Modern Slavery Statement

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Griffin Mill Garages Ltd - Modern Slavery Statement

Fiscal Year 1st April 2023 – 31st March 2024

This Statement is made pursuant to Section 54 (Part 6) of the Modern Slavery Act 2015 (‘Act’) and sets out the steps that CCR Motor Co Ltd t/a Griffin Mill, has taken during the previous financial year to ensure that slavery and human trafficking is not operating within either its own business or its supply chains.

This Statement has been approved by the Board of Directors and signed by Tim Bagnall, Managing Director, for Financial Year April 2023 – March 2024

Policy statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers 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, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

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

Our Supply Chains

Our supply chains are predominantly the major international motor manufacturers who supply us with motor vehicles and aftersales parts. In addition, we partner with vehicle finance and insurance providers for the provision of finance and insurance products to our customers. We also contract with other suppliers for the provision of ancillary goods, services, and equipment.

Due Diligence Process for Slavery and Human Trafficking

As part of the implementation of our ongoing risk assessments across the business, we have identified third party supplier risk as an area for continued focus on risk reduction for the Company. As part of this work, we have identified that car valeting suppliers potentially carry modern slavery risks due to the high turnover rates and reliance on migrant workers. In 2020, we have reviewed our car valeting supplier and have ensured through our due diligence process, that they are complying with the obligations under the Modern Slavery Act 2015.  We require our suppliers to comply with the Modern Slavery Act and prohibit any form of exploitation. Any suppliers found to have breached these obligations could face sanctions, including termination of our contract with them.

Responsibility for the policy

The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Business Support Manager has primary and 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 they are effective in countering modern slavery.

Line managers at all levels are responsible for ensuring those reporting to them understand and 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 employees and suppliers must ensure that they 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. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees must notify their manager as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future.

Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If anyone believes or suspects a breach of this policy has occurred or that it may occur they must notify their manager or report it in accordance with our Whistleblowing Policy as soon as possible.

If unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with a manager or the Group HR Controller.

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 as a result of reporting in good faith their suspicion that modern slavery of whatever 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 unfavourable treatment connected with raising a concern. If anyone believes that they have suffered any such treatment, they should inform the Group HR Controller immediately. If the matter is not remedied, and they are an employee, they should raise it formally using our Grievance Procedure.

Communication, awareness, and training

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided, as necessary.  The basis for the training is formed highlighting the key signs that someone could exhibit if they are a victim to slavery:

  • Appear to be under the control of someone else and reluctant to interact with others
  • Not have personal identification on them
  • Have few personal belongings, wear the same clothes every day or wear unsuitable clothes for work
  • Not be able to move around freely
  • Be reluctant to talk to strangers or the authorities
  • Appear frightened, withdrawn, or show signs of physical or psychological abuse
  • Dropped off and collected for work always in the same way, especially at unusual times, i.e. very early or late at night

Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business 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 breach this policy.