Gardening Millbank Modern Slavery Statement

Statement of intent

This Modern Slavery Statement sets out Gardening Millbank's commitment to preventing slavery, servitude, forced labour and human trafficking in our business and supply chains. As part of our ongoing modern slavery policy, the board affirms a zero-tolerance approach to any form of exploitation. This anti-slavery statement describes the steps we take to identify risk, act on concerns and build resilient, ethical procurement practices.

Gardening Millbank's approach to the slavery and human trafficking statement is grounded in clear leadership, resourcing and staff training. We embed anti-slavery clauses into contracts, maintain supplier standards and require compliance with labour rights across all partnerships. Our Modern Slavery Act statement obligations are therefore treated as central to corporate governance.

We set out here the practical measures for risk assessment, supplier audits and reporting channels. This anti-slavery policy for Gardening Millbank applies to all employees, contractors and third parties providing goods or services to us. We will not tolerate recruitment fees, withholding of identity documents or any restrictions on freedom of movement that result in forced labour.

Risk management and supplier due diligence

We conduct risk-based due diligence on suppliers, prioritising regions, sectors and service types with elevated vulnerability. Our procurement team performs checks on labour practices, recruitment processes and working conditions before onboarding. Where necessary, enhanced due diligence is carried out for higher-risk suppliers and sub-contractors.

Supplier audits form a core part of our mitigation measures. Audits include documentation review, site visits and worker interviews, and are scheduled periodically and when triggered by concerns. Non-compliance prompts corrective action plans and may lead to termination of contracts. We require suppliers to demonstrate continuous improvement and to allow third-party verification where appropriate.

Key procurement expectations are listed below:

• Transparent recruitment with no fees charged to workers;
• Accurate payroll and lawful working hours;
• Safe housing where accommodation is provided;
• Freedom to terminate employment without undue restriction.

We provide training for relevant staff and procurement partners so they can spot indicators of modern slavery and know how to respond. Our training covers victim-sensitive approaches and protections for whistleblowers, ensuring concerns are escalated to the appropriate specialist team for investigation. Management monitor implementation and ensure resources are in place to support remediation where exploitation is identified.

Gardening Millbank maintains accessible and confidential reporting channels to ensure that employees, supply chain workers and third parties can raise concerns without fear of retaliation. Reports can be made through internal whistleblowing processes and through anonymised escalation mechanisms operated by independent third parties. All allegations are treated seriously and investigated promptly by trained investigators.

We commit to transparency and continuous improvement through an annual review of this anti-slavery statement and our policies. Each year the board assesses the effectiveness of our actions, reviews audit outcomes, evaluates training uptake and updates risk assessments. Findings are used to refine supplier monitoring, strengthen contractual requirements and allocate resources to areas of greatest need.

Remediation may include worker support, compensation, employment regularisation and collaboration with specialist agencies. We seek to remediate harm in a manner consistent with survivor-centred principles and local law. Disciplinary measures within the company and contractual sanctions against suppliers are applied where breaches are confirmed.

Our ongoing commitments include embedding anti-slavery considerations into procurement strategy, sharing best practice with industry peers and supporting supply chain capacity-building programmes. By sustaining these actions, Gardening Millbank aims to reduce the risk of labour exploitation across the horticulture and grounds maintenance sectors in which we operate.

This anti-slavery and human trafficking policy remains under active review and is reissued following the annual review cycle. Senior leadership is accountable for implementation and for ensuring that our zero-tolerance policy is reflected in everyday business decisions, procurement activities and supplier relationships.