Gardener Sudbury - Modern Slavery Statement

Gardener Sudbury sets out this Modern Slavery Statement to declare our commitment to preventing slavery and human trafficking in all areas of our operations and supply chains. This anti-slavery statement reflects our responsibilities under applicable laws and underlines a company-wide approach that is ethical, transparent and accountable. We recognise that a robust modern slavery policy is essential to protect workers, communities and the integrity of our business.

Scope and Intent

This modern slavery and human trafficking statement applies to all employees, contractors and suppliers who provide goods and services to Gardener Sudbury. It covers our direct operations and extends to subcontractors and suppliers. We adopt a zero-tolerance approach to any form of forced labour, debt bondage, servitude or human trafficking and expect the same high standards from our partners.

Principles and Commitments

Our commitment is clear: no form of modern slavery will be tolerated. Gardener Sudbury will not knowingly engage with any entity that exploits workers. We will continually assess and strengthen our anti-slavery measures and ensure senior leadership oversight and resourcing for compliance with this slavery statement and associated policies.

Zero-Tolerance Policy

Our zero-tolerance policy means that any employee, contractor or supplier found to be involved in slavery, human trafficking or severe exploitation will face disciplinary action, up to and including termination and referral to the appropriate authorities. The policy is enforced consistently and is an integral part of staff contracts, supplier agreements and procurement criteria.

Supplier Audits and Due Diligence

We require all material suppliers to undergo due diligence checks and regular audits. Our supplier audit program includes:

• Verification of labour practices and working conditions;
• Checks for appropriate right-to-work documentation and fair recruitment practices;
• On-site inspections and third-party assessments where risk indicators are identified;
• Contractual clauses obligating remedial action and cooperation with investigations.

Where audits identify non-compliance, we work with suppliers to implement corrective action plans and, where improvements are not achieved, we reserve the right to suspend or terminate agreements. Our supplier standards form a central part of our slavery and human trafficking statement.

Reporting Channels and Whistleblowing

Gardener Sudbury provides multiple reporting channels to enable confidential and, where desired, anonymous reporting of concerns related to modern slavery. Employees and third parties can raise issues without fear of retaliation. Reports are investigated promptly by a designated compliance team. We emphasise clear escalation paths and maintain records of investigations and outcomes to ensure accountability.

Training, Risk Assessment and Continuous Monitoring

We conduct regular risk assessments to identify areas most vulnerable to exploitation, including seasonal supply fluctuations and high-risk supplier categories. Mandatory training on the anti-slavery policy is delivered to staff and procurement teams to ensure awareness of indicators of exploitation and correct response protocols. Continuous monitoring mechanisms include supplier performance metrics, periodic spot-checks and incorporation of modern slavery risks in new project risk registers.

Annual Review and Statement Approval

Gardener Sudbury reviews this anti-slavery policy and the broader slavery prevention framework at least once every 12 months. The annual review evaluates the effectiveness of supplier audits, reporting channels, training uptake and remedial actions. Findings inform updates to the modern slavery statement, risk-based controls and resource allocation. Senior leadership formally approves the updated statement and it is communicated internally to all staff and externally to business partners.

Declaration: By publishing this Modern Slavery Statement, Gardener Sudbury reaffirms its commitment to ethical conduct, respect for human rights and continuous improvement. We will continue to strengthen our practices, collaborate with industry peers and respond decisively to any identified instances of exploitation to ensure our operations and supply chains remain free from modern slavery.