Gardener Mill Hill Modern Slavery Statement

Gardener Mill Hill is committed to preventing slavery and human trafficking in all forms across our operations and supply chains. This modern slavery statement sets out our zero-tolerance approach, the responsibilities of our leadership and workforce, and the steps we take to assess and manage risk. We recognise that a clear, enforceable anti-slavery policy and consistent actions are essential to uphold human rights and maintain ethical procurement.

Our zero-tolerance policy is simple and unequivocal: we will not tolerate forced labour, bonded labour, child exploitation or any form of involuntary work within Gardener Mill Hill or among our suppliers. The board and senior management have adopted a Modern Slavery Policy that requires compliance with applicable laws and the inclusion of anti-slavery clauses in all supplier contracts. This policy underpins our expectations and forms the basis for remedial action where breaches are found.

We operate a risk-based approach to due diligence across our supplier network. Our procurement and compliance teams carry out pre-engagement checks and ongoing monitoring for higher-risk relationships. The slavery statement describes our commitment to assess supplier practices through self-assessments, documentation reviews and targeted on-site or remote verification where necessary. These measures help us identify and address potential modern slavery indicators early.

To reinforce accountability we provide training and awareness sessions for staff involved in sourcing, contract management and site supervision. Employees are trained to recognise red flags, escalate concerns, and apply the anti-slavery statement principles in procurement decisions. Managers are tasked with ensuring that suppliers adhere to our standards and that any suspected violations are treated as serious compliance matters.

We maintain a structured audit programme to validate supplier adherence. This supplier audits regime includes:

• Risk prioritisation based on geography, sector and labour intensity;
• Documentary checks of payroll, working hours and recruitment practices;
• On-site inspections or third-party audits where risks are elevated;
• Corrective action plans and time-bound remediation;
• Contract termination provisions for persistent breaches.

We provide multiple secure and confidential reporting channels to raise concerns about modern slavery. Staff and third parties can report anonymously through an internal whistleblowing mechanism, speak directly to line managers, or escalate to our compliance team. All reports are taken seriously, investigated promptly and, where necessary, reported to appropriate authorities. We ensure protection from retaliation for those who raise concerns in good faith.

In cases where incidents are confirmed, Gardener Mill Hill pursues proportionate remediation which may include worker support, recovery plans and contractual sanctions for suppliers who fail to remedy violations. Our approach is to prioritise the welfare of affected individuals while ensuring that systemic failures are corrected and prevented from recurring. We document findings and corrective actions to inform continuous improvement.

This Modern Slavery Statement is reviewed annually by senior leadership and the board to reflect evolving risks, regulatory requirements and stakeholder expectations. The annual review evaluates policy effectiveness, audit outcomes, and the impact of training and reporting mechanisms. Where gaps are identified, we set clear action plans and timelines to strengthen controls, supplier engagement and transparency.

Gardener Mill Hill is committed to continuous improvement in tackling modern slavery and human trafficking. We will continue to refine our due diligence processes, expand our supplier audits programme, and strengthen our whistleblowing channels. Our modern slavery policy and related procedures will evolve as we learn from audits, stakeholder dialogue and industry best practice to ensure responsible sourcing and respect for human rights throughout our value chain.

By maintaining a clear zero tolerance stance, conducting regular supplier audits, offering robust reporting channels, and performing an annual review of our anti-slavery measures, Gardener Mill Hill aims to reduce the risk of exploitation and demonstrate accountability. Our commitment extends to embedding ethical standards in procurement decisions and promoting a culture where labour rights are respected and protected.

We will continue to publish this anti-slavery statement and report progress through our governance channels, ensuring transparency and ongoing accountability in our fight against modern slavery, forced labour and trafficking.