Gardener Millbank Modern Slavery Statement

Gardener Millbank confirms its commitment to preventing modern slavery, forced labour and human trafficking across our operations and supply chain. This modern slavery statement sets out how we identify, prevent and mitigate the risk of slavery and human trafficking in our business. We adopt a firm stance: there is a zero-tolerance policy for any forms of exploitation.

Our commitment and scope

We publish this anti-slavery and anti-trafficking declaration to make clear that Gardener Millbank expects all employees, suppliers and partners to comply with relevant laws and our standards. This slavery and human trafficking statement applies to our global operations, contractors and third-party providers. We promote transparency and accountability at every level.

To translate policy into practice we maintain clear obligations for suppliers and partners. Key actions include:

• Due diligence on new suppliers and regular risk assessment.
• Contract clauses that prohibit forced labour and require adherence to our standards.
• Training and awareness campaigns for staff and procurement teams.

Zero-tolerance policy

Gardener Millbank operates a fundamental zero-tolerance approach to any instance of modern slavery, whether it appears as forced labour, debt bondage, child labour or deceptive recruitment. We will take decisive action if any breach is identified, including termination of contracts and reporting to relevant authorities. This zero tolerance policy is non-negotiable and is enforced through audits and contractual remedies.

Supplier audits and assessments are central to our prevention strategy. We conduct periodic on-site and remote audits, targeted spot checks and documentary reviews. Audits include worker interviews, review of payroll, recruitment processes and working conditions. Findings are acted upon with corrective action plans, follow-up inspections and escalation when necessary. We prioritise high-risk sectors and regions and continuously refine our supplier risk profiling.

To support these audits we maintain a supplier code of conduct that outlines expectations for labour standards, freedom of association and safe working conditions. Suppliers must demonstrate traceability in their own chains and evidence efforts to eradicate exploitation.

Reporting channels and whistleblowing

We provide multiple, secure reporting channels to encourage employees and third parties to raise concerns. Reports can be made anonymously and are investigated promptly. Our reporting mechanisms include internal hotlines, confidential email routes and escalation to senior compliance officers. We protect whistleblowers from retaliation and treat all reports with seriousness and confidentiality.

We encourage the use of clear, accessible processes: report, investigate and remediate. Where incidents are substantiated we implement remedial actions to support affected individuals, rectify conditions and hold responsible parties to account. Our approach balances compliance with remediation and prevention.

Annual review and continuous improvement are integral to this modern slavery policy. Gardener Millbank conducts a formal review of its anti-slavery measures each year. The review evaluates the effectiveness of due diligence, supplier audits, training programs and reporting channels, and identifies areas for enhancement. Outcomes are reported to senior leadership and inform updates to our policies and supplier expectations. As part of the review cycle we also monitor legislative changes and international guidance on slavery and human trafficking.

Our anti-slavery statement reiterates that preventing modern slavery is a shared responsibility across Gardener Millbank. We commit resources to strengthen controls, promote ethical procurement and foster partnerships that support fair labour practices. We will continue to publish our findings and demonstrate progress through measurable indicators.

This slavery and human trafficking statement reflects Gardener Millbank’s principled stance and operational commitments. We will update this modern slavery statement as our understanding of risks evolves and as remedial measures are implemented. Our sustained resolve is to ensure dignity, fairness and safety for every worker connected to our business.

By maintaining rigorous supplier audits, secure reporting channels, an uncompromising zero-tolerance policy and an annual review process, Gardener Millbank pledges to uphold the highest standards in combating modern slavery in all its forms.