Gardener Earls Court Modern Slavery Statement

Gardener Earls Court publishes this Modern Slavery Statement to affirm our commitment to preventing forced labour and human trafficking in all parts of our operations and supply chain. Our stance is clear: we have a zero-tolerance policy toward modern slavery and any form of exploitation. This anti-slavery statement applies to all employees, contractors and suppliers engaged by Gardener Earls Court, and sets out the measures we take to identify, prevent and remediate risk.

Our modern slavery policy drives a culture of vigilance across the business. We recognise that risks can arise at many points — recruitment, subcontracting, seasonal labour and within the extended supplier network. As part of our modern slavery compliance, we require everyone working with us to adhere to our values and to the standards laid out in our supplier code of conduct.

We have embedded practical steps into procurement and sourcing procedures to assess and mitigate slavery risks. These steps include:

• pre-contract due diligence on labour practices;
• periodic supplier questionnaires and site checks;
• remedial action plans where risks are identified.

Policy Framework and Expectations

Our anti-slavery statement sets expectations for suppliers and contractors. We demand legal compliance and ethical conduct. Suppliers must demonstrate transparent labour practices, lawful wage payments and respectful working conditions. Breaches of the modern slavery statement or our supplier code may lead to corrective measures, up to and including contract termination.

To operationalise these commitments we conduct supplier audits and risk-based assessments across our supply chain. Audit activity focuses on high-risk categories and regions and combines document review, site visits and worker interviews. Findings are tracked and escalated internally to ensure timely remediation.

Training is delivered to procurement teams and frontline managers to raise awareness of forced labour indicators and the steps to take where concerns arise. We promote a culture where staff feel supported to act. Reporting channels are made available in multiple formats to encourage disclosure.

Reporting Channels and Enforcement

We maintain confidential and secure reporting mechanisms so that potential instances of modern slavery can be raised without fear of retaliation. Reporting channels include internal hotlines, anonymous submission options and designated compliance contacts. All reports are treated with priority, investigated promptly and appropriate remedial actions are implemented.

Core elements of our supplier assurance program include:

• regular supplier audits and third-party verification;
• contract clauses requiring compliance with anti-slavery standards;
• capacity-building sessions for suppliers on labour rights;
• clear escalation protocols for suspected breaches.

Commercial decisions are informed by compliance considerations; where necessary, we will disengage from relationships that fail to demonstrate sustained improvement. We use contractual levers and remedial plans to protect workers and eliminate exploitative practices.

Our commitment is sustained by governance and transparency. The board and senior leadership have oversight of modern slavery risks and receive regular reports on audits, investigations and mitigation progress. We integrate findings from supplier audits into procurement strategy and risk management processes to prevent recurrence.

The effectiveness of this modern slavery policy is monitored through a set of key indicators, including the number of audits completed, incidents reported, remedial actions closed and training sessions delivered. We review these metrics quarterly and report material issues to executive leadership.

We will update this modern slavery statement annually as part of continuous improvement and accountability. The annual review includes a reassessment of risk, evaluation of our supplier assurance activities, updates to training and improvements to reporting channels. Our aim is to ensure Gardener Earls Court remains proactive, transparent and relentless in the fight against modern slavery and forced labour.