MODERN SLAVERY ACT STATEMENT

This statement is Snows Motor Group Limited and its subsidiaries Modern Slavery and Human Trafficking Statement relating to section 54 of the Modern Slavery Act 2015 (‘the Act’).

Introduction from the Chairman and CEO

We oppose slavery and human trafficking in all its forms and make this statement to set out the steps we have taken to ensure that slavery or human trafficking is not taking place in our business or in our supply chains.

Slavery and human trafficking remain 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. All Snows colleagues are expected to report concerns and management are expected to act upon them.

Organisation Structure and Business

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 £489m.

Our business is organised across the sixteen different new vehicle brands we represent – Abarth, Alfa Romeo, BMW, Cupra, FIAT, Jeep, KIA, Lexus, Mazda, Mercedes-Benz CV, MINI, Peugeot, SEAT, Toyota, Vauxhall, and Volvo.

Definitions

Snows Motor Group considers that modern slavery encompasses:

• Human Tracking
• Forced work through mental or physical threat
• Being owned or controlled by an employer through mental or physical abuse or threat of abuse
• Being dehumanised, treated as a commodity, or being bought or sold as property
• Being physically constrained or have to restriction placed on freedom of movement

Commitment

Snows Motor Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. We understand that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

Snows Motor Group 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 business in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Snows Motor Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation.

Our Supply Chain

In order to fulfil its activities, the main supply chains of Snows Motor Group include those related to the supply of vehicles and parts from the manufacturers we represent.

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 Chief Operating Officers are responsible for compliance in their respective dealerships and for their supplier relationships.

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.

We provide all colleagues with full details of this statement, along with our Code of Conduct and we have a number of policies in place which further defines our stance on modern slavery including:

• Anti-Slavery Policy

• Whistleblowing Policy
• Anti-corruption and Bribery Policy
• Fraud and Theft Policy
• Money Laundering Policy
• Recruitment Policy
• CSR Policy

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. All colleagues are encouraged to familiarise themselves with this information at induction and annually via our colleague policy portal. Our management structure is 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 is limited to 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
• 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

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 all our colleagues, and all of the Executive Board and the Directors have been briefed on the subject.In addition, our supplier chains and contractors are asked to confirm they too have met the requirements in our agreements with them.

Over the next year, we will continue to seek improvements to training processes for colleagues including widening the scope of the training to included modern slavery as well as child trafficking.

Our Effectiveness in Combating Slavery and Human Trafficking

We use 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. These KPIs include but are not limited to:

• Identifying high risk within our supply chain and
• Obtaining compliance declarations on a biennial basis
• Delivering internal awareness training to all colleagues who join our business and existing colleagues on a regular basis

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

1 January 2023
Stephen Snow
Chairman and CEO, Snows Motor Group Limited

Statement last updated 04/04/2023