Gardener Downham Modern Slavery Statement

Gardener Downham declares a zero-tolerance approach to exploitation and forced labour. This Modern Slavery Statement sets out the steps we take to identify, prevent and address modern slavery and human trafficking risks across our operations and supply chains. We recognise the grave harm caused by modern slavery and commit to a proactive, transparent anti-slavery stance that informs procurement, contracting and daily practices.

Our anti-slavery policy is embedded in company values and applies to all colleagues, contractors and partners. Zero-tolerance policy means we will not tolerate any form of involuntary labour, debt bondage, child labour, or exploitative working conditions. We require that everyone acting on behalf of Gardener Downham upholds the standards in this modern slavery policy. Compliance is mandatory and breaches lead to investigation and corrective action.

To operationalise our commitments we implement supplier due diligence and systematic supplier audits. Our supplier assessment process screens new and existing partners for slavery and trafficking risks using risk indicators such as geographic region, labour-intensity of services, and subcontracting practices. We deploy targeted supplier audits and on-site inspections to validate working conditions and documentation, and to ensure adherence to our slavery and human trafficking provisions.

We maintain a risk-based approach to supply chain management.

Supply Chain Risk

Where risk is higher, we require enhanced controls including worker interviews, payroll verification and third-party audit reports. Our procurement teams are trained to spot red flags and escalate concerns to senior management. Transparency in supply relationships is central to mitigating modern slavery risk.

Training and awareness are core to prevention. All staff in procurement, operations and HR receive regular training on how to recognise and respond to signs of exploitation. We encourage an organisational culture where concerns about forced labour or unfair practices are raised promptly. Reporting channels are accessible and confidential, enabling workers and third parties to report issues without fear of retaliation.

Contractual clauses and supplier codes of conduct set clear expectations. Our contracts include explicit anti-slavery and human trafficking clauses, allowing audit rights, remediation requirements and termination for breach. We require suppliers to flow relevant obligations down to their subcontractors and to maintain accurate labour records. Failure to comply triggers a remedial plan or contract termination.

We carry out ongoing supplier audits to verify compliance.

Supplier Audits and Monitoring

Audits are a mix of announced and unannounced visits, documentary checks and worker interviews. Findings are rated by severity and followed by corrective action plans. We use a combination of internal audits and independent third-party verifiers to ensure objectivity and continual improvement.

Our reporting channels include confidential internal hotlines, anonymous reporting mechanisms and escalation to senior governance bodies. Reports of suspected modern slavery are investigated promptly and with appropriate sensitivity. We protect whistleblowers and ensure that reports trigger timely remediation, support for affected workers and, where necessary, referral to legal authorities.

An annual review of this anti-slavery statement and related processes assesses effectiveness and identifies improvements. We set measurable KPIs such as audit coverage, corrective action completion rates and training uptake. The Board and senior leadership receive regular updates on slavery risk, remediation outcomes and progress against our modern slavery commitments. This public modern slavery statement reflects our ongoing responsibility to eradicate forced labour from our operations.