Modern Slavery Policy

MODERN SLAVERY POLICY

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of one person’s liberty by another to exploit them for personal and / or commercial gain.

Gander & White has a zero-tolerance approach to modern slavery, and we are committed to acting both ethically and with integrity throughout our business dealings as well as our relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our own business or any of our supply chains.

We are also committed to ensuring there is transparency throughout our business alongside our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

Gander & White expects the same high standards from all our suppliers and business partners; as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labor, in addition to anyone held in slavery or servitude, whether adults or children. We expect at all times that  our suppliers and business partners will follow our lead to ensure their own suppliers are held to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, interns, and business partners.

This policy does not form part of any employee’s contract of employment, and we may amend it at any time.

Responsibility for the policy

Gander & White has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those employed by us comply with it.

The Company has primary day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure it is effective in countering modern slavery.

All levels of management comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

Compliance with the policy

All members of staff must read, understand, and comply with this policy.

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.

All stakeholders are required to avoid any activity that might lead to, or suggest, a breach of this policy. Staff must notify their line manager or a company director at the earliest possible convenience if they have reason to believe or suspect that a violation of this policy has occurred or may occur in the future.

Employees are encouraged to raise concerns about any issue or suspicion of modern slavery throughout our business and across our supply chains at the earliest possible stage. Should they believe or suspect a breach of this policy has occurred or that it may occur, they must notify their line manager or a company Director as soon as possible. Failing that they must report it in accordance with our Whistleblowing Policy.

You should note that where appropriate, and with the welfare and safety of all employees as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive, and exploitative work practices in their own business and supply chains.

If employees are unsure about whether a particular action the have witnessed or the treatment of  any third party workers more generally – for example in their working conditions constitutes any form of modern slaver they must raise it with their line manager or a company Director.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment because of reporting in good faith their suspicion that modern slavery in any form is or may be taking place in any part of our own business or in any of our supply chains.

Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment connected with raising a concern.

If a member of staff believes that they have suffered any detrimental treatment, they should inform their line manager immediately. If the matter is not remedied they should raise it formally using our Grievance Procedure, which can be found in our current employee handbook.

Communication & awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in our supply chains, forms part of the induction process for all individuals who work for us, and refreshers as well as updates will be provided using established methods of communication between the business and employees. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our trading relationship with them and reinforced as appropriate thereafter.

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they are found to be in  breach this policy.

Oliver Howell

Managing Director, July 2026