In accordance with the Modern Slavery Act 2015 (MSA), this Statement provides the measures which we take to prevent slavery and human trafficking occurring in our business and supply chains.
Arnold Clark Automobiles Limited is fully committed to preventing acts of modern slavery and human trafficking from occurring within both its business and supply chains and requires the same standards on its suppliers.
This Statement will be made available on our website to all who engage with us whether in employment or in business so that those parties may acquaint themselves with the contents.
Arnold Clark Automobiles Limited is the parent company of the Arnold Clark Group. Its subsidiaries are Arnold Clark Finance Limited, (also trading as Arnold Clark Vehicle Management, Activa Contracts and Arnold Clark Car and Van Rental), Harry Fairbairn Limited, GTG Training Limited, Arnold Clark Insurance Services Limited, Towquest Limited and Assure Alarms.
We operate retail sites and service centres across the UK. Our principal activities concern the sale, hire and servicing of new and used automobiles. We represent 24 new car manufacturers. We have over 200 dealerships, 150 service centres, 40 accident repair centres and 13 parts centres. We also have 35 car and van rental locations, 3 training facilities and 6 vehicle leasing business centres. Our Group directly employs over 12,500 people.
Our functions across our businesses are very broad. Our vehicle aftercare includes the servicing and repair of vehicles for both businesses and the general public. We arrange finance to enable customers to buy vehicles. We sell parts and accessories from our parts centres across the UK. We hire vehicles to the public and to businesses throughout the UK. We provide a suite of fleet management services to businesses in the public, private and third sectors. We provide and organise insurance, conduct MOT testing and accident repairs. Our training centres provide various qualifications which include apprenticeships, business courses and building trade courses.
We revisited our assessment from 2018 and concluded that whilst risks exist in our recruitment practices and operational site management, the most significant risks remain in our material and subcontract procurement.
We source and sell products and parts from a broad range of national and international suppliers. Supply chains in the automotive industry are complex and wide ranging, which can make it difficult to conduct full audits of each tier. Furthermore, raw materials commonly used in the automotive industry such as cobalt, which is used in electronics, and rubber, used for tyres and seals, are supplied from a range of high risk countries. Finally, some of our staff members are required to wear company uniforms. The garment industry is highlighted as having a high risk of modern slavery in both its national and international supply chains.
Construction has been highlighted by The Chartered Institute of Building as high risk for modern slavery. This is due to a combination of factors such as high turnover of staff, a reliance on migrant workers and low profit margins across the industry. Our construction and maintenance work is currently outsourced.
Cleaning and valet services also face a higher risk of modern slavery due to similar factors as those in the construction industry including high staff turnover and a reliance on migrant workers. Presently, we employ a number of full and part time cleaning and valet staff across our branches as well as using external suppliers.
We prohibit all areas of our business and supply chain from using slavery and human trafficking of any kind. We are committed to taking action to prevent any cases within our business or supply chains.
From a supply chain perspective, we ensure our suppliers commit to our company values by obtaining written confirmation from all our suppliers that their business practices and supply chains are in accordance with the MSA. In procurement, this is evaluated as part of the tender process. We monitor compliance of these suppliers with suitable levels of due diligence according to the level of risk which we assess for the potential of human trafficking and/or modern slavery. However, due to the complexity of the global supply chains in the automotive industry we are unable to check every business relationship and avenue between each tier.
Any instances of non-compliance, alleged modern slavery or human trafficking of which we are made aware of will be assessed on a case-by-case basis. We will quickly and thoroughly investigate any claim or indication that any area of our business or supply chain is engaging in human trafficking or slave labour. Any such claim would be reported to senior management as appropriate. The board of directors will be informed of the issue including the findings and outcome of the investigation.
If such instances are proven, remedial action will be taken and tailored to suit the circumstances. We will only trade with those who are taking steps towards full compliance. If we are not satisfied with the steps being taken towards full compliance, we will temporarily suspend our business with that supplier (to the extent allowed in contract or law). The ultimate sanction for the continual failure to comply will be for us to cease to trade with that supplier (to the extent as provided for in law or contract).
Our estates department only contract with those contractors who are “Alcumus SafeContractor” approved, (https://www.safecontractor.com) in order to guarantee that construction companies are health and safety accredited. Alcumus SafeContractor are committed to stamping out modern slavery within the construction industry. For workers on our own sites and locations, we require our contractors to check that all on site workers carry Construction Skills Certification Scheme (CSCS) cards which are only granted to licensed labourers and engineers.
For our valet and cleaning services we only contract with approved external suppliers. These suppliers are vetted and must sign up to our terms and conditions whereby they must adhere to minimum wage and labour standards including providing sick pay, holiday pay and providing contracts and wage slips to their employees.
Finally, one of our main protection against modern slavery is that we ensure all our operations comply with minimum wage legislation and that all our employees have the right to work in the UK. We also require our contractors to comply with these standards. While we acknowledge that this does not eradicate completely the risk of modern slavery, it is one of the most effective ways of combating this risk.
While we have made numerous steps towards reducing the risk of modern slavery and human trafficking within our business, we understand that there is still more that all businesses, including our own, can do. Some of the steps we are taking in 2019 will help us to do this.
Our procurement team plan to complete further training on how we can reduce the risk of modern slavery and human trafficking within our supply chains. By furthering our understanding of how we can use contractual obligations in our procurement activities, we hope to be able to work more effectively with our suppliers in minimising the risk of modern slavery. This can then be utilised in a range of procurement activities, including but not limited to the procurement of company uniforms and cleaning services.
From a contractual perspective, we also plan to work more closely with those who supply our construction services to mitigate the risk of modern slavery on our sites. Our estates team are considering methods to improve our due diligence in this area and are committed to a collaborative approach between ourselves and external contractors.
Arnold Clark Automobiles Limited and all its employees are committed to eliminating modern slavery and human trafficking within our business activities and supply chains. Employees are encouraged to familiarise themselves with this statement and our whistle blowing policy so as to incorporated our ethical business values within their day to day working.
This statement has been approved by the Arnold Clark Automobiles Limited board of Directors on 8th April 2019 and the original statement has been signed by our Managing Director, Eddie Hawthorne. This statement will be reviewed and updated on an annual basis.