Gardener Lee Modern Slavery Statement

Gardener Lee is committed to preventing modern slavery and any form of exploitation across our business and supply chains. This Modern Slavery Statement outlines our approach to identifying, assessing and mitigating risks related to slavery and human trafficking, and it affirms a zero-tolerance policy for forced labour.

Scope and purpose

We publish this anti-slavery statement to set clear expectations for employees, contractors and suppliers. Our policies cover modern slavery, forced labour and related abuses, and apply to all business units and purchasing activities. Gardener Lee expects those who supply goods or services to adhere to the same standards.

Zero-tolerance policy

Gardener Lee operates a zero-tolerance approach to slavery and human trafficking. Any confirmed instance of exploitation will lead to immediate action, which may include termination of contracts, suspension of suppliers and referral to appropriate authorities. We require written commitments from partners that they will not engage in practices that constitute modern slavery or forced labour.

Supplier due diligence and audits

We perform risk-based due diligence on suppliers and maintain a supplier code of conduct. Our supplier audit program includes third-party assessments and on-site inspections where necessary. Audit focus areas include working hours, wage compliance, recruitment fees, freedom of movement and subcontracting practices.

Audit process details

Audits and reviews use a combination of document checks, interviews and physical inspections. Findings are documented and remediation plans are required for any non-conformance. We prioritize audits for high-risk categories and geographies, with a program that includes:

• Initial risk assessment to classify supplier risk profiles;
• Periodic audits for critical suppliers and spot checks for others;
• Corrective action plans with defined timelines and verification;
• Escalation procedures for persistent or severe breaches.

Training and employee awareness

We provide regular training for procurement, HR and operational teams to help them recognise indicators of modern slavery and to understand their responsibilities under this anti-slavery statement. Training materials explain how to detect risks such as debt bondage, withheld documents or exploitative recruitment practices.

Reporting channels and whistleblowing

Gardener Lee maintains confidential reporting channels to enable staff, suppliers and third parties to raise concerns. Reports can be made through an internal anonymous hotline, an internal reporting portal and direct channels to designated compliance officers. All reports are treated seriously, investigated promptly and handled with confidentiality to protect whistleblowers.

Monitoring, remediation and annual review

We track identified risks, remedial actions and outcomes using a governance framework. Remediation may include supplier training, contract renegotiation or termination where necessary. Our board and senior management review progress regularly, and we conduct an annual review of this slavery and human trafficking statement and related policies to ensure continuous improvement. The annual review assesses effectiveness, updates risk assessments, and adjusts audit scope and training as needed.