Gardener Archway Modern Slavery Statement

Gardener Archway publishes this Modern Slavery Statement to reaffirm our commitment to identifying and eliminating all forms of modern slavery, forced labour and human trafficking across our operations and supply chain. We adopt a zero-tolerance policy towards exploitation. This modern slavery declaration sets out our policies, due diligence, risk mitigation and the measures we take to ensure ethical conduct by everyone associated with Gardener Archway.

Our zero-tolerance stance

We operate a clear and unambiguous zero-tolerance policy on any form of slavery or human trafficking. All employees, contractors and suppliers are required to comply with the anti-slavery rules embedded in our code of conduct. We make it explicit that any breach of the slavery and human trafficking statement will result in immediate action, which may include contract termination, disciplinary measures and referral to appropriate authorities as needed.

In setting out our responsibilities, Gardener Archway’s modern slavery policy describes the processes we use to assess and manage the risk of modern slavery. We perform regular supplier screening and risk assessments, and we require suppliers to confirm compliance with our anti-slavery standards. We communicate expectations clearly and require written confirmation that their workforce is treated lawfully and ethically.

We carry out targeted supplier audits and site inspections to verify labour standards. Supplier audits include documentation checks, workforce interviews and sampling of employment records. Where audits indicate potential concerns, we implement corrective action plans with defined timelines and follow-up inspections. These supplier compliance checks form a key part of our anti-slavery monitoring programme and help us ensure that our suppliers adhere to the modern slavery policy and our ethical sourcing code.

Our due diligence framework includes screening at onboarding, continuous monitoring and periodic re-assessment. We prioritise suppliers by risk profile, considering factors such as geography, industry, labour intensity and subcontracting practices. In high-risk areas we require enhanced transparency, third-party verification and, where feasible, labour-supply mapping to trace and mitigate the risk of forced labour.

Reporting channels and whistleblowing

Gardener Archway provides multiple confidential reporting channels to enable workers, suppliers and third parties to raise concerns about potential slavery or exploitation. These reporting channels are accessible, protected and available in multiple languages where necessary. Reports are handled promptly, investigated impartially and escalated to senior management. We encourage the use of our secure channels and guarantee protection from retaliation for good-faith reporting.

Training, policies and continuous improvement

We deliver regular training on the modern slavery statement and modern slavery policy to employees and relevant suppliers. Training covers recognising signs of exploitation, how to report concerns, and the obligations of procurement teams. We maintain internal policies that reflect our commitment to human rights and embed anti-slavery requirements in contractual terms. Prevention and remediation are central to our approach.

We maintain a formal procedure for remediation where victims of exploitation are identified. Remediation focuses on safety, restoration of rights and, where appropriate, compensation. We work cooperatively with authorities, NGOs and expert advisors to ensure appropriate support. Our approach balances enforcement with compassion, aiming to remove individuals from exploitative circumstances and prevent recurrence.

Annual review and transparency: Gardener Archway undertakes an annual review of our anti-slavery measures, supplier audit outcomes and risk assessments. This review informs continuous improvement of our policies, training and controls. Results and actions arising from the review are reported to senior leadership and used to refine our work on supplier audits, reporting channels and policy governance. We remain committed to increasing transparency and strengthening our slavery-prevention efforts across all operations.

Key commitments and next steps include:

• Maintain zero-tolerance: Continue enforcing our zero-tolerance policy across the business.
• Expand supplier audits: Increase the scope and frequency of audits, prioritising higher-risk suppliers and regions.
• Enhance reporting channels: Improve accessibility and protective measures for whistleblowers.
• Annual review: Conduct and act on the outcomes of a comprehensive annual review of our modern slavery measures.

Gardener Archway’s slavery and human trafficking statement is an ongoing commitment rather than a single action. We will continue to review, strengthen and report on our anti-slavery and human trafficking measures, ensuring that our modern slavery statement, modern slavery policy and broader human rights approach remain effective, proportionate and aligned with evolving best practice and legal obligations.