Modern Slavery and Human Trafficking Statement
INTRODUCTION
Modern slavery remains a grave violation of fundamental human rights and a criminal act. It encompasses various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking. These forms all share a common element – the deprivation of an individual's liberty, undertaken by another, for personal or commercial gain. At Barlow Motors Plc, we steadfastly maintain a zero-tolerance approach towards modern slavery. We pledge to conduct our business ethically and with integrity, both in our internal operations and in our relationships with external partners. To achieve this, we diligently implement and enforce effective systems and controls to ensure that modern slavery does not take place within our organization or within our supply chains. The Modern Slavery Act 2015 (the "Act"), along with its subsequent amendments, has strengthened UK law to enhance transparency in supply chains. Specifically, large businesses are mandated to disclose the measures they have taken to ensure that their operations and supply chains remain free from modern slavery. This statement outlines the steps we have taken and continue to take to ensure that slavery and human trafficking are eradicated from all our supply chains and business operations.
GROUP POLICY
Barlow Motors Ltd is dedicated to continuously improving our practices to combat modern slavery and human trafficking in all their forms within our organization and supply chains. To prevent slavery, we ensure that all our business activities are in compliance with minimum wage legislation, and we expect the same from our contractors. Our first line of defence against human trafficking is verifying that all Barlow Motors Ltd Group employees have the right to work in the UK. We also require UK-based contractors to employ only those individuals with the right to work in the UK.
OUR SUPPLY CHAINS
Given the scope of our operations and supply chains, it is not always possible to vet every business relationship thoroughly. However, we have identified the key risk areas for human trafficking and slavery, particularly within our supply chains, including cleaning services, valeting, and uniform suppliers. Barlow Motors Ltd sources products and parts from a wide array of national and international suppliers. Our supplier and contractor approval process includes a review of their adherence to controls, including their compliance with the Modern Slavery Act and related regulations. To ensure that external supply chains conform to this policy, we insist that the business practices and supply chains of each supplier align with Barlow Motors Ltd principles. We closely monitor compliance through varying levels of due diligence, dependent on the assessed risk of potential human trafficking and modern slavery.
Any instances of non-compliance that come to our attention will be assessed on a case-by-case basis. We will take remedial actions tailored to the specific circumstances. We will only continue trading with suppliers who are in full compliance with this statement, the Modern Slavery Act, and related regulations, or are actively working towards achieving full compliance. If we find that a supplier is not making satisfactory progress, we will temporarily suspend our business relationship, to the extent permitted by contract or law. The ultimate sanction for continuous non-compliance is the cessation of our business relationship, as allowed by contract or law. Barlow Motors is committed to swiftly and thoroughly investigating any claims or indications of human trafficking or slave labour within our business or supply chains. Personnel within Barlow Motors Ltd are encouraged to report such claims, following our Whistleblowing Policy. The findings and outcome of these investigations will be communicated to the board of directors.
TRAINING
We ensure that all Barlow Motors Ltd employees have access to detailed information regarding our Business Code of Conduct, Whistleblowing Policy, and other company policies, including this statement. This information is accessible via the Barlow Motors Ltd employee portal. We encourage all employees to familiarize themselves with this information during their induction, and we provide regular training sessions to raise awareness about the risks and consequences associated with modern slavery and human trafficking, along with updates as relevant laws change. Our Code of Conduct emphasizes ethical business practices as integral to all our dealings, with an uncompromising expectation of compliance with applicable laws, including the Modern Slavery Act and related regulations.
APPROVAL
This statement has been approved by the board of directors of Barlow Motors Ltd, and we are committed to reviewing and updating it as necessary on an annual basis to ensure compliance with the latest requirements of the Modern Slavery Act and related regulations.
Updated 03/05/2024