This statement is made by Glacier pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps the company has taken, and continues to take, to ensure that modern slavery and human trafficking are not taking place within its business operations or supply chains. 

Our business and structure 

Glacier operates across the United Kingdom and Europe, and is committed to conducting its business with integrity and in accordance with applicable laws and regulations. We recognise our responsibility to take a robust and proportionate approach to preventing modern slavery and human trafficking within our organisation and across our supply chain. 

Our policies 

Glacier maintains internal policies and practices designed to promote ethical conduct and compliance, including: 

• A Code of Conduct outlining expected standards of behaviour
• Whistleblowing procedures to enable the reporting of concerns in confidence.

These policies reflect our commitment to acting ethically and with integrity in all business relationships. We also expect our suppliers and business partners to comply with applicable laws and to operate in a responsible manner. 

Due diligence 

We undertake proportionate and risk-based due diligence in respect of our suppliers and business partners. This includes: 

• Assessing potential risk areas within our supply chains
• Conducting appropriate checks prior to engaging new suppliers, where relevant 
• Maintaining oversight of supplier relationships and addressing any concerns identified. 

Risk assessment and management 

We recognise that certain sectors and geographies may present a higher risk of modern slavery. Glacier considers these factors as part of its approach to supplier engagement and takes appropriate steps to mitigate potential risks. 

Training and awareness 

Glacier provides guidance, as appropriate, to employees to support awareness of modern slavery risks and how to identify and report potential concerns. 

Reporting concerns 

Employees, suppliers, and other stakeholders are encouraged to report any concerns related to modern slavery or human trafficking. Reports can be made through established whistleblowing channels and will be treated seriously and investigated as appropriate. 

Ongoing commitment 

Glacier is committed to maintaining and improving its approach to preventing modern slavery and human trafficking. We review our policies and practices periodically to ensure they remain appropriate to our business and risk profile.