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 business, 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 us not taking place in any of our supply chains of any part of our business.
The organisation is composed of Central Garage (Uppingham) Limited, a franchised motor dealer and ultimate parent company of six other companies, also predominantly franchised motor dealers. Our core activities are the sales and service of motor vehicles along with their associated parts.
As part of the organisation’s induction process and throughout workers’ employment with us, we train all staff to treat others with respect and courtesy as well as ensuring they adhere to all relevant laws, regulations and standards. This is an ongoing due diligence process. We offer a training and development program for all staff from the ground floor through to management. 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 worker is found in breach of our policies, we ensure suitable disciplinary action is taken which can include termination.
In relation to our supply chains, we use our reasonable endeavours to conduct risk assessments of the third parties we work with. However, as the majority of our purchases by value come from multi-national motor manufacturers, it is not feasibly for our organisation to investigate their own practices and supply chain, therefore we would refer any interested parties to view the Modern Slavery and Human Trafficking Statement of the relevant supplier(s) that we represent.
As part of our risk assessments, we have procedures in place to identify whether there is a possible risk of slavery and human trafficking either in the business or our supply chain. Our sources of supply are predominantly from the United Kingdom, Europe and the United States. As such, we do not view this as a significant and as a result we have taken no further steps to assess and mange that risk. However, should a risk be identified, we aim to work with our colleagues and suppliers to ensure collaboration to remedy or mitigate such risks.
We allow all individuals who work to provides services to us the right to freely choose employment and, the right to associate freely with other individuals. Workers are free to choose whether to join a trade union or not and 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 legalisation. We do not engage in forced or involuntary labour and have a zero tolerance approach to the same, meaning we not tolerate any of our suppliers engaging in such conduct.
As a result of our risk assessments, we have introduced new performance indicators, being training about modern slavery issues, which we have introduced to reduce such risk occurring.
Central Garage (Uppingham) Limited trading as Sycamore Harley-Davidson is an appointed representative of ITC Compliance Limited which is authorised and regulated by the Financial Conduct Authority (their registration number is 313486). Permitted activities include advising on and arranging general insurance contracts and acting as a credit broker not a lender.
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