Modern Slavery Statement — Gardener Seven Kings

Our Commitment to a Responsible Supply Chain

Gardener Seven Kings issues this modern slavery statement to set out our clear and uncompromising stance on forced labour, human trafficking and other forms of exploitation. We operate a zero-tolerance policy toward slavery and forced labour across all operations and in our supplier network. This Modern Slavery Statement reflects our values and operational approach to preventing modern slavery in every aspect of our business.

We recognise that a robust anti-slavery approach requires continual vigilance. Our modern-slavery statement and associated policies apply to all employees, contractors and suppliers. We will not tolerate any practice that could constitute slavery, servitude, forced or compulsory labour or human trafficking within our organisation or our supply chain.

As part of our slavery and human trafficking statement, we maintain a set of minimum standards that every partner must meet. These standards are incorporated into supplier agreements and procurement terms. We carry out pre-engagement checks and require suppliers to confirm they have effective policies, staff training and grievance mechanisms in place.

Due Diligence, Risk Assessment and Supplier Audits

We undertake a risk-based due diligence programme to identify and assess potential areas of vulnerability. Our supplier audits combine document reviews, site visits and interviews where necessary. Audit findings are used to develop corrective action plans or, where breaches are material or persistent, to terminate commercial relationships.

Our supplier audit process includes:

• Verification of labour practices and payroll records to detect irregularities;
• Evaluation of recruitment fees and debt bondage risks;
• Assessment of working hours, contracts and accommodation where provided;
• Review of subcontractor arrangements and migrant worker protections.

We use a combination of remote assessments and on-site inspections. Where on-site audits are not feasible, we employ third-party auditors and collaborate with industry peers to share intelligence and best practices. Our procurement team receives training to spot red flags in supplier behaviour and documentation.

Reporting Channels and Remedy

We provide multiple reporting channels for employees, workers in our supply chain and third parties to raise concerns confidentially and without fear of retaliation. Reports can be made through anonymous internal mechanisms and via secure reporting platforms maintained by our compliance function. All allegations are investigated promptly and objectively.

In line with our zero-tolerance policy, substantiated incidents trigger immediate corrective action, which may include remediation for affected workers, supplier improvement plans, and termination of relationships where required. We aim to remedy harm and restore dignity to affected individuals while cooperating with relevant authorities as appropriate.

Annual Review and Continuous Improvement — Our approach is reviewed at least once a year by senior management and the board to ensure it remains effective and aligned to emerging risks. The review covers policy effectiveness, audit outcomes, training completion rates and the status of remediation actions. We update our modern slavery policy and modern slavery disclosure in response to lessons learned and evolving statutory requirements.