ORGANISATION
This statement applies to Motorclean Ltd (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2020/2021.
ORGANISATIONAL STRUCTURE
Our services are provided across the UK which is divided into Regions (Managed by a Regional Manager) and sub Divided into Areas (managed by an Area Manager ) The field Staff are supported from a team at the Organisations Head Office based in Laindon Essex. All of this is managed by the Board of Directors. The main activity carried out by the Organisation is the provision of valeting services to the Automotive Industry, in addition to this it provides imaging services and drivers. These activities are carried out on the premises of our client and occur all year around.
DEFINITIONS
The Organisation 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
COMMITMENT
The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Organisation does not enter into business with any other organisation, 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 Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK.
SUPPLY CHAINS
In order to fulfil its activities, the main supply chains of the Organisation include those related to the supply of Chemicals and equipment. We understand that the Organisation’s first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.
POTENTIAL EXPOSURE
The Organisation considers its main exposure to the risk of slavery and human trafficking to be through its subcontracting of the services. In general, the Organisation considers its exposure to slavery/human trafficking to relatively high and so has taken steps to ensure that such practices do not take place in its business. This is done by the undertaking of stringent checks on all PAYE and Sub -Contract personnel and ensuring that the same applies to the business of any organisation that supplies goods and/or services to it.
STEPS
The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:
• Have undertaken an audit to identify potential risks in the supply chain.
• Reviewed our supplier contracts to ensure that there is an immediate termination clause that can be evoked in the event that the supplier is, or is suspected, to be involved in modern slavery.
• Have undertook impact assessments of our services and the potential instances of slavery.
• All staff are made aware of where the potential for risk with Modern Slavery – those that work closely within the departments that are exposed to the elements where risk is highest are trained to be extra vigilant and to report the slightest suspicion to their line manager where it is investigated thoroughly.
KEY PERFORMANCE INDICATORS
The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.
• Our dedicated staff view 70-80 contracts per week , a photo is taken of the potential operator and two forms of Proof of Identity and Address are provided.
• Our system highlights bank accounts used for multiple operators for addresses where more than 2 operators live.
All of the above are investigated by our experienced staff , if they are not satisfied with the responses they then highlight this to their line manager or further investigation. We reject approximately 4% of the contracts per year, for various reasons.
POLICIES
The Organisation has the following policies which further define its stance on modern slavery a modern slavery policy.
SLAVERY COMPLIANCE OFFICER
The Organisation 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 Organisation’s obligations.