Gardeners Millbank Modern Slavery Statement

Our commitment to a modern, ethical supply chain

Gardeners Millbank publishes this Modern Slavery Statement to make clear our stance on exploitation, forced labour and trafficking. We operate a zero-tolerance policy for any form of modern slavery, human trafficking or coerced work across our operations and supply networks. This slavery and human trafficking statement outlines our ongoing steps to prevent wrongdoing and the measures we maintain to detect and deter abuse.

We require all staff and partners to adhere to a single, clear standard; no tolerance for exploitation. Our internal policies and the modern slavery policy are embedded into recruitment, onboarding and supplier engagement procedures. Managers receive mandatory training to identify potential indicators of forced labour and to escalate concerns through approved reporting channels.

Gardeners Millbank's modern slavery statement for suppliers sets expectations across procurement, contracting and on-site delivery. We demand transparency in labour practices and require suppliers to maintain records demonstrating compliance with employment law, living wage commitments and freedom of movement for workers. Where subcontracting is used, primary vendors must ensure the same standards are enforced down the chain.

To verify adherence, we conduct regular supplier audits and risk assessments. Audits combine document review, worker interviews and site visits, enriched by third-party audits where necessary. Our supplier auditing programme focuses on high-risk categories such as seasonal labour, cleaning, and logistics. Audit results are reviewed by a cross-functional committee and used to drive corrective action plans.

The supplier audits include:

• screening for recruitment fees and retention of identity documents;
• verification of wage records, working hours and rest periods;
• assessment of accommodation standards and freedom of movement.

When audits reveal non-compliance, we require time-bound remediation. Persistent breaches can result in contract termination and reporting to authorities.

Gardeners Millbank maintains multiple secure reporting channels to encourage internal and external disclosures. Employees, contractors and third parties can raise concerns through anonymous hotlines, protected email routes and escalation to our ethics committee. We guarantee non-retaliation and take all allegations seriously, investigating promptly and confidentially under our forced labour response protocol.

Our governance structure supports this slavery and human trafficking statement: the board receives annual assurance on modern slavery risks and the executive team oversees implementation. We apply a risk-based approach, updating supplier due diligence intensity according to geography, sector and contract value. Prevention remains central to our approach, combining policy, training and verification to limit exposure.

As part of continuous improvement, Gardeners Millbank commits to an annual review of the modern slavery policy and our forced labour mitigation strategies. The review examines audit outcomes, incident reports, training completion rates and changes to law or best practice. Findings inform enhancements to supplier requirements, contract terms and the scope of future audits.

Accountability and progress

We publish this modern slavery statement annually to record progress and maintain transparency with stakeholders. Our objectives include reducing identified risks, increasing supplier compliance, and improving access to safe reporting routes. By embedding these standards across purchasing, HR and operations, Gardeners Millbank seeks to eradicate labour exploitation from our value chain and uphold the highest ethical standards.