Gardener Highbury - Modern Slavery Statement

Gardener Highbury is committed to ensuring that slavery, forced labour, and human trafficking have no place in our operations or supply chains. Our modern slavery statement sets out a clear commitment to ethical conduct, transparency and the practical steps we take to identify, prevent and remedy any risks related to modern slavery and human trafficking. This policy reflects our corporate values and a zero-tolerance policy toward exploitation.

We operate a zero-tolerance approach to all forms of exploitation. Our modern slavery policy mandates immediate action if any instance of forced labour, bonded labour or other abusive practices is identified. All employees and contractors are required to comply with this anti-slavery stance and must report concerns through the approved internal channels. Non-compliance will lead to disciplinary measures, contract termination and, where appropriate, legal action.

This slavery and human trafficking statement applies across all Gardener Highbury business units, subsidiaries and joint ventures where we exercise control. We define modern slavery broadly, to include forced labour, human trafficking, debt bondage, child labour and any practice that deprives a person of their freedom for personal or commercial gain. Our anti-slavery statement is intended to meet applicable regulatory expectations and to go beyond compliance by embedding prevention measures into daily operations.

Supplier Expectations and Due Diligence

We require suppliers, contractors and business partners to adhere to our modern slavery statement and to demonstrate alignment with our values. Procurement processes include risk-based due diligence and contractual clauses that prohibit forced labour. Our expectations include:

• Transparency in labour practices and worker recruitment.
• Documentation of working hours, wages and conditions.
• Freedom for workers to terminate employment and to move workplaces without penalty.

These measures are part of our supplier code of conduct and are monitored through ongoing engagement.

Supplier Audits and Remedial Action

We conduct supplier audits on a risk-prioritised basis. Audits may be carried out by our internal team or independent third parties and include on-site inspections, worker interviews and document verification. Where issues are identified we implement corrective action plans, set clear timelines for remediation, and follow up to verify improvements. Serious breaches result in contract suspension or termination and, where necessary, referral to law enforcement. Our supplier audit programme is continuously refined to address emerging risks.

Reporting channels are a critical part of our approach. Employees, suppliers and other stakeholders can raise concerns about modern slavery through multiple anonymous and confidential routes. We provide internal reporting systems protected by non-retaliation guarantees, and we ensure that whistleblowers are supported and their anonymity is respected. Confidential reporting is actively promoted, and any reports are investigated promptly by trained personnel.

To strengthen prevention we invest in training and capacity building. Staff involved in procurement, HR and site management receive regular training on recognising signs of exploitation and on the procedures for escalation. We also work collaboratively with suppliers to build their capability to identify and address modern slavery risks. Our approach emphasises continuous improvement, transparency and shared responsibility.

Gardener Highbury commits to an annual review of this modern slavery policy and associated processes. Each year the Board and senior management will review incident data, audit outcomes, remediation effectiveness and supplier performance metrics to assess whether our practices remain robust and proportionate. The annual review informs updates to our policy, strengthens controls and directs resources to high-risk areas. We will continue to publish a statement of progress and to demonstrate our ongoing commitment to eradicating modern slavery across our operations and supply chains.