Modern Slavery Statement — Gardener Blackfriars

Gardener Blackfriars publishes this Modern Slavery Statement to set out our commitment to preventing slavery and human trafficking in all areas of our operations and supply chains. This anti-slavery statement explains our approach to identifying risk, the steps we take to prevent forced labour, and how we respond to concerns. We recognise that modern forms of slavery are an ever-present risk in complex supply chains and, as such, adopt a proactive, company-wide stance.

Our Zero-Tolerance Policy

We operate a zero-tolerance policy towards any form of slavery, forced labour, servitude, or human trafficking. All employees and contractors are expected to understand and comply with this policy, which makes clear that exploitation is unacceptable in our business or within any supplier relationship. Gardeners, suppliers and partners must adhere to our standards and contractual requirements; breaches will result in corrective action up to contract termination.

Scope and Principles — This slavery and human trafficking statement covers our operations, relevant subsidiaries, and key tiers of our procurement chain. We focus on sectors and geographies with higher risk, and we integrate ethical labour standards into procurement decisions. Our anti-modern slavery statement emphasises respect for human rights, transparent recruitment practices, and fair pay.

To implement our commitments we have defined specific controls and expectations for suppliers and contractors. These include:

• Mandatory clauses in supplier contracts requiring compliance with anti-slavery laws and our policies.
• Pre-engagement due diligence on labour practices and recruitment pathways.
• Worker rights awareness and training provisions for suppliers and subcontractors.

We conduct regular supplier audits and risk-based assessments. These audits combine document reviews, on-site inspections where practical, and remote interviews to verify wages, working hours, recruitment fees and living conditions. Our supplier audit programme targets higher-risk suppliers more frequently and uses external specialist auditors when necessary to validate compliance and remedial action plans.

Reporting Channels and Whistleblowing

Gardener Blackfriars provides multiple confidential reporting channels for employees, contractors and third parties to raise concerns about modern slavery or exploitation. Reports can be made internally through line managers, HR, or via an anonymous reporting mechanism. All reports are treated seriously, investigated promptly, and if substantiated, lead to remediation for affected individuals and corrective measures for culpable parties. We protect whistleblowers from retaliation and encourage early reporting to limit harm.

Where modern slavery indicators are identified, our response includes immediate protective measures for victims, suspension of business relationships when warranted, and a formal remediation plan. We collaborate with NGOs and law enforcement when required and commit to learning from incidents to improve prevention. Our forced labour statement clarifies that remediation and prevention are as important as enforcement.

Governance and Responsibility — Ultimate responsibility for our slavery and human trafficking statement sits with senior management and the Board, who receive regular updates on risk, audit outcomes and remediation progress. Operational ownership rests with procurement, HR, and legal teams who embed the anti-slavery policy into contracts, recruitment, and supplier management processes. Training programmes for staff and procurement teams ensure that policy requirements are understood and applied.

Annual Review and Continuous Improvement — We commit to an annual review of this modern slavery and human trafficking statement and related policies. Each year we will assess the effectiveness of our measures, update risk assessments, refine supplier audit approaches, and report on progress. This ongoing review cycle ensures that our anti-slavery stance remains robust, responsive to emerging risks, and aligned with best practice. Gardener Blackfriars reaffirms its commitment to eradicating modern slavery from our operations and supply chain and to acting transparently and decisively when issues arise.