Gardener Sydenham Modern Slavery Statement

Gardener Sydenham publishes this Modern Slavery Statement to set out our commitment to preventing forced labour, human trafficking and exploitation across our operations and supply chains. This anti-slavery statement describes our policies, the actions we take, and the responsibilities held by our leadership to ensure that modern slavery is not present in any part of our business.

We operate a zero-tolerance policy for any form of slavery, servitude, forced or compulsory labour and human trafficking. This modern slavery policy is embedded in our corporate code of conduct and applies to every employee, contractor and partner. Our board and senior management give visible and ongoing support to these standards, and we require all staff to complete mandatory awareness training to recognise and report risks.

As part of this slavery and human trafficking statement, Gardener Sydenham maintains clear contractual obligations with suppliers and imposes expectations on working conditions, recruitment practices and pay. We review new and existing supplier relationships against ethical and legal standards and refuse to tolerate practices that undermine human dignity.

Supplier due diligence and proactive supplier audits form a central pillar of our approach. We conduct risk-based assessments of our supply chain, prioritising suppliers operating in higher-risk sectors or geographies. Our procurement team uses third-party verification where appropriate and requires suppliers to disclose their own anti-slavery measures.

Audits include on-site inspections, document review and interviews with workers when feasible. Where audits identify concerns we implement corrective action plans, set timelines for remediation and monitor progress. Repeat non-compliance results in contract termination. The anti-slavery statement includes clear escalation procedures and remedies to protect affected workers.

To support transparency we maintain a register of suppliers classified by risk and publish internal summaries for governance. We also require clauses in contracts that allow Gardener Sydenham to audit supply chain partners and to terminate agreements if modern slavery practices are confirmed.

Reporting channels and whistleblowing

We provide multiple reporting channels so concerns about suspected modern slavery can be raised confidentially and without fear of retaliation. Reports may be made through an internal hotline, a confidential email to compliance officers, or via designated senior managers. All reports are taken seriously, investigated promptly and handled with sensitivity.

Our reporting framework emphasises protection for whistleblowers and victims. Investigations are carried out by trained staff and may involve external specialists, law enforcement or non-governmental organisations to ensure appropriate support for affected individuals. We document outcomes and adjust policies to reduce recurrence.

Annual review and continuous improvement

Gardener Sydenham conducts an annual review of this anti-slavery statement, our risk assessments, and the effectiveness of supplier audits and reporting mechanisms. The review process includes feedback from internal stakeholders and, where relevant, external partners to ensure our modern slavery statement and practices evolve with emerging risks and best practice.

Our ongoing commitments include:

• Maintain and strengthen supplier audits and remediation processes;
• Deliver targeted training to procurement teams and operational managers;
• Enhance transparency through improved reporting and record-keeping;
• Review and update contractual terms to ensure enforceable anti-slavery obligations.

Gardener Sydenham expects all persons and organisations with whom we do business to share our commitment to end modern slavery and trafficking. We will continue to invest in prevention, detection and remediation measures and hold ourselves to the highest standards of ethical conduct.

This slavery and human trafficking statement is approved by the board and will be reviewed annually to ensure its relevance and effectiveness in preventing modern slavery across our operations and supply chains.