Applies to Trust Group UK Limited trading as Wolverhampton Volkswagen, Stourbridge Volkswagen, Redditch Volkswagen, Trust Skoda Wolverhampton, Trust Skoda Stourbridge and Trust Skoda Redditch, Birmingham TPS (2015) Limited, Wolverhampton TPS (2015) Limited and Coventry TPS (2016) Limited (“Trust Group UK")

Purpose

The Modern Slavery Act 2015 (MSA 2015) focuses specifically on the issue of modern slavery to ensure offenders are suitably reprimanded with severe sentences. Modern slavery encompasses the offences of: 'slavery' where ownership is exercised over a person; 'servitude' which involves the obligation to provide service imposed by coercion; forced or compulsory labour' involves work or service exacted from any person under the menace of a penalty and for which the person has not offered themselves voluntarily; and 'human trafficking' concerns arranging or facilitating the travel of another with a view to exploiting them.

The MSA 2015 requires large businesses, with sales of over €36 million, to be transparent about their efforts to eradicate slavery and human trafficking. This statement therefore explains the steps we have taken during the financial year to ensure that slavery and human trafficking is not taking place in any of our supply chains or any part of our business. This statement is made pursuant to Section 54, Part 6 of the MSA 2015 and applies to Trust Group UK.

Group structure

Trust Group UK operates motor retail dealerships (both new and used vehicles) and service and repair centres within the West Midlands and representing the Volkswagen and Skoda franchises. In addition to this, we operate Trade Parts Specialists businesses through three subsidiary companies. All of its operations are based in the United Kingdom and Trust Group UK currently employs around 280 colleagues.

Policies

We have an Anti-Slavery and Trafficking Policy in place internally, which is available in our Employee Handbook and also on the Trust Group UK intranet site and can be accessed by third parties. We maintain a whistleblowing policy to improve the ability for colleagues and others to report any concerns confidentially and effectively. Details of this policy are contained within our Employee Handbook, copies of which are distributed to all colleagues upon joining Trust Group UK.

As part of Trust Group UK’s induction process and throughout colleagues' employment with us, we train all colleagues to treat others with respect and courtesy as well as ensuring they adhere to all relevant laws, regulations and standards.

We focus on ensuring our management team is aware of the requirements to be alert to modern slavery but can also address concerns raised by their team or any suppliers. If any colleague is found in breach of our policies, we would ensure suitable disciplinary action is taken which could include termination.

Supply Chain Overview

Our main suppliers are the Volkswagen Group who supply vehicles and parts, and the supply chain prior to a completed vehicle is complex and has many layered and often overseas elements.

This makes it challenging for Trust Group UK, as a motor retailer, to see or manage any issues in that supply chain. Respecting human rights and environmental issues in that supply chain is ultimately our manufacturer supplier’s responsibility.

However, Trust Group UK has a number of other suppliers with contracts negotiated at group level and numerous smaller suppliers at a group or local level.

Supply Chain Standards

We allow all individuals who work or provide services to us the right to freely choose employment and, the right to associate freely with other individuals. As a result of our training, we offer an environment which is free from harassment and unlawful discrimination. We ensure our working practices are in accordance with the Equality Act 2010 and all employment legislation. We do not engage in forced or involuntary labour and have a zero tolerance approach to this, meaning we do not tolerate any of our suppliers engaging in such conduct.

We seek to identify and do business with companies that have values consistent with ours, including applying these expectations to their own supply chain.

Effectiveness

As we have a zero tolerance approach to modern slavery, and have not identified any indications that it occurs in our supply chain, we have not adopted any performance indicators. However, our ongoing work with our suppliers should indicate if any of them are not implementing appropriate measures or cannot provide the necessary confirmations to us.

Approval

The board of directors of the Company approved this updated statement at its board meeting on 13 March 2019.

Signed…………………………………

Nigel White, Finance Director

Trust Group UK Limited

Dated: 13 March 2019