Gardener Addiscombe Modern Slavery Statement

Gardener Addiscombe publishes this Modern Slavery Statement to set out our commitment to preventing forced labour, human trafficking and exploitation across our operations and supply chains. This anti-slavery statement describes the policies and steps we take to ensure that modern slavery has no place in our business or among our suppliers. Our modern slavery declaration is aligned with our values and legal obligations.

We operate a zero-tolerance policy towards any instances of slavery, servitude, forced or bonded labour and human trafficking. This policy is embedded in our employee code of conduct and procurement standards. All staff and contractors are required to comply with these expectations and to act in accordance with our values of fairness and respect.

Our company publishes this Modern Slavery policy to explain how Gardener Addiscombe identifies, assesses and mitigates modern slavery risks. We recognise that risks may arise in direct employment, in temporary labour, and within third-party suppliers, sub-contractors and partners. The statement on modern slavery below explains our governance, due diligence and training measures.

Policies, Procedures and Governance

Gardener Addiscombe maintains a framework of policies that supports our anti-slavery work. These include recruitment checks, right-to-work verifications, and supplier requirements. Our HR and procurement teams share responsibility for enforcement. We require suppliers to accept contractual clauses that prohibit modern slavery and to cooperate with our compliance checks.

We provide regular training and awareness sessions to employees and managers. Training covers identifying signs of exploitation, reporting channels and the responsibilities of those involved in recruitment and supplier management. Staff are encouraged to raise concerns without fear of retaliation under our whistleblowing provisions.

Our governance approach includes board oversight and a nominated senior lead responsible for implementing this modern slavery declaration. The board reviews significant supplier relationships and high-risk categories annually and directs remedial action where necessary.

Supplier Audits, Risk Assessment and Remediation

We undertake systematic supplier audits and risk assessments to verify compliance with our anti-slavery expectations. Audits may be conducted by internal teams or independent third parties and include documentation reviews, site visits and worker interviews where appropriate. The audit programme prioritises higher-risk suppliers and sectors.

Key elements of our supplier audit and monitoring programme include:

• Pre-contract risk screening and due diligence for new supply relationships;
• Regular site-based and remote audits for medium and high-risk partners;
• Corrective action plans with time-bound milestones for any non-compliance found;
• Termination clauses for persistent or severe breaches of our anti-slavery requirements.

Reporting channels are confidential and accessible. Employees and third parties can report concerns through established internal channels, including secure reporting lines and designated compliance contacts. Reports may be raised anonymously and will be investigated promptly and fairly. We emphasise protection for whistleblowers and strong follow-up actions where issues are substantiated.

We will take proportionate remediation steps, which may include supplier corrective action, termination of contracts, referral to law enforcement, and support for affected workers where appropriate. Our aim is to ensure immediate safety for victims and to prevent recurrence.

Gardener Addiscombe commits to an annual review of this anti-slavery statement and related policies. Each year we will evaluate the effectiveness of our measures, update risk assessments, publish changes to our approach and set objectives for continuous improvement. The review process includes feedback from stakeholders across procurement, human resources and legal teams.

In summary, this statement on modern slavery demonstrates our ongoing commitment to eradicating modern slavery from our business and supply chains. We maintain a robust zero-tolerance stance, deliver proactive supplier audits, provide clear reporting channels and undertake an annual review to strengthen our response to modern slavery risks.