Gardeners Millbank Modern Slavery Statement

This Modern Slavery Statement is made on behalf of Gardeners Millbank and sets out the steps we take to prevent modern slavery and human trafficking in our business operations and supply chains. Gardeners Millbank is committed to acting ethically and with integrity in all our dealings, and to implementing effective systems and controls to ensure that modern slavery has no place in our organisation.

Modern slavery is a severe violation of fundamental human rights. It includes slavery, servitude, forced or compulsory labour, child labour, and human trafficking. We recognise that no sector or region is immune to these risks, and we are committed to continually strengthening our approach to identification, prevention, and remediation.

Zero-Tolerance Policy

Gardeners Millbank has a clear and strict zero-tolerance policy towards modern slavery and human trafficking. We will not knowingly engage with or support any organisation, individual, or activity that is involved in exploiting people or violating labour rights. This commitment applies to all parts of our business, including our suppliers, contractors, and business partners.

Our zero-tolerance policy is embedded in our internal standards and expectations of conduct. Employees, managers, and directors are required to uphold and promote this policy in their day-to-day work and decision-making. Any breach of this policy by an employee may result in disciplinary action, up to and including termination of employment. Where breaches are identified in our supply chain, we will take appropriate steps, which may include corrective action plans or the termination of commercial relationships.

Supply Chain and Supplier Audits

Our supply chain includes providers of goods, services, and labour that support our operations. We acknowledge that risks of modern slavery can arise at different tiers of the supply chain, and we are committed to conducting appropriate due diligence to identify and mitigate these risks.

Before engaging new suppliers, Gardeners Millbank assesses them against our ethical standards, including requirements relating to labour practices, health and safety, and respect for human rights. We expect suppliers to comply with all applicable laws and regulations and to maintain working conditions that are fair, safe, and free from coercion.

We conduct periodic supplier audits and reviews, focusing on those areas where we consider the risk of modern slavery to be higher due to geography, industry, or nature of the work. These audits may include document reviews, site visits where appropriate, and discussions with management and, where feasible, workers. Where issues are identified, we work with suppliers to develop and monitor corrective actions. If a supplier is unwilling or unable to address serious concerns, we will consider ending the relationship.

Reporting Channels and Whistleblowing

Gardeners Millbank encourages everyone associated with our business, including employees, contractors, and suppliers, to speak up if they have concerns about modern slavery, human trafficking, or any other unethical behaviour. We are committed to ensuring that concerns can be raised safely, confidentially, and without fear of retaliation.

Concerns can be reported to line managers, senior management, or through designated internal reporting channels. All reports are taken seriously and will be investigated promptly and impartially. Where an investigation confirms a risk or incident of modern slavery, we will take appropriate remedial action and, where required, cooperate with relevant authorities.

We strictly prohibit retaliation against anyone who raises a concern in good faith or participates in an investigation. Disciplinary measures will be considered for anyone who victimises or harasses a person for speaking up.

Training, Awareness, and Continuous Improvement

We provide relevant training and guidance to employees, particularly those involved in procurement, supplier management, and recruitment, so they can identify warning signs of modern slavery and understand how to respond. Awareness of modern slavery risks and our zero-tolerance approach is reinforced through internal communications and policy updates.

Gardeners Millbank is committed to learning from best practice, industry guidance, and stakeholder feedback. We review our procedures to strengthen our due diligence, auditing, and remediation processes, and to enhance transparency in our operations and supply chains.

Annual Review and Governance

This Modern Slavery Statement is reviewed annually by the senior leadership of Gardeners Millbank to ensure it remains accurate, relevant, and effective. The review considers changes in our business structure, supply chains, identified risks, and regulatory developments. Where necessary, we update our policies, procedures, and training programmes to reflect emerging risks and lessons learned.

The responsibility for overseeing our response to modern slavery and human trafficking rests with senior management, who are accountable for ensuring that adequate resources and attention are dedicated to this important issue. By publishing this Statement and reviewing it each year, Gardeners Millbank reaffirms its ongoing commitment to preventing modern slavery in all its forms and promoting respect for human dignity throughout our operations and supply chains.