Modern Slavery Statement — Gardener Kensington

Gardener Kensington issues this Modern Slavery Statement to set out our clear commitment to preventing slavery, forced labour and human trafficking in our operations and supply chains. Our anti-modern slavery policy is founded on respect for human rights and the belief that exploitation has no place in our business. We maintain a zero-tolerance approach to any form of modern slavery and require all colleagues, partners and suppliers to meet the standards described below.

Purpose, Scope and Principles

This modern slavery statement (the “anti-slavery statement” for Gardener Kensington) applies to all business units and contractors engaged to deliver goods and services. We expect adherence to ethical labour practices across sourcing, recruitment and ongoing supplier management. The purpose of this modern slavery policy is to identify and reduce risk, protect vulnerable workers, and ensure that our commercial activity does not contribute to slavery or human trafficking.

Our commitments include:

• Prevention — integrating anti-slavery checks into procurement and hiring;
• Due Diligence — assessing suppliers for slavery risks before engagement;
• Remediation — taking prompt corrective action where concerns are identified.

Supplier Audits and Due Diligence

We operate a risk-based supplier audit programme that combines desk-based reviews with on-site and third-party audits where appropriate. Our supplier audits evaluate working conditions, recruitment fees, freedom of movement, documentation retention, and wage practices. Where audits reveal non-compliance, we require concrete remediation plans and monitor progress until issues are resolved. This supplier due diligence forms a core part of how Gardener Kensington prevents modern slavery and enforces its procurement standards.

We apply a tiered approach to supplier monitoring: high-risk categories receive frequent, in-depth audits, medium-risk suppliers are periodically reviewed, and low-risk suppliers are monitored through contractual assurances and certification checks. Our procurement teams use these findings to inform supplier selection, contract terms and continuing relationships. When persistent non-compliance is found, escalation can include contract termination.

To support the slavery and human trafficking statement objectives, we require contractual clauses that mandate compliance with our labour standards and reserve the right to audit. We also include supplier training and capacity-building as part of our remediation strategies to help suppliers meet expected standards.

Zero-Tolerance Policy — Gardener Kensington enforces a strict policy that any confirmed instances of forced labour, human trafficking or other severe labour rights violations will be addressed immediately. Our zero-tolerance stance means that anyone within our operations found to be complicit in modern slavery will be subject to disciplinary action, up to and including termination, and we will pursue contractual or legal remedies against suppliers where appropriate.

We provide multiple reporting channels for concerns: a confidential whistleblowing mechanism, secure digital reporting, and escalation to senior compliance leads. Reporting channels are accessible to employees, agency workers and third parties; reports are taken seriously, investigated promptly, and protected from retaliation. We encourage workers and stakeholders to report suspected abuse without fear, and we commit to transparent investigation outcomes where possible.

Annual Review and Continuous Improvement — Our modern slavery programme is reviewed at least annually to measure effectiveness and drive improvement. This review includes analysis of audit results, remediation outcomes, training completion rates, supplier risk trends, and any reported incidents. We set annual targets, update policies and refine our supplier audit methodology to reflect emerging risks. The board and senior leadership receive regular updates on performance against these metrics as part of our governance of ethical sourcing.