Gardener Barnes Modern Slavery Statement

Gardener Barnes sets out this Modern Slavery Statement as a clear declaration of our commitment to an anti-slavery and human trafficking approach across our operations and supply chains. We operate a zero-tolerance policy to any form of modern slavery, forced labour or exploitation, and we expect the same standards from all partners and suppliers. This modern slavery policy is embedded in our corporate values and recruitment practices, ensuring that every employee understands that exploitation is unacceptable.

Scope and Commitment

This slavery and human trafficking statement applies to all entities within the Gardener Barnes group and covers our procurement, contracting and operational activities. Our anti-modern slavery statement explains responsibilities at board, management and operational levels. We are committed to continual improvement in our modern slavery prevention measures, and we document and communicate our standards regularly.

To implement our commitments we maintain practical controls and supplier assurance mechanisms. These include a structured supplier onboarding process, contractual clauses prohibiting forced labour, and targeted supplier audits. Key elements of our supply chain assurance are:

• Risk-based supplier audits and site visits to verify working conditions and employment practices.
• Mandatory supplier declarations and contractual anti-slavery warranties.
• Training and capacity building for procurement staff and supplier managers.

Due Diligence and Supplier Audits

Our due diligence process for the anti-slavery statement includes risk assessment, desk-based checks and on-site supplier audits where risk indicators are identified. We prioritise audits in higher-risk regions and sectors and record findings in our supplier compliance register. Audits are conducted by trained auditors or accredited third parties and cover recruitment practices, wage payments, working hours and freedom of movement.

Reporting channels are fundamental to our approach. Gardener Barnes operates confidential and accessible reporting mechanisms for workers, suppliers and stakeholders to raise concerns about modern slavery or exploitation. We maintain multiple secure channels for reporting and guarantee protection from retaliation for whistleblowers. All reports are logged, triaged and investigated by a cross-functional team, and corrective action plans are put in place where issues are identified.

We also maintain a formal escalation process to ensure timely remediation. Where evidence of modern slavery is found, immediate steps are taken to secure victim safety and ensure fair remediation. We require suppliers to cooperate with investigations, implement corrective actions and, where necessary, terminate relationships with non-compliant parties. Our approach balances remediation, accountability and continuous improvement.

Gardener Barnes communicates expectations through supplier codes of conduct and contractual commitments. We provide guidance and training to suppliers and internal teams on compliance with the anti-modern slavery statement and modern slavery policy. Suppliers are expected to maintain effective grievance mechanisms and to support independent verification during audits.

Our monitoring framework includes regular review cycles, performance indicators and the collection of supplier data to inform risk profiling. As part of our slavery and human trafficking statement we publish an annual summary of audit outcomes and corrective actions internally, and we use learnings to refine procurement policies and supplier engagement strategies. Transparency and accountability are central to our efforts.

In line with our governance commitments, Gardener Barnes undertakes an annual review of this anti-slavery statement and associated policies to assess effectiveness and identify improvements. The annual review examines audit results, incident reports, remediation outcomes and changes in risk exposure. Findings from the review drive updates to training, supplier audit frequency and contractual clauses, and are considered by senior leadership to ensure ongoing oversight and resources are allocated where needed.

We remain resolute in our objective to prevent modern slavery in all its forms. This modern slavery declaration for Gardener Barnes is supported by robust governance, active supplier engagement and clear reporting channels to detect and address risks. Our anti-slavery statement will continue to evolve as we learn from audits and stakeholder engagement, and we will persist in promoting respect for human rights across our entire supply chain.

By sustaining rigorous supplier audits, maintaining confidential reporting channels and committing to an annual review cycle, Gardener Barnes aims to identify and eradicate instances of forced labour and exploitation. We encourage a culture where workers are respected, rights are protected and any suspicion of wrongdoing is promptly investigated and remedied under our zero-tolerance policy.

We affirm our ongoing commitment to these principles and to strengthening our modern slavery prevention measures across all operations, procurement and partnerships.