The Modern Slavery Act 2015 requires commercial organisations supplying goods or services with a turnover of above £36 million to prepare and publish an annual 'Slavery and Human Trafficking Statement'. The Statement must set out the steps an organisation has taken, if any, during its financial year to ensure that slavery or human trafficking is not taking place in its supply chain.
What is Modern Slavery
Modern slavery is an international crime, affecting an estimated 29.8 million slaves around the world. It is a growing global issue that transcends age, gender and ethnicities. It includes victims who have been brought from overseas and vulnerable people in the UK, who are forced to illegally work against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing.
Mill Garages North East is working towards establishing a zero-tolerance position on violations of anti-human trafficking and anti-modern slavery laws. This statement explains the steps we intend to take during the financial year 1st January 2018– 31st December 2018, to ensure that slavery and human trafficking is not taking place in any of our supply chains or any part of our business. If we do find breaches of these laws within our supply chain, we will look to support companies in their efforts to comply with the legislation or change our suppliers if necessary.
Our Structure and Supply Chains
Mill Garages North East’s principal activity is in the retail motor trade, comprising the sale, distribution and servicing of new and used cars and the sale of parts and accessories. In total we employ 170 direct employees across the following dealerships:
Mill Volvo Newcastle: 60 permanent employees;
Mill Volvo Sunderland: 40 permanent employees;
Mill Volvo Stockton: 37 permanent employees; and
Mill Volvo Harrogate:33 permanent employees.
We also have a car storage compound located in North Shields.
As a recognised Volvo dealer, our predominant supplier of all parts and materials is Volvo Car UK, accordingly we are obliged to comply with Volvo’s Code of Conduct for Business Partners.
With the exception of one or two European suppliers who we use occasionally for Volvo uniform or showroom refurbishments, our other suppliers are predominantly UK based.
Mill Garages North East has numerous internal HR policies which are available to all staff and these can be accessed by third parties on request by contacting Simon Hewitson at firstname.lastname@example.org for a copy. These policies include Equal Opportunities, Dignity at Work and Whistle Blowing. Our whistle blowing procedures encourage anyone who has concerns, for example, about how supplier partners or staff including agency workers are behaving, to raise their concerns confidentially. Through the modern slavery training we intend to conduct, employees will also be encouraged to report any suspicions that they may have regarding modern slavery. Our policies are reviewed annually by the organisations’ legal advisors to ensure we remain compliant.
As part of the organisation’s induction process and throughout our employees’ employment with us, we train all employees to treat others with respect and courtesy as well as ensuring they adhere to all relevant laws, regulations and standards. This is an ongoing due diligence process. We offer a training and development programme for all staff. We focus on ensuring our management team is not only aware of the requirements to be alert to modern slavery but can also address concerns raised by their team or any suppliers. If any employee is found in breach of our policies, we ensure suitable disciplinary action is taken which can include termination of employment.
All right to work documentation is checked for permanent employees, contracts of employment are provided to all new starters and market-related pay is provided to all employees which will at all times meet national living and minimum wage rates set by the government.
Sub-contractor Labour Suppliers
We occasionally engage with car wash and valet sub-contractor companies or employment agencies, to provide their services on an ad hoc basis at any of our four locations. Whenever a sub-contractor company is engaged, signed agency or supplier contracts are to be issued which obliges the agency or service supplier to comply with eligibility to work checks, national minimum wage compliance, MSA compliance and Anti-Bribery compliance.
Furthermore, all sub-contractor labour suppliers or agencies will be issued with a letter requesting a response confirming their own modern slavery and anti-human trafficking policies. If any risks are identified then further investigations will be carried out and any necessary action will be taken.
Our aim for the financial year, 2018 is to:
Mill Garages North East shall take responsibility for this statement and its objectives which will be reviewed and updated as appropriate.