Modern Slavery Statement


Introduction
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
The Harratts Group Limited has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing appropriate and effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in our supply chains.
The Modern Slavery Act 2015 (the “Act”) introduced changes in UK law focused on increasing transparency in supply chains. Specifically, large businesses are required to disclose the steps they have taken to ensure their business and supply chains are free from modern slavery.
This statement sets out the steps we have and are taking to ensure that slavery and human trafficking are not taking place in any of our supply chains or businesses and is made pursuant to section 54(1) of the Act.

Group Structure
The Harratts Group Limited is the holding company of a number of trading subsidiaries (the “Group”) whose principal activities are the sale of cars and commercial vehicles, vehicle leasing, vehicle servicing and associated activities.
All of the Group’s operations are based in the United Kingdom and the Group employs 155 members of staff across its businesses.

Our Supply Chains
The Group’s principal suppliers are global vehicle manufacturers which supply the Group vehicles and parts for onward sale to customers and under whose franchise agreements the Group operates its motor dealership businesses.
In addition, the Group has commercial arrangements with vehicle finance and insurance providers which provide finance and insurance products to the Group’s customers. The Group also engages with other providers of goods and ancillary services (including oil and consumables supply, valeting services etc).
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. We have adopted an Anti-slavery Policy which 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 Processes for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk, we are putting in place systems to:
• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains, focusing on the highest risk areas.
• Protect whistle blowers.

Supplier Adherence to Our Values
We have zero tolerance to slavery and human trafficking. We are reviewing our supply chain management process to ensure all those in our supply chain and contractors comply with our values and their legal obligations. This includes seeking confirmation from key suppliers of the Group that they have implemented contractual arrangements which prohibit modern slavery and trafficking and seeking confirmation that they have adopted their own anti-slavery and human trafficking policies. We are also introducing changes to our standard terms and conditions of trading to require suppliers to comply with all applicable anti-slavery and human trafficking laws. A number of our key commercial supply arrangements already contain specific provisions regarding slavery and human trafficking and contractual arrangements will be updated, where necessary, upon renewal.

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 will be providing appropriate training to our staff to raise awareness and highlight any areas of concern they may have.
Effectiveness in Combating Slavery and Human Trafficking
We have not identified any instances or indications that either slavery or human trafficking occurs in our supply chain. As such, we have not considered it necessary to adopt any formal performance indicators 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. We intend to keep this under review.

Further Steps
As set out in above, the Group is in the process of taking a variety of further steps to ensure that neither slavery nor human trafficking occurs either in our business or in our supply chain.

Approval
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st December 2019. Approved by the board on the 29th March 2019.

S.M. Harratt FIOD
The Harratts Group Limited
Finance Director
Date: 8/04/2019

Harratts Group Ltd | Calder Park, Off Denby Dale Road, Wakefield, West Yorkshire WF2 7UA

Harratts Limited is an appointed representative of ITC Compliance Limited which is authorised and regulated by the Financial Conduct Authority (their registration number is 313486) and which is permitted to advise on and arrange general insurance contracts.