Gardener Euston - Modern Slavery Statement

Gardener Euston is committed to preventing any form of exploitation in our operations and supply chains. This modern slavery statement explains our approach to identifying, preventing and responding to slavery, human trafficking and forced labour risks. We adopt a zero-tolerance policy towards modern slavery of any kind and expect the same high standards from all partners, contractors and suppliers that support our business activities.

We publish this anti-slavery statement to set out clear obligations and practical steps. Our Modern Slavery Policy requires all employees to act responsibly and to report concerns. Key commitments include:

• Zero-tolerance policy enforced across all operations
• Due diligence and risk-based supplier assessment
• Regular training and awareness for staff and contractors

Supplier Accountability and Audit Programme

We operate a structured supplier audit and assessment regime to ensure compliance with our slavery and human trafficking statement expectations. Supplier audits include documentation reviews, contractual clauses, on-site checks where feasible and third-party verifications in higher-risk categories. Our procurement team uses risk indicators such as industry sector, geography and employment practices to prioritise audits and follow-up actions.

All suppliers are required to sign contractual warranties confirming adherence to our anti-slavery and human trafficking policies. Where audits or assessments reveal non-compliance, we take proportionate remedial steps ranging from corrective action plans to contract termination for persistent breaches. We also provide guidance and support to help suppliers meet acceptable standards and reduce risk in their own supply chains.

Reporting Channels and Whistleblowing

Gardener Euston maintains clear reporting channels for concerns related to slavery and trafficking. Workers, suppliers and stakeholders are encouraged to report issues through confidential mechanisms. Our reporting channels include a secure internal ethics hotline, anonymous submission forms and direct escalation to senior management where needed. We guarantee that reports will be investigated promptly and that whistleblowers will be protected from retaliation.

Reports are handled with confidentiality and care. Investigation outcomes are documented and, where appropriate, triggers for remediation are actioned immediately. Our remedial measures may include worker support, corrective actions for suppliers and collaboration with relevant authorities when criminal behaviour is suspected. Employees receive training on recognising signs of exploitation and on how to use the reporting channels effectively.

We incorporate modern slavery risk considerations into our broader corporate compliance framework and procurement decisions. Training programmes educate staff at all levels about the signs of forced labour, fair recruitment practices and responsible sourcing. Recruitment and HR processes are designed to prevent debt bondage, confiscation of identity documents or other abusive practices.

Annual review: Gardener Euston conducts an annual review of its slavery and trafficking statement, supplier audit results and remediation outcomes. The review evaluates the effectiveness of policies, identifies emerging risks and sets improvement targets for the coming year. Findings are used to update the anti-slavery policy, enhance supplier monitoring and refine staff training.

In closing, our slavery and human trafficking statement demonstrates a firm corporate stance: no tolerance for exploitation. We will continue to strengthen our systems, work collaboratively with the supply chain and respond decisively to any evidence of modern slavery. This modern slavery policy and related procedures remain live documents subject to continuous improvement through stakeholder engagement, robust supplier audits, clear reporting channels and regular annual review.