Gardener Osterley - Modern Slavery Statement

This Modern Slavery Statement sets out Gardener Osterley’s commitment to preventing all forms of forced labour, exploitation and trafficking across our operations and supply chains. We publish this anti-slavery policy to be clear that we operate a zero-tolerance approach to modern slavery and to describe the steps we take to deliver on that commitment.

Our zero-tolerance policy to modern slavery and human trafficking means that any form of coerced labour, debt bondage, involuntary servitude, or exploitative practices will not be accepted. We expect all employees, contractors and suppliers to adhere to our standards; violations result in immediate investigation and remedial action up to contract termination. This modern slavery and human trafficking statement underpins our corporate values and procurement principles.

To ensure compliance across our network, Gardener Osterley requires suppliers to meet minimum standards and to provide transparent information about labour practices. Our supplier due diligence includes:

• Contractual clauses requiring compliance with our anti-slavery statement and the right to audit;
• Targeted supplier audits and risk assessments focusing on geography, labour intensity and third-party subcontracting;
• Remediation plans and binding corrective actions where issues are identified.

Supply Chain Audits and Expectations

We conduct a program of supplier audits, combining desk-based checks with on-site visits where necessary. Audit criteria examine worker contracts, wage records, working hours, freedom of movement and recruitment practices. Our procurement teams use a risk-based approach to determine audit frequency and depth, aiming to prevent modern slavery before it occurs. The slavery statement for suppliers is reinforced in tender documents and purchase orders, and suppliers must demonstrate continual improvement.

Reporting channels are central to our detection and remediation framework. Employees, contractors and third parties can raise concerns confidentially and, where necessary, anonymously through multiple channels maintained by Gardener Osterley. We operate a protected whistleblowing route and an internal reporting hotline monitored by trained compliance staff. All reports are taken seriously, investigated promptly and escalated to senior management when appropriate. We provide support to affected individuals and collaborate with authorities and NGOs as required.

Training and awareness form part of prevention. We deliver regular e-learning modules and face-to-face briefings for procurement, HR and operations teams. Training emphasises how to spot indicators of exploitation, how to use reporting channels and the expectations contained in our anti-slavery policy. Responsibility for compliance is embedded across the business, and line managers are accountable for enforcing standards.

Monitoring, Review and Continuous Improvement

Gardener Osterley monitors key performance indicators linked to supplier audits, remediation rates and report outcomes. We track the number of audits completed, non-compliance findings, corrective actions implemented and the time taken to resolve issues. Where modern slavery risks are identified, we collaborate with suppliers to implement corrective action plans, and we reserve the right to suspend or terminate relationships if improvements are inadequate.

This document is subject to an annual review to ensure our modern slavery measures remain effective and aligned with evolving risks and legislation. The annual review includes an assessment of supply chain mapping, audit outcomes, training uptake and the adequacy of reporting channels. Findings are presented to the Board and used to update policies, contract terms and supplier engagement strategies.

In conclusion, this anti-slavery statement reflects Gardener Osterley’s enduring commitment to eradicating forced labour from our operations and supply chains. We will continue to strengthen governance, extend supplier audits, maintain clear reporting channels and perform rigorous annual reviews. By working collaboratively with stakeholders and applying practical remediation, we aim to ensure that our business and the businesses we work with are free from exploitation and compliant with our modern slavery statement principles.