Gardener Elephant and Castle - Modern Slavery Statement

Gardener Elephant and Castle publishes this Modern Slavery Statement to set out our commitment to preventing forced labour, human trafficking and other forms of exploitation across our operations and supply chain. Our anti-slavery declaration is founded on a zero-tolerance approach: we will not accept modern slavery within our business or among our suppliers. This modern slavery policy applies to all employees, contractors and procurement partners.

We adopt a proactive stance in identifying risks and enforcing compliance. Our modern slavery statement for Gardener Elephant and Castle clarifies responsibilities at every level of the organisation. Senior management is accountable for implementation and teams receive training on recognising signs of exploitation and coercive labour practices. Our people policies reinforce respect for human rights, fair treatment and lawful working conditions across our sites and projects.

This statement outlines core measures we use to deter, detect and remediate instances of exploitation. Our Modern Slavery Act statement references relevant legislation and industry best practice. Supplier audits and due diligence are central to our approach: all new suppliers face risk-based screening, while high-risk relationships are subject to enhanced checks and ongoing monitoring.

Supplier Standards and Audit Programme

We require suppliers to adhere to our Supplier Code of Conduct, which includes clear expectations on wages, working hours, freedom of movement and the prohibition of forced or bonded labour. We maintain a risk-based audit cycle that uses documentary review, on-site inspections and worker interviews. Findings trigger corrective action plans, and persistent non-compliance may lead to contract termination. Our procurement team works with suppliers to remediate gaps where possible.

Supplier audits focus on areas most commonly associated with modern slavery risks, including recruitment practices, subcontracting, and accommodation arrangements. We also emphasise transparency in recruitment fees and the right of workers to retain passports or identity documents. In partnership with third-party specialists, we verify payroll, worker interviews and health and safety conditions to gain a full picture of supplier compliance.

Key elements of our supplier control framework include:

• Pre-engagement risk assessment and screening
• Periodic on-site and remote auditing by trained assessors
• Mandatory corrective action plans and follow-up reviews

Reporting Channels and Remediation

We provide multiple, secure reporting channels for workers, contractors and third parties to raise concerns about suspected modern slavery. Reports can be raised anonymously through an internal whistleblowing mechanism, or escalated to our compliance team. Every report is treated with confidentiality, investigated promptly, and documented. We commit to protecting whistleblowers from retaliation and to supporting victims through referral to appropriate services.

Our remediation protocol is victim-centred: we prioritise safety, medical care, legal support and, where appropriate, repatriation or alternative employment. Remediation outcomes are monitored to ensure effectiveness. We also review contractual relationships and take enforcement action, including termination, against suppliers who fail to address verified abuses.

Annual review: We review this modern slavery policy annually to assess effectiveness, incorporate lessons learned from investigations and audits, and update prevention measures. The annual review includes stakeholder feedback, audit results, training records and performance metrics. Changes to the policy or supplier management processes are communicated across the organisation to reinforce our ongoing commitment to eradicating modern slavery.