Gardener Sutton Modern Slavery Statement

Our Commitment to Preventing Modern Slavery

Gardener Sutton is committed to the highest standards of ethical conduct. This Modern Slavery Statement sets out our zero-tolerance approach to modern slavery and human trafficking, clarifying responsibilities across our operations and supply network. We publish this anti-slavery statement to demonstrate how we assess and address risks related to slavery and human trafficking in the course of our business.

We maintain a clear zero-tolerance policy that applies to all employees, contractors and suppliers. The policy is enforced by our leadership team and forms part of mandatory training. Any breach of the anti-slavery or labour standards policy is treated as a disciplinary matter and may lead to contract termination and legal action where appropriate.

Our Modern Slavery and Human Trafficking Statement requires all business partners to comply with our standards. We expect suppliers to adhere to fair labour practices, safe working conditions and to prohibit forced labour. Failure to meet these expectations will trigger remedial measures or termination of the business relationship.

Risk Assessment and Due Diligence

Gardener Sutton performs a risk-based assessment across sectors and geographies where risks of modern slavery are higher. Our risk assessment process reviews labor practices, recruitment methods and working hours within supply chains. The assessment is updated regularly and informs our supplier engagement strategy.

We operate a robust supplier due diligence program that includes documentation checks, contractual clauses and third-party verification where necessary. Strong supplier onboarding procedures and periodic reviews ensure ongoing compliance with our Modern Slavery Policy and anti-slavery expectations.

Supplier audits are a core control in our compliance framework. We carry out scheduled and unannounced audits, using both internal audit teams and independent auditors. Audit findings are recorded, and corrective action plans are agreed and tracked until closure. Key audit focus areas include worker recruitment, employment terms, pay, freedom of movement and grievance access.

Reporting Channels and Whistleblowing

We provide multiple secure reporting channels for workers, suppliers and third parties to raise concerns. These include a confidential whistleblowing hotline, an anonymous reporting portal and direct reporting to designated compliance officers. Reports are handled promptly, confidentially and with protections against retaliation.

All allegations are investigated by trained staff and, where credible, escalated to senior management and the board. We ensure that victims receive appropriate support and remediation, and we cooperate with statutory authorities when required. Our reporting procedures are designed to be accessible to all workers, including those in our supply chain.

As part of our transparency commitments, we maintain clear records of reports, investigations and remedial actions. We do not publish personal identifying details but will disclose steps taken to remedy confirmed instances of exploitation in line with data protection and privacy obligations.

Training, Governance and Annual Review

Training and awareness are essential elements of our anti-slavery approach. We deliver mandatory training for staff with procurement, HR and site responsibilities, emphasising recognition of indicators of forced labour and safe reporting procedures. Management performance metrics include compliance with the anti-slavery statement and supplier oversight responsibilities.

Governance is provided by our compliance committee and senior leadership, who review modern slavery risks and mitigation measures. We incorporate anti-slavery due diligence into procurement contracts and evaluate supplier performance using objective criteria.

We conduct an annual review of this modern slavery statement, our policies and our due diligence processes. The annual review examines the effectiveness of supplier audits, the adequacy of reporting channels and the outcomes of investigations. Findings from the review drive improvements to policy, training and operational controls to strengthen our response to slavery and human trafficking risks.

Continuous Improvement and Accountability

Gardener Sutton is committed to continuous improvement. We will continue to refine our risk management, extend supplier audits where necessary and enhance worker protections across supply chains. Our approach is proactive: identifying risks early, taking decisive action and ensuring accountability for results.

Key priorities for the coming year include expanding supplier auditing coverage, increasing training frequency, and improving transparency in remediation processes. We welcome constructive engagement with stakeholders who share our ambition to eliminate modern slavery.

This Modern Slavery Statement represents our ongoing pledge to prevent exploitation and uphold human dignity across all our activities. It is approved by Gardener Sutton's senior leadership and will be reviewed at least annually to ensure continued relevance and effectiveness.