MODERN SLAVERY STATEMENT

Indtroduction

This statement sets out Leven Cars Group Limited’s actions to understand all potential Modern Slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 January 2018 to 31 December 2018.

As part of the motor retail and repair industry, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The Company is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking. Integrity and Respect are two of our core company values and we strive to operate our business with honesty and professionalism whilst showing the utmost respect to our employees, customers and suppliers at all times. As such Leven Cars Group Limited have a zero tolerance approach to Modern Slavery and human trafficking.

Company structure and supply chains

This statement covers the activities of Leven Cars Group Limited:

  • We are a privately owned family business founded in May 2014;
  • Leven Cars Group Limited are a motor dealer group situated in Scotland. We sell new and used vehicles and carry out maintenance and repair on vehicles. We are proud to represent the marques of Aston Martin, Kia, Lotus, Mitsubishi, Rolls Royce and Suzuki in dealerships located in both Edinburgh and Selkirk. We also operate a Leasing Company;
  • We were awarded 'Number 1 dealer in the world for Customer Satisfaction in New Car Sales' (2017) for our Aston Martin franchise;
  • We were also awarded European Provenance Dealer of the Year awards in 2015 and 2016 for Rolls Royce.

Countries of operation and supply

The Company currently operates in the following countries:

  • Leven Cars Group Limited have businesses solely in Scotland and do not operate anywhere else either in the UK, Europe or other international areas;
  • To operate our business effectively we have contracts with various multinational suppliers. These contracts are primarily multinational parts and vehicle manufacturers;
  • Leven Cars Group Limited are committed to only dealing with reputable suppliers who have their own stringent Modern Slavery Policy and processes.

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

  • Leven Cars Group Limited will not interact with any Company which does not have a Modern Slavery Statement and that this statement is core to their Company values;
  • We shall continuously monitor our supply chain to identify any areas of risk

Responsibility

Responsibility for the Company's anti-slavery initiatives is as follows:

  • Policies: The Group Personnel Manager in conjunction with the Board of Directors shall continuously review this policy;
  • Risk assessments: the Group Personnel Manager shall ensure no employee is paid below their statutory minimum entitlement. The Senior Management Team shall notify the Board of Directors should they suspect any part of the supply chain puts the Company’s Modern Slavery Statement at risk;
  • Investigations/due diligence: the Group Personnel Manager shall carry out any necessary investigations in conjunction with the relevant Senior Manager if an instance of suspected slavery or human trafficking is identified;
  • Training: All employees are taken through a Company induction and introduced to the Company Values and culture

Relevant policies

The Company operates the following policies that describe its approach to the identification of Modern Slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy: The Company encourages all its employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
  • Company Values: The Company's core values makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour at all times.
  • Supplier code of conduct: The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
  • Recruitment policy: The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. In addition, every new employee of the Company has their “Right to Work” in the UK checked during the recruitment process.

Due diligence

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company's due diligence and reviews include:

  • mapping the supply chain broadly to assess particular product or geographical risks of Modern Slavery and human trafficking;
  • evaluating the Modern Slavery and human trafficking risks of each new supplier;
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.

Performance indicators

The Company has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the Company is:

  • require all staff to have completed training on our Values and Modern Slavery by 30th April 2019;
  • developing a system for supply chain verification expected to be in place by 30th April 2019, whereby the Company evaluates potential suppliers before they enter the supply chain; and
  • reviewing its existing supply chains expected to be completed by 30th June 2019, whereby the Company evaluates all existing suppliers.

Training

The Company requires all employees within the Company to read our policy on Modern Slavery and this will be shared via our intranet site. This is in addition to having a Company induction which advises all employees of the Company values and culture.

  • We would encourage all employees to notify their Line Manager of any suspected breaches of our Modern Slavery statement, however, there may be occasions where they feel unable to do so:
  • Therefore, we shall ensure all employees are aware of the Modern Slavery helpline website and number as detailed below;
  • The website can be found at www.modernslaveryhelpline.org
  • The helpline number is 08000 121 700.

Board approval

This statement has been made in relation to section 54(1) of the Modern Slavery Act 2015. This is our Modern Slavery and Human Trafficking statement for the financial year ending 31st December 2018. This statement has been approved by the Company's Board of Directors, who will review and update it annually.

Chairman: Mr Hugh McMahon

Managing Director: Mr Chris McMahon

Date: 31st March 2019