MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person's liberty and dignity for another person's gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.

At Mike Pulman Holdings Limited, Mike Pulman Limited, Pulman SEAT Limited and Pulman Skoda Limited (“the Group”) we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2019.

Our Business and Supply Chains

We are a Volkswagen, Skoda, SEAT, Cupra and Volkswagen Commercial Vehicles automotive dealership with sites across the North East of England offering motor retail and aftersales services. Our operations are carried out in the UK.

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards, and references

We haven't been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.

Policies

The Group operates the following policies for identifying and preventing slavery and human trafficking in our operations:

  • Whistleblowing Policy - we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of the whistleblowers.
  • Code of Conduct - our code encourages employees to do the right thing by clearly stating the actions and behavior expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behavior when operating abroad and managing our supply chain

Supplier Due Diligence

We expect all suppliers to ensure:

  • They don't use any form of forced, compulsory or slave labour
  • Their employees work voluntarily and are entitled to leave work
  • They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
  • They don't require employees to post a deposit/bond and don't withhold their salaries for any reasons
  • They don't require employees to surrender their passports or work permits as a condition of employment

If we find any supplier not adhering to these minimum standards, it is our policy to cease trading with them immediately.

Alternative Supplier DD

The Group have reviewed our supply chains to identify particular categories that potentially carry a risk over Modern Slavery. We will continue our proactive approach to mitigating this risk in the year.

Our procurement team is working hard to ensure that where we have group wide contacts, we are only trading with suppliers that have signed up to our terms, which prohibits any forms of exploitation.

Any suppliers found to have breached these obligations could face sanctions, including termination of our contract with them.

Awareness

The Group has raised awareness of modern slavery issues by adding a section to the staff handbook that is focused specifically on modern slavery to all our staff, which explains:

  • Our commitment in the fight against modern slavery
  • Red flags for potential cases of slavery or human trafficking
  • How employees should report suspicions of modern slavery

This statement covers 1 January 2019 to 31 December 2019 and has been approved by the board of The Group at the board meeting on 10/05/2019

MD Signature
Ian Buckle, Managing Director