Modern Slavery Statement — Gardening Elephant and Castle

This Modern Slavery Statement sets out the commitment of Gardening Elephant and Castle (also referred to as Gardening Elephant & Castle and the organisation) to prevent modern slavery and human trafficking in all parts of our operations and supply chain. We declare a zero-tolerance policy towards all forms of forced labour, bonded labour, and exploitation. Our anti-slavery approach is embedded in procurement, contracting, and day-to-day operational practices.

Our policy scope covers employees, contractors, suppliers and partners. The company requires that everyone who works with Gardening Elephant and Castle Ltd adheres to ethical labour standards and the Modern Slavery and Human Trafficking Statement we publish annually. We apply risk-based due diligence to identify where exploitation might occur, and we include binding terms in contracts that require suppliers to comply with our expectations and local laws.

We operate a rigorous supplier audit programme and maintain a schedule of supplier assessments. Key actions include:

• Supplier audits: scheduled on-site or remote checks to verify working conditions, documentation and wage practices;
• Contract clauses: mandatory anti-slavery provisions and the right to audit and remediate;
• Corrective action plans: escalation and remedial measures for any non-compliance identified.

To strengthen compliance we provide targeted training for procurement, HR and operations teams. Our procurement staff evaluate high-risk categories and suppliers using a combination of questionnaires, risk matrices and third-party screening tools. The Gardening Elephant and Castle anti-slavery policy is reinforced through supplier onboarding and periodic review meetings.

The organisation maintains clear reporting channels so that concerns about modern slavery can be raised safely and confidentially. Reports may be raised internally through line managers and HR, or via anonymous reporting mechanisms where permitted. We emphasise non-retaliation and protect whistleblowers who act in good faith.

Reporting channels and whistleblowing

Our reporting framework includes a tiered response model: initial intake and risk assessment, investigation, remedial action and escalation to senior management where necessary. We publish clear procedures for handling allegations and document every report, ensuring a timely and proportionate response. Employees and third parties are informed that any credible allegation will trigger an investigation and immediate protective action for vulnerable individuals.

We require all suppliers to cooperate with independent audits and to submit documentation demonstrating compliance with labour and human rights standards. Audits focus on recruitment practices, the absence of recruitment fees, freedom of movement, appropriate working hours and lawful pay. If non-compliance is discovered, we pursue remediation, which may include supplier improvement plans, temporary suspension of orders or termination of the relationship where problems are not resolved.

Zero-tolerance enforcement and supplier audits

Our zero-tolerance policy means that any form of forced labour or trafficking discovered in our direct operations or in the supply chain will be confronted decisively. Where evidence indicates severe or systemic abuse, contracts will be terminated and appropriate authorities engaged. We also work collaboratively with suppliers to implement corrective measures and support improved practices where feasible.

An annual review of our policies, processes and performance is conducted by senior leadership and reported to the board. This review assesses the effectiveness of due diligence, training uptake, audit outcomes, and the operation of reporting channels. We use findings from the review to update policies, enhance controls and set measurable objectives for the coming year, including improved supplier monitoring and increased staff awareness.