Gardener Kenton Modern Slavery Statement

Gardener Kenton sets out this Modern Slavery Statement to confirm our firm commitment to preventing slavery, servitude, forced labour and human trafficking in any part of our operations or supply chains. This anti-slavery declaration reflects our corporate values and legal responsibilities, and it is an integral part of how we run our business across all services and procurement activities.

Zero-Tolerance Policy

Zero tolerance is the foundation of our approach. Gardener Kenton operates a zero-tolerance policy towards any form of modern slavery or exploitation. We require every colleague, partner and supplier to comply with our standards and actively work to eradicate exploitation. All allegations are treated seriously and investigated promptly, and any confirmed breaches result in decisive actions including contract termination and referral to authorities when appropriate.

We publish this modern slavery statement to be transparent about the measures we take. Our leadership team endorses the policy and ensures it is resourced, enforced and reviewed. We provide training to employees to recognise signs of exploitation and to understand their responsibilities under the slavery and human trafficking statement framework.

Supply Chain Standards and Supplier Audits

Gardener Kenton requires suppliers to adhere to strict Labour and Human Rights clauses in contracts and purchase orders. We implement a risk-based supplier due diligence process that includes:

• Pre-contract checks and mandatory declarations from suppliers;
• Regular supplier audits and on-site inspections for high-risk categories;
• Corrective action plans with deadlines for remediation;
• Continuous monitoring via questionnaires and third-party assessments.

These measures form the backbone of our supplier audit programme and demonstrate our commitment to an anti-slavery statement embedded in procurement.

Monitoring and Continuous Improvement

We maintain protocols to assess effectiveness, using audit findings, supplier performance data and incident reports to drive improvement. When audits identify risks or non-compliance, we enforce proportionate responses ranging from targeted support and retraining to suspension or termination of contracts. Our procurement team collaborates with legal and compliance functions to ensure remediation is recorded and verified.

Compliance with this human trafficking and modern slavery statement is mandated through contractual clauses and reinforced by regular supplier communications. We encourage suppliers to adopt their own robust policies that align with our expectations and international standards.

Reporting Channels

Gardener Kenton provides secure and confidential reporting channels for concerns related to slavery and human trafficking. Employees and third parties can raise issues through internal whistleblowing mechanisms, anonymous reporting tools and direct reporting to designated compliance officers. We guarantee protection from retaliation for genuine reports and treat all submissions with strict confidentiality.

Our reporting process ensures timely investigation, clear escalation pathways and documented outcomes. We publish summaries of significant findings and actions in our internal records and use lessons learned to refine training materials and control measures. The use of clear reporting channels supports early detection and rapid response to potential abuses.

Annual Review and Accountability

Gardener Kenton will review this modern slavery policy and associated actions at least annually and whenever there are material changes to our business or risk profile. The Board and senior management are accountable for oversight and for approving the annual modern slavery review. The review process includes evaluation of supplier audit results, incident trends, training uptake and the effectiveness of reporting channels. We are committed to continuous improvement and will update this statement to reflect progress and evolving best practice.