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Anti-Slavery & Human Trafficking Policy
Introduction
This statement sets out Spirit Motor Holdings Limited's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed to ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to the actions and activites during the financial year 2019/2020.

As part of the Automotive Retail & Repair industry, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.


Organisation structure and supply chains
This statement covers the activities of Spirit Motor Holdings Limited:

Our supply chains include sourcing, sale and leasing motor vehicles (predominantly Hyundai), parts, consumables and provision of services, repairs, including body and repair. Respecting human rights in the supply chain is ultimately our suppliers' responsibility however we will ensure that our expectations concerning slavery and human trafficking are communicated to them.


Relevant policies
The Company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy: The Company encourages all its workers, customers, and other business partners to report any concerns related to the direct activites, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation;
  • Employee code of conduct: The Company's code makes clear to employees that actions and behaviour expected of them when representing the Company. The Company is strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain;
  • Supplier code of conduct: The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with supplier to ensure that they meet the standards of the code and improve their workers' working conditions. However, serious violations of the Company's supplier code of conduct will lead to termination of the business relationship;
  • Recruitment/agency workers policy: The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.


Training
The Company requires all relevant staff within the Company to complete training on modern slavery.

The Company's modern slavery training covers:

  • Our business's purchasing practices, which influence supply chains conditions and which should, therefore, be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below the country's national minimum wage, or the provision of products by an unrealistical deadline;
  • How to access the risk of slavery and human trafficking about various aspects of the business, including resources and support available;
  • How to identify the signs of slavery and human trafficking;
  • What initial steps should be taken if slavery or human trafficking is suspected;
  • How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.
  • What external help is available, for example through the Modern Slavery Helpline;


Board approval
This statement has been approved by the Company's board of directors, who will review and update it annually.