Modern Slavery Statement — Gardener Northolt

Gardener Northolt publishes this Modern Slavery Statement to affirm our commitment to preventing forced labour, human trafficking and any form of modern slavery in our operations and supply chain. We recognise that a clear anti-slavery statement is essential for ethical procurement and responsible business conduct. This declaration outlines our policies, processes and ongoing commitments to eradicate exploitation from every corner of our organisation.

Zero-Tolerance Policy

We operate a zero-tolerance policy towards any instances of slavery or human trafficking. All employees, contractors and partners are expected to comply with this policy. Breaches will lead to disciplinary action, including termination of employment or contracts. Our approach is proactive: we require recruitment transparency, monitor working conditions and strictly prohibit the use of forced or bonded labour. The modern slavery policy that guides our work emphasises respect for human rights, fair pay and safe working environments.

Supplier engagement is central to our prevention strategy. We maintain clear contractual clauses that prohibit exploitation and require suppliers to adhere to applicable laws and our slavery and human trafficking statement principles. We also reserve the right to terminate agreements where serious breaches are identified, and we work with suppliers to remediate issues where possible.

To support supplier accountability we conduct regular supplier audits and checks. Audits combine documentation reviews, on-site inspections and risk-based assessments to verify that labour standards are upheld. We prioritise suppliers in higher-risk geographies and sectors for more frequent and in-depth auditing.

Reporting Channels and Whistleblowing

Gardener Northolt provides multiple secure reporting channels for employees, contractors and third parties to raise concerns. Reports can be made confidentially and, where requested, anonymously. We guarantee that no individual who reports a genuine concern will suffer retribution. Our reporting framework includes formal internal routes, escalation to senior management and independent investigation procedures. We encourage early reporting of any suspicion of forced labour or unethical practice.

To make our reporting accessible and actionable, we have established clear steps for how concerns are handled: initial intake, risk assessment, investigation, remediation planning and monitoring. These steps ensure allegations are addressed swiftly and transparently while protecting the rights of those involved.

Our supplier audits follow a structured checklist that examines recruitment practices, working hours, wage payment, freedom of movement and housing (where provided by employers). Typical audit elements include:

• Verification of recruitment documentation and fee policies
• Inspection of payroll records and timekeeping
• Interviews with workers to assess conditions and freedom to leave
• Review of sub-contractor management and traceability

Annual Review and Continuous Improvement

We conduct an annual review of our anti-slavery measures to evaluate effectiveness, identify emerging risks and update our modern slavery policy. This review includes analysis of audit findings, trends in reported concerns, corrective actions taken and supplier performance metrics. Results inform training priorities, supplier engagement strategies and resource allocation for compliance activities. The review is presented to senior leadership and used to refine our strategic risk controls.

Training and awareness form a vital part of our prevention efforts. We deliver targeted sessions for procurement teams, site managers and staff with supplier-facing roles to ensure they can identify warning signs and respond appropriately. We also provide guidance to suppliers to help them align with our expectations and remedial frameworks.

Gardener Northolt reaffirms its commitment to continuous improvement and transparent reporting. Our anti-slavery statement is an ongoing promise to uphold human dignity and lawful labour practices across our operations and supply chain. We will continue to strengthen supplier audits, maintain accessible reporting channels and review our policies annually to ensure that our business remains free from modern slavery and human trafficking in all its forms.