Modern Slavery Statement — Gardening Eltham

Gardening Eltham publishes this Modern Slavery Statement to confirm our firm commitment to preventing modern slavery, forced labour and human trafficking across all operations and supply chains. We recognise our responsibility to maintain ethical standards and to take active steps to ensure that slavery and human trafficking have no place in any part of our business. This slavery and human trafficking statement sets out policies, oversight, actions and ongoing measures.

Our commitment and zero-tolerance policy

We have a zero-tolerance policy towards any form of modern slavery. Gardening Eltham requires all employees, contractors and partners to comply with our code of conduct which expressly prohibits forced labour, child labour, excessive working hours and exploitative practices. Our zero tolerance extends to every tier of the supply chain. We explicitly state in contracts and supplier agreements that any breach relating to slavery or human trafficking is a material breach and may result in termination.

To ensure clarity and accountability, senior management oversee our modern slavery compliance program. This modern slavery declaration is supported by risk assessments, training, and clear governance. We require managers to complete regular training on recognising signs of exploitation and to apply consistent standards when assessing recruitment practices and subcontracting arrangements. Gardening Eltham's stance on forced labour is non-negotiable.

Supplier due diligence and audits

We conduct due diligence on suppliers during onboarding and through ongoing monitoring. Our supplier audit framework includes:

• Risk-based supplier screening and questionnaires;
• On-site and remote audits focusing on labour practices, contracts, and worker welfare;
• Contractual clauses requiring compliance with anti-slavery obligations;
• Corrective action plans where issues are identified, with timelines for remediation.

Audits are prioritised by risk, using sector, geography and service type filters. We maintain records of audits, findings and resolutions. Where suppliers fail to improve, we escalate to contractual remedies, support for remediation or termination. Our supplier engagement includes capacity building so partners can meet our standards, reflecting our belief that collaborative action reduces exploitation risks for workers.

Reporting channels and whistleblowing

We provide multiple confidential reporting channels to enable workers, contractors and third parties to report concerns about exploitation or modern slavery without fear of reprisal. Reports can be made anonymously through independent hotlines and are treated in strict confidence. All allegations are investigated promptly, documented and escalated to senior leadership as needed. We protect whistleblowers and ensure non-retaliation, with disciplinary measures for those found to be obstructing investigations.

Monitoring, training and worker engagement are core to our prevention strategy. We deliver targeted training to procurement teams, site managers and HR to ensure awareness of indicators of exploitation and appropriate responses. We also encourage direct worker engagement through site meetings and surveys so workers can raise concerns about recruitment fees, passport retention, payroll irregularities and other red flags.

Our annual review process ensures continuous improvement. Each year we publish progress against our modern slavery and human trafficking action plan, assess the effectiveness of supplier audits and revise policies where necessary. The board reviews this modern slavery policy and our slavery prevention measures annually, and updates are integrated into operational plans. Continuous review supports evolving best practice and regulatory expectations.

In summary, Gardening Eltham takes a proactive, risk-based approach to eradicating forced labour and trafficking from our operations and supply chains. Through a clear zero-tolerance policy, robust supplier audits, accessible reporting channels and an annual review cycle, we aim to protect workers and uphold human rights. We remain committed to transparency and to working with partners to drive out modern slavery in all its forms.