Gardener Soho Modern Slavery Statement

Gardener Soho confirms its firm commitment to combatting modern slavery across our operations and supply chains. This Modern Slavery Statement explains our approach to preventing slavery and human trafficking in every aspect of our business. We maintain a zero-tolerance stance to any form of forced labour, bonded labour or exploitation, and we expect the same standards from partners and suppliers. Our anti-slavery statement is embedded in corporate governance, procurement decisions and day-to-day operations, and is aligned with applicable legislation and international standards.

As part of this modern slavery and human trafficking statement, the policy applies to all employees, contractors and third-party suppliers engaged by Gardener Soho. We define modern slavery broadly to include forced labour, involuntary servitude, human trafficking and any practice that deprives an individual of their freedom and dignity. The statement covers our UK and international activities, and it extends to subcontractors, labour brokers and temporary work arrangements.

Our commitments are summarised in practical measures and principles:

• Prevention — integrate anti-slavery clauses into supplier agreements and procurement documentation, and build prevention into contract lifecycle management.
• Detection — deploy risk-based supplier audits, data-driven risk scoring and targeted site visits to verify compliance.
• Response — maintain clear remediation pathways, support for affected individuals and transparent escalation routes for breaches.

These commitments form the foundation of our modern slavery policy and anti-slavery framework, and are overseen by senior leadership and the compliance function.

Gardener Soho operates a zero-tolerance policy for any form of slavery or exploitation. Senior management and the board endorse this anti-slavery commitment and ensure resources are allocated for implementation. All managers are accountable for enforcing this Modern Slavery policy within their teams and supply chains. Non-compliance with our slavery and human trafficking policy is treated as a serious disciplinary matter and may lead to termination of employment or supplier contracts.

We conduct systematic supplier audits and assessments as part of our supplier assurance programme. Supplier audits combine document reviews, self-assessment questionnaires, independent verification and on-site inspections where necessary. Findings are recorded, categorised by severity and used to drive corrective action plans. Suppliers who fail to remediate serious breaches are subject to contract termination and removal from approved supplier lists.

To support these activities we maintain a robust set of controls including enhanced due diligence for high-risk categories, pre-contract checks, and periodic reassessments of existing partners. We use contractual clauses that require compliance with our slavery and human trafficking policy and the right to audit. These controls reduce risk exposure and provide clear mechanisms for enforcement.

Gardener Soho provides multiple confidential reporting channels so that employees, contractors and workers in our supply chain can raise concerns about suspected modern slavery. These reporting channels include internally managed whistleblowing routes, protected escalation to the compliance team, and anonymous reporting options. Every report is logged, assessed and investigated promptly by trained investigators. Where appropriate, we work with external specialists to ensure victim support and legal compliance.

We deliver regular training programmes to build awareness of forced labour indicators, ethical procurement practices and reporting responsibilities. Training is mandatory for procurement, HR and key operational staff and is refreshed periodically. Our training materials include scenario-based modules and are updated to reflect emerging risks and regulatory changes. We also engage suppliers through outreach, supplier workshops and capacity-building initiatives to raise standards across the value chain.

An annual review of this modern slavery and human trafficking statement is performed to measure the effectiveness of our policies, audits and remediation actions. The annual review includes analysis of audit results, incident reports, training completion rates and supply chain risk mapping. Outcomes of the review are approved at executive level and incorporated into a continuous improvement plan. Gardener Soho remains committed to transparency, responsible procurement and the protection of human rights in all our operations and partnerships.