Modern Slavery Statement for Birchwood Group in East and West Sussex

Introduction

Birchwood Group is committed to the prevention, deterrence, and detection of modern slavery and human trafficking. In line with general employment and human rights laws, and specifically the UK government's Modern Slavery Act 2015, we have reviewed our existing compliance and risk management processes to determine the necessary measures to prevent modern slavery and human trafficking within our business and supply chain.

Birchwood Group has adopted a modern slavery statement approved by the board of directors. This statement is available on our website. This policy supports our statement and outlines our approach to dealing with modern slavery and human trafficking.

Purpose of this Policy

• Modern slavery is a criminal offence under the Modern Slavery Act 2015. It can occur in various forms, such as forced or compulsory labour and human trafficking, which exploit individuals for personal or commercial gain.
• Birchwood Group has zero tolerance for modern slavery and human trafficking and fully supports the Modern Slavery Act 2015.
• This document sets out our policy against modern slavery and human trafficking, as well as the standards and procedures required to ensure compliance within our business and supply chains.

Birchwood Group specialises in the sale, repair, and service of new and used motor vehicles, as well as the sale of accessories and replacement parts. This statement applies to all companies within the Birchwood Group that are incorporated in the UK.

Birchwood Group currently has around 1,293 employees working at its motor dealerships.

We establish relationships of trust and integrity with all our suppliers, built upon mutually beneficial factors. Our supplier selection and onboarding procedures include due diligence of the supplier's reputation, respect for the law, compliance with health, safety, and environmental standards, and references. We have not been made aware of any allegations of human trafficking or slavery activities against any of our suppliers, but if we were, we would act immediately against the supplier and report it to the authorities.

Risk Assessment

In the past year, we conducted a risk assessment of our supply chain by considering:

• The risk profile of individual countries based on the Global Slavery Index.
• The business services rendered by the suppliers.
• The presence of vulnerable demographic groups.

This assessment has determined our response and the risk controls that we implement.

Policies

Birchwood 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.
• Our Conduct Rules – Our conduct rules encourage employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our supply chain.

Birchwood Group conducts supplier due diligence on all new suppliers during onboarding and on existing suppliers at regular intervals.

We require all suppliers to verify that:

• They do not 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 do not require employees to post a deposit/bond and do not withhold their salaries for any reasons.
• They do not require employees to surrender their passports or work permits as a condition of employment.

Birchwood Group
Date – 11 July 2024

Third-Party Harassment and Sexual Harassment.

Birchwood Group is committed to providing a safe, inclusive, and respectful working environment for all employees. We have a zero-tolerance policy towards any form of harassment or sexual harassment by third parties, including clients, customers, contractors, suppliers, consultants, and visitors.

Harassment is defined as unwanted conduct related to a protected characteristic (such as age, sex, race, disability, religion, sexual orientation, etc.) that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment.

Sexual harassment includes anyunwanted conduct of a sexual nature that violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating, or offensive environment. This applies regardless of intent.

Examples include (but are not limited to):

• Offensive, intimidating or abusive language or behaviour
• Unwelcome sexual advances, comments, or gestures
• Inappropriate physical contact
• Sending or displaying offensive material
• Persistent unwanted attention or communication
• Victimisation or retaliation following a complaint

All third parties engaging with Birchwood Group are expected to:

• Treat our employees and representatives with dignity and respect
• Avoid any conduct that could constitute harassment or sexual harassment
• Comply with our workplace policies and site conduct rules
• Cooperate fully with any investigation into alleged misconduct

Birchwood Group reserves the right to take immediate and appropriate action in response to any breaches of this statement. This may include formal warnings, removal from site, or termination of the business relationship.

We ask all third parties to uphold our values and contribute to a respectful and safe working environment.

For concerns or questions regarding this statement, please contact: HR@birchwoodgroup.co.uk