Applies to Trust Group UK Limited, Wolverhampton TPS (2015) Limited, Birmingham TPS (2015) Limited and Coventry TPS (2016) Limited. (“Trust Group UK”)
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 for the financial year ending 31st December 2021.
Trust Group UK is composed of a group of business units and trading subsidiaries under the holding company, Trust Group UK Limited. Each business unit operates a motor retail dealership (both new and used vehicles) and service and repair centres divided by franchise, or other ancillary businesses. The ancillary businesses operated by Trust Group UK include the agency to sell Volkswagen Group parts through our Trade Parts Specialists centres. All of its operations are based in the United Kingdom and Trust Group UK currently employs around 250 colleagues. .
We have an anti-slavery and trafficking policy in place internally, which is available to all on the Trust Group UK intranet and can be accessed by third parties on request and via our website. We support a whistleblowing policy to improve the ability for colleagues and others to report any concerns confidentially and effectively. Details of this policy have been communicated to all current colleagues via our company handbook.
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. This is an ongoing process and includes a compulsory online element covering various compliance topics. The modern slavery module is compulsory for all sales, management and central service colleagues to ensure that awareness is there across Trust Group UK.
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 colleague is found in breach of our policies, we would ensure suitable disciplinary action is taken which could include termination.
Trust Group UK values include ‘Integrity’ and ‘Respect’ and these are embedded in the culture of Trust Group UK.
Supply Chain Overview
Our main suppliers are vehicle manufacturers 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 suppliers’ responsibility.
However, Trust Group UK has a number of other significant 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.
In our standard procurement process for group-wide contracts, we issue contracts that incorporate standard Terms and Conditions (T&Cs). The T&Cs include specific requirements on our suppliers to adopt and enforce policies to address issues such as forced labour.
We continue to assess the risk of slavery and trafficking in our supplier due diligence process, especially for areas of the business we deem to be higher risk, for example valeting suppliers, where we have enhanced checks.
We seek to identify and do business with companies that have values consistent with ours, including applying these expectations to their own supply chain.
The T&Cs clearly state that we will not tolerate forced labour (including human trafficking) or child labour or abusive disciplinary processes in our supply chain. We reserve the right to terminate our relationship with a supplier if issues of noncompliance with our policies are discovered.
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.
The board of directors of the Company approved this updated statement at its board meeting on 29th March 2021.
Nigel White, Finance Director
Trust Group UK Limited
Dated: 13 March 2019