Modern Slavery Policy
This statement applies to Unity Automotive Group (referred to in this statement as ‘the Company’). The information included in the statement refers to the financial year 2018/2019.
Unity Automotive Group Ltd is the company name with four vehicle dealerships operating under Unity Automotive Group Ltd, Unity Oxford, Unity Coventry, Unity Leicester & Unity Tredington – The company is controlled by a Board of Directors.
The main activity carried out by the Company is the sale, service and repair of motor vehicles. The Company performs the sale of the aforementioned goods from specialised dealerships based in the Midlands. Demand for our product is consistently high throughout the year and is therefore not seasonal.
The labour supplied to the Company in pursuance of its operation is wholly carried out in the United Kingdom.
The Company considers that modern slavery encompasses:
• human trafficking
• forced work, through mental or physical threat
• being owned or controlled by an employer through mental or physical abuse of the threat of abuse
• being dehumanised, treated as a commodity or being bought or sold as property
• being physically constrained or to have restriction placed on freedom of movement.
The Company acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Company understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Company does not enter into business with any other company, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Company in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom and in many cases exceeds those minimums in relation to its employees.
In order to fulfil its activities, the main supply chains of the Company include those related to the sale, service and repair of motor vehicles. The Company performs the sale of the aforementioned goods from specialised dealerships.
The Company considers its main exposure to the risk of slavery and human trafficking to exist in its vehicle and vehicle parts supply chains and working with suppliers who are contracted or do contract out because they involve the provision of labour in or from a country where protection against breaches of human rights may be limited
In general, the Company considers its exposure to slavery/human trafficking to be relatively limited and it has taken steps to ensure that such practices do not take place in its business nor the business of any company that supplies goods and/or services to it.
The Company carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its company or supply chains, including conducting a review of the controls of its suppliers.
The Company has not, to its knowledge, conducted any business with another company which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Company has taken the following steps to ensure that modern slavery is not taking place:
• Raised awareness with the workforce in the company
• Operate a right to work policy with checks at the recruitment stage
• Ensure minimum employment age adhered to, in line with relevant legislation.
• Always apply national minimum wage thresholds, in line with the relevant legislation
• Where possible we build long standing relationships with local suppliers and make clear our expectations of business behavior
• We limit the geographical scope of our operations to the UK, Ireland and Europe
Key performance indicators
The Company has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Company or its supply chains.
• Store right to work documents including copies of passports securely on an online HR system
• Payroll check and record data including minimum employment age and wage thresholds.
• Employee reference check at the recruitment stage
The Company has the following policies which further define its stance on modern slavery.
• Equality and Diversity Policy
• Flexible Working Policy
• Dignity at Work Policy
• Other Time of Policy
• Part Time Workers Policy
• Whistle-blowing Policy
• Equal Opportunities Policy
Slavery Compliance Officer
The Company has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Company’s obligations.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.
Date of approval: 05/11/2018
Signed: Mark Hensher
Print name: Mark Hensher
Job Title: H R Director