Gardener Kingston Modern Slavery Statement

Gardener Kingston publishes this Modern Slavery Statement to confirm our unwavering commitment to combatting forced labour, human trafficking and other forms of exploitation across our operations and supply chains. We operate a zero-tolerance approach to modern slavery, and this anti-slavery statement sets out the actions we take to identify, prevent and remedy risks. Our policy applies to all employees, contractors and business partners engaged with Gardener Kingston.

We believe a robust modern slavery policy and vigilant governance are essential. Our board and senior leadership maintain oversight of this slavery and human trafficking statement and integrate anti-slavery considerations into procurement, HR and compliance functions. We embed expectations into contracts and require suppliers to adhere to our standards as a condition of engagement.

The Company has a clear accountability structure: the Chief Compliance Officer leads anti-slavery initiatives supported by procurement, legal and operations teams. We publish a concise code of conduct that reflects our values and includes explicit prohibitions on forced labour and exploitative practices. To ensure clarity, we provide employees with accessible guidance and deliver regular training on recognising the signs of modern slavery across our business and partner network.

Supplier Due Diligence and Audit Programme

Gardener Kingston employs a risk-based supplier due diligence programme. We conduct pre-contract risk assessments and ongoing monitoring of suppliers in higher-risk locations and sectors. Our approach combines desktop checks, contractual clauses, and physical and virtual supplier audits to verify compliance with anti-slavery obligations.

Supplier audits are a cornerstone of our mitigation strategy. Audits are carried out by trained auditors and include document review, worker interviews and site inspections where feasible. Audit findings lead to corrective action plans with clear timelines and follow-up. If suppliers fail to remediate material breaches, Gardener Kingston will suspend or terminate business relationships under a zero-tolerance policy.

Key elements of our supplier audit and compliance programme include:

• Screening suppliers for modern slavery and human rights risks prior to onboarding;
• Periodic on-site and remote audits focused on worker conditions, recruitment practices and wage transparency;
• Contractual requirements for supply chain traceability and the right to audit;
• Remediation pathways and escalation for serious breaches, up to contract termination.

Reporting Channels and Whistleblowing

We maintain multiple confidential reporting channels through which employees, suppliers and third parties can raise concerns about suspected exploitation. Reports are handled promptly and impartially. We protect whistleblowers against retaliation and encourage early reporting to enable swift investigation and remediation.

Allegations of modern slavery are investigated by trained investigators. Investigations may result in disciplinary action, supplier corrective measures or termination of contracts. Where appropriate, we cooperate with law enforcement and specialist agencies to ensure victims receive support and that perpetrators are held accountable. Our response process emphasises victim safety, confidentiality and legal compliance.

Monitoring, training and continuous improvement are central to our commitment. We provide targeted training for procurement teams, site managers and HR staff to strengthen detection and response capabilities. We also encourage supplier capacity-building through workshops and resources to improve labour standards across the value chain.

Gardener Kingston publicly reaffirms that we do not tolerate any form of modern slavery, forced labour or human trafficking. Our mandatory contractual clauses, audit rights and corrective frameworks reflect this stance and are enforced consistently.

We review this modern slavery declaration and associated policies on an annual basis to reflect evolving risks, regulatory changes and lessons learned from audits and investigations. The annual review includes assessing supplier risk ratings, audit outcomes, training effectiveness and reported incidents to ensure continuous improvement.

In conclusion, this statement documents Gardener Kingston’s proactive measures to prevent modern slavery in our operations and supply chains. Through a combination of strong governance, supplier audits, confidential reporting channels and an annual review cycle, we strive to eliminate exploitation and to act swiftly and decisively should issues arise. This anti-slavery statement will be updated and republished as our programme develops and as new intelligence or legislative requirements emerge.