1: Opening statement from senior management
FRF Motors Limited has a zero tolerance approach to modern slavery. This is our first statement under section 54 of the Modern Slavery Act 2015 and sets out the steps we are taking in order to minimise the risk of modern slavery in our business and supply chain during the year ending 31 March 2019.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. FRF Motors Limited has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
2: Structure of the organisation
The FRF Motors group encompasses modern Mazda, Vauxhall and Peugeot dealerships in Swansea and Bridgend, as well as our Approved Used car division known as The Car Warehouse. We are an independent family-run business that has maintained a commitment to service excellence for over 40 years, we are involved in the sales, servicing and repairs of vehicles.
Our supply chains are extensive and we expect the same high standards which we set out for ourselves from those parties with whom we engage, such as our suppliers and customers.
3: Policies
As part of our commitment to combating modern slavery, we have implemented the following policies:
- Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all directly employed staff, to safeguard against human trafficking or individuals being forced to work against their will.
- Equal Opportunities. We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities.
- Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals.
- An anti-corruption and bribery policy. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
We also make sure our suppliers are aware of our policies, and adhere to the same high standards.
4: Due diligence
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted the following due diligence procedures:
- Mitigate the risk of slavery occurring in our supply chains;
- Monitor potential risk areas in our supply chains; and
- Protect those who report concerns regarding modern slavery ('whistleblowers' with the Company's Whistleblowing Policy).
Our procedures are designed to:
- Establish and assess areas of potential risk in our business and supply chains;
- Monitor potential risk areas in our business and supply chains;
- Reduce the risk of slavery and human trafficking occurring in our business and supply chains; and
- Provide adequate protection for whistleblowers.
5: Risk and compliance
FRF Motors Limited has taken advice to ensure that it understands the requirements of the Modern Slavery Act 2015.
We have considered our exposure to the risk of modern slavery across all aspects of our business, and have identified 4 key areas:
- Agency and temporary employment practices;
- 3rd Party Dealerships and Importers;
- Material suppliers; and
- Sub-contractor relationships.
We require our suppliers to comply with the Modern Slavery Act 2015 and report any incidents or suspected incidents of modern slavery to us. We reserve the right to terminate our relationship with suppliers if they do not adhere to the Modern Slavery Act 2015, or if they breach our Supplier Code of Conduct.
6: Training
To ensure a level of understanding of the risks of modern slavery in our supply chains and our business, we are in the process of rolling out training to key members of staff across different sectors of our business. We will also encourage our business partners to provide training to their staff and suppliers and providers.
It is the responsibility of all members of staff, to seek to prevent, detect and report modern slavery in our business or supply chain. Members of staff are encouraged to raise any concerns regarding modern slavery at the earliest opportunity and must not act in a way that is inconsistent with, or which might lead to a breach of the Modern Slavery Act.
7: Further actions and sign-off
Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking:
In the coming year we will seek to measure how effective we have been to ensure that modern slavery is not taking place in any part of our business of supply chains: We will also provide training to employees so that they can identify and understand what modern slavery is, how to report concerns and so that they can support and facilitate our ongoing commitment to combating modern slavery.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes FRF Motors Limited's slavery and human trafficking statement for the financial year ending 31st March 2019.
This statement was approved by Paul Watkins, Director on 1st April 2019.