Gardener Belmont Modern Slavery Statement

Our commitment to ending modern slavery

Gardener Belmont publishes this Modern Slavery Statement to affirm a clear and enduring commitment: we have a zero-tolerance policy on all forms of slavery, forced labour, human trafficking and servitude. This policy applies across our direct operations, contractors and extended supply chain. The purpose of this modern slavery and human trafficking statement is to set out the actions we take to prevent exploitation, and to make explicit the responsibilities of our leadership, procurement teams and suppliers.

We require that all employees, partners and suppliers operate in accordance with our anti-slavery policy. Any breach triggers immediate investigation and may lead to contract termination, debarment from future engagement and referral to authorities where necessary. Our zero tolerance approach includes clear disciplinary measures, contractual remedies and escalation procedures to ensure swift corrective action when non-compliance is identified.

To reduce risk we undertake rigorous supplier due diligence and deliver frequent supplier audits tailored to risk level. Our supplier management programme includes:

• Initial screening on labour practices, documentation and recruitment methods
• Risk-based on-site and remote supplier audits conducted by trained auditors
• Contract terms mandating compliance with our anti-slavery standards and the right to remedial audit

Supplier audits are complemented by supplier improvement plans, follow-up verifications and the suspension of trading where remediation is inadequate. These actions form the backbone of our supplier compliance process for the modern labour statement we uphold.

Our slavery prevention measures are embedded in procurement cycles and contractor engagement. We incorporate slavery risk indicators into tender evaluations, require self-assessment questionnaires and validate certification or third-party audit results for high-risk suppliers. Training is provided to procurement and HR staff so they can spot warning signs such as unusual recruitment fees, excessive working hours or restrictions on worker movement.

Reporting channels and whistleblower protections

Gardener Belmont provides multiple safe and confidential reporting channels where people can raise concerns about suspected modern slavery or exploitation. Reports may be submitted through internal reporting lines, an anonymous reporting mechanism and direct escalation to the compliance team. We guarantee that all allegations are treated seriously, investigated promptly and handled impartially, with protections in place for whistleblowers to prevent retaliation.

Our investigation process follows clear steps: log the report, triage risk, conduct interviews and document reviews, propose remedial measures and monitor outcomes. Where exploitation is confirmed, remedial actions include supplier remediation plans, worker remediation and, where required, termination of the supply relationship. We also use learnings from investigations to improve policy, training and supplier selection criteria.

Risk assessment and continuous monitoring are essential parts of our slavery and forced labour prevention strategy. We prioritise high-risk goods, services and geographies and maintain detailed risk registers. Periodic reviews of labour supply chains, combined with targeted audits and performance KPIs, enable us to detect emerging risks and allocate resources effectively to the areas of greatest concern.

Annual review and continuous improvement — This Modern Slavery Statement is subject to an annual review by senior management and the Board. The annual review evaluates the effectiveness of supplier audits, the status of reported incidents, the success of remediation plans and training completion rates. Based on this assessment we update policies, reallocate audit frequency, and set measurable goals to strengthen our anti-slavery performance year on year.

Conclusion: Gardener Belmont remains resolute in its duty to prevent modern slavery across its operations and supply chain. We will continue to expand supplier audits, enhance reporting channels and refine our risk-based approach. This modern slavery statement is endorsed at the highest level and will be used to drive continuous improvement, accountability and transparency in our fight against exploitation.