Gardener Waterloo Modern Slavery Statement

Gardener Waterloo sets out its Modern Slavery Statement to declare a clear, organisation-wide commitment to the prevention of forced labour, human trafficking and all forms of exploitation. This anti-slavery statement reflects a zero-tolerance policy and outlines the steps we take across our operations and supply chain. We recognise our responsibility to identify, prevent and remedy modern slavery risks where they occur and to ensure our values are embedded into everyday practice.

Scope and commitment: This slavery and human trafficking statement covers Gardener Waterloo and all subsidiaries and controlled entities. We commit to continuous improvement in our modern slavery policy, embedding ethical recruitment practices, and requiring compliance from every supplier and partner. Our corporate code of conduct reinforces that any form of forced labour, debt bondage, or exploitative practice will not be tolerated under any circumstances.

Supply chain due diligence and supplier audits

We operate an enhanced supplier due diligence programme designed to reduce the risk of modern slavery throughout our procurement processes. Key elements include:

• Pre-engagement screening of new suppliers for labour practice risks;
• Periodic on-site and remote audits to verify compliance with labour standards;
• Contractual obligations requiring adherence to our anti-slavery requirements;
• Corrective action plans where non-compliance is identified, monitored until closure.

Policies, training and responsible sourcing

Gardener Waterloo has developed a modern slavery policy and an anti-slavery statement that is integrated into procurement, HR and operations. We deliver mandatory training modules to purchasing, HR and site managers to help them recognise indicators of exploitation, coercion or high-risk recruitment practices. Recruitment partners are vetted and required to follow our standards for fair wages, freedom of movement and transparent contracts.

Reporting channels and whistleblowing: We maintain multiple safe channels for reporting suspected abuse, exploitation or non-compliance. Employees, contractors and suppliers are encouraged to report concerns through anonymous hotlines, designated compliance officers and internal reporting platforms. Reports are treated confidentially and investigated promptly. We emphasise protection from retaliation and offer support measures where needed.

Investigations, corrective actions and remediation: Allegations are investigated by a trained team led by our compliance and HR functions. Where modern slavery risks are substantiated we take decisive action including supplier suspension, contractual termination and cooperation with authorities. We also require and support remediation for affected workers, including recovery of unpaid wages, safe repatriation and access to support services.

Supplier engagement and monitoring: We proactively work with vendors to build capacity and reduce exploitation risks through supplier workshops, ongoing monitoring and shared improvement plans. Our responsible sourcing approach focuses on transparency, traceability and long-term partnerships that prioritise worker welfare. We use risk-based monitoring to allocate audit resources to higher-risk tiers of the supply chain.

Annual review and continuous improvement: Gardener Waterloo undertakes an annual review of this modern slavery statement and our policies to assess effectiveness, update risk assessments and set measurable objectives. The review incorporates audit findings, anonymous report trends, remediation outcomes and stakeholder input. Performance metrics include the number of audits completed, incidents investigated, and the status of corrective action plans.

In conclusion, Gardener Waterloo reiterates its zero-tolerance policy towards slavery and human trafficking. We publish this anti-slavery policy statement to be transparent about our approach, to hold ourselves accountable and to provide confidence to stakeholders that we will continuously work to eradicate modern slavery from our business and supply chains. This modern slavery statement will be reviewed annually and updated as required to reflect evolving best practice and regulatory expectations.