Gardener Gunnersbury Modern Slavery Statement

This Modern Slavery Statement sets out Gardener Gunnersbury's commitment to preventing modern slavery and human trafficking across our operations and supply chains. We recognise that slavery, servitude, forced labour and human trafficking are abhorrent crimes and that proactive measures are required to reduce the risk of exploitation in all forms. This slavery and human trafficking statement applies to all staff, contractors and suppliers engaged by Gardener Gunnersbury.

We operate a zero-tolerance policy towards any form of forced labour or exploitation. Our anti-slavery policy is enforced through clear standards of conduct, mandatory training for managers and workers, and integrated risk management procedures. All employees are required to adhere to our code of conduct which explicitly forbids the use of coercive labour practices; any breach will result in disciplinary action, up to and including dismissal.

Our expectations of suppliers and partners are explicit: we require compliance with local and international labour laws, transparent recruitment practices and documented payment of wages. To support this we publish a procurement code that sets minimum requirements for workers' rights and safety. Key elements include a commitment to:

• Safe working conditions and lawful working hours
• Fair pay and transparent payroll systems
• No use of forced or bonded labour and ethical recruitment

Supply Chain Due Diligence and Supplier Audits

Gardener Gunnersbury conducts risk-based due diligence across our supply chain. We undertake supplier audits and assessments that examine labour practices, recruitment fees, identity verification and living conditions where relevant. Audits combine documentary review, worker interviews and site inspections and are prioritised in higher-risk sectors. Where issues are identified, we require corrective action plans with time-bound milestones and follow-up reviews to ensure remediation.

We use contractual clauses to require compliance with our modern slavery policy and reserve the right to terminate relationships that fail to remediate serious breaches. Our procurement team provides ongoing support to suppliers to build capacity for improved labour standards and to share best practice across networks.

To further reduce risk we carry out supplier screening at onboarding and periodically thereafter. Screening covers geographic risk, sector risk and indicators of vulnerability. We also encourage subcontractor transparency and expect primary suppliers to flow down ethical obligations to their sub-tier suppliers.

Reporting Channels, Whistleblowing and Remediation

Employees, contractors and third parties are encouraged to report concerns through our established reporting channels. Reports may be made anonymously where permitted, and all allegations are treated seriously and investigated promptly. We have a formal whistleblowing procedure and a non-retaliation commitment so that individuals who raise concerns in good faith are protected. Reports are triaged, investigated and escalated to senior management as necessary.

Where exploitation is identified we work to secure safe remediation for affected workers, which may include repatriation support, payment of owed wages, medical care and collaboration with law enforcement and specialist support organisations. Our approach balances immediate worker safety with appropriate disciplinary or contractual action against offending parties. We maintain records of investigations and outcomes to inform continuous improvement.

Governance, Review and Continuous Improvement: Our modern slavery governance framework assigns clear responsibilities for compliance and oversight. The Board and senior leadership review modern slavery risks and mitigation activity regularly. We commit to an annual review of this anti-slavery statement and associated policies to reflect changes in our business, the supply chain and emerging best practice. Findings from supplier audits, incident investigations and training programmes feed into this review, and action plans are updated accordingly.

Gardener Gunnersbury will continue to strengthen controls, increase transparency and collaborate with industry peers to tackle modern slavery. We remain resolute in our commitment to ethical labour standards and to ensuring our modern slavery policy is both meaningful and effective across all aspects of our operations.