Slavery Statement

Slavery and Human Trafficking Statement for Snows Motor Group Limited and its subsidiaries for the year ending 31 December 2018.

Introduction from the Group Chairman

Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.

Organisation Structure

We are primarily an automotive retailer and a provider of servicing and parts. Snows Business Holdings Limited is the parent company of a wholly owned subsidiary, Snows Motor Group Limited. The group has its head office in the UK (Southampton) and all trading outlets are in the UK (South and South West of England).The group has an annual turnover in excess of £372m.

Our Business

Our business is organised across the nineteen different brands we represent – Abarth, Alfa Romeo, BMW, Citroën, Cupra, FIAT, Jeep, Kia, Lexus, Lotus, MINI, Mazda, Mercedes-Benz Vans, Peugeot, SEAT, Suzuki, Toyota, Volvo & Volkswagen Commercial Vehicles.

Our Supply Chain

Our supply chains principally include the supply of vehicles and parts from the manufacturers we represent.

Our Policies on Slavery and Human Trafficking

We are committed to, where possible and practical, due to the breadth of our business and supply chains, to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We provide all employees with full details of this statement, along with our Code of Conduct and Whistle-blowing Policy. All employees are encouraged to familiarise themselves with this information at induction and at regular intervals via our employee policy portal. Our management structure are familiar with these policies and are aware of their responsibilities in relation to them. 

Due Diligence Process for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk –

• We manage retail dealerships in-line with best practice UK automotive standards;
• The geographical scope of our premises are limited to the Southern England allowing us to have firm control on our activities and being able adequately to oversee them;
• Where possible we build long standing relationships with local suppliers and, make clear our expectations of business behaviour;
• With regards to national or international supply chains, our point of contact is the represented personnel of our UK-based manufacturer partners and we expect these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity in the chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the chain.
• We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due Diligence Process for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk –

• We manage retail dealerships in-line with best practice UK automotive standards;
• The geographical scope of our premises are limited to the Southern England allowing us to have firm control on our activities and being able adequately to oversee them;
• Where possible we build long standing relationships with local suppliers and, make clear our expectations of business behaviour;
• With regards to national or international supply chains, our point contact is the represented personnel of our UK-based manufacturer partners and we expect these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity in the chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the chain.
• We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.
• We will quickly and thoroughly investigate any claim or indication that any area of our business, or its associated supply chain, is engaging in human trafficking or slave labour.

Supplier Adherence to Our Values

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.

The Franchise Directors are responsible for compliance in their respective dealerships and for their supplier relationships.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Directors have been briefed on the subject. Further training has been identified as an area for improvement since our last statement was issued.

Our Effectiveness in Combating Slavery and Human Trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Identify high risk within our supply chain and obtain compliance declarations on a biennial basis;
• Use of labour monitoring and payroll systems to determine compliance with Living/Minimum wage rates and Working Time Regulations; and

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group's slavery and human trafficking statement for the financial year detailed above.