This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 and sets out the steps the Company has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
Introduction from the Managing Director
Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking. The Company has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.
The Company also expects the same high standards from its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards.
Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain. Employees are expected to report concerns and management are expected to act upon them.
The Sandown Group is a franchised Mercedes-Benz and smart dealer and retails and repairs Mercedes Benz and smart cars. In addition, the group retails vehicle parts and accessories as part of the Mercedes Benz UK network. The Sandown Group trades through two entities, namely, Sandown Surrey and Hampshire Limited and Sandown Dorset and Wiltshire Limited. The group has its head office in the UK and all trading outlets are in the UK. The group has an annual turnover in excess of £36m.
Sandown is a privately owned Mercedes-Benz group operating across eight sites. The group is responsible for two of Mercedes-Benz UK’s market areas and employs approximately 400 people.
Our Supply Chains
Our supply chains include the sourcing of vehicles and parts relating to the sale and repair of new and used Mercedes and smart cars.
The automotive supply chain is one of the most complicated of any industry. There are often six to ten levels of suppliers between an automaker and the source of raw materials that enter the manufacturing process. The breadth, depth and interconnectedness of the automotive supply chain make it challenging to effectively manage business and sustainability issues. Respecting human rights and environmental issues in the supply chain is ultimately our suppliers’ responsibility. As customers, however, we play an active role in supplier development and have adopted various means to clearly communicate our expectations to our suppliers.
Our Policy on Human Slavery and Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in any part of business or in our supply chains. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to prevent slavery and human trafficking taking place anywhere in our supply chains.
Due Diligence Processes for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk:
We have embraced the Stronger Together Programme across our sites, and applaud the work being done to reduce forced labour and human trafficking in the UK. Our Human Resources team have been trained in the exploitation of human labour and we have provided training to key personnel within the business. All employees and agency staff have received information regarding the Stronger Together principles and have mechanisms to increase the visibility of issues, for example through confidentially contacting the Human Resources Team 01202 644 381.
We regularly assess risk related to human trafficking and forced labour associated with our supply base. Our preliminary assessment is based upon the commodity or service purchased, supplier quality performance, business location and the nature of the business transaction. The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk.
Sandown classifies its suppliers as follows: 1) Goods for resale 2) Direct materials 3) Indirect purchases; consumables and services, e.g. cleaning and valeting.
Internal processes and procedures allow us to clearly identify high risk supply chains and/or areas within our supply chains where there is an increased risk of modern slavery. We have as such identified that one of the main areas of exposure has been identified as the outsourcing of valeting services. As a result, we have included taking positive steps to ensure that our contract valeting companies are adhering to all our supplier’s principles, included their management on our internal training program and have provided them with clear and concise directions with regards to the recruitment and assessment of their personnel.
Supplier Adherence to our Values
We expect all those in our supply chain and contractors comply with our values.
The Directors and Senior Managers are responsible for compliance in their respective departments and for their supplier relationships.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to each and every one of our employees. All new employees undertake the training within the first month of employment. All Directors have been briefed on the subject.
Our Effectiveness in Combating Slavery and Human Trafficking
We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
This statement constitutes the Sandown Group's Slavery and Human Trafficking statement for the current financial year.
Group Human Resources Director