Gardener Hoxton Modern Slavery Statement

Gardener Hoxton is committed to preventing all forms of modern slavery and human trafficking in our operations and supply chains. This anti-slavery statement outlines our approach to ensuring ethical practices across our business. We adopt a zero-tolerance policy towards forced labour, servitude, and any conduct that violates basic human rights.

Our organisation publishes this modern slavery statement to demonstrate accountability and continuous improvement. The policy applies to every staff member, contractor and supplier. We emphasize transparency and take proactive steps to identify and address slavery and human trafficking risks in both direct and indirect procurement.

As part of our slavery and human trafficking statement, Gardener Hoxton integrates risk assessment processes into procurement and vendor onboarding. We require suppliers to confirm compliance with anti-slavery standards and to align with our ethical code of conduct. Non-compliance is addressed by remediation plans or termination where appropriate.

We maintain a

Zero-Tolerance Policy

which is clear and enforceable: any instance or credible allegation of modern slavery will trigger immediate investigation. Employees and partners are trained to recognise indicators of exploitation and are empowered to report concerns. Our zero-tolerance approach extends to subcontractors, agents and third parties.

To operationalise this commitment, we perform regular supplier audits and due diligence. Our supplier audits include documentation review, on-site visits where feasible, and interviews with relevant personnel. We adopt a risk-based approach, increasing scrutiny for higher-risk categories such as low-skilled labour, seasonal services, and complex supply chains.

Supplier audits cover specific checks and corrective measures including:

• Verification of legal employment contracts and wage records
• Assessment of working hours, accommodation and recruitment fees
• Evaluation of grievance mechanisms and worker representation
• Follow-up action plans and time-bound remediation

We provide multiple

Reporting Channels

so concerns can be raised safely and confidentially. Staff are encouraged to use internal reporting routes via managers or designated ethics officers. We also maintain anonymous reporting options through internal hotlines and secure digital forms. All reports are treated seriously, investigated promptly, and kept as confidential as possible.

Reports are handled by a cross-functional team that includes compliance, human resources and legal advisors. We do not tolerate retaliation against anyone who raises genuine concerns in good faith. The process ensures timely support for affected individuals and includes referral to appropriate support services where needed.

Our anti-slavery statement is not static; we commit to an annual review to evaluate effectiveness and progress. Each year, senior management reviews policy implementation, audit findings, remediation outcomes, and training uptake. The annual review informs amendments to our supplier code, procurement practices and risk assessment methodology, strengthening the Gardener Hoxton slavery prevention framework.