This statement is made by Redde plc on behalf of the Redde Group pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial year ending 30th June 2018. It sets out the overall commitment of, and steps taken by, Redde Group companies to prevent modern slavery and human trafficking from being present in its business or direct supply chains.
Redde Group Structure
The business activities of the Redde Group as a whole comprise incident management, general insurance mediation, vehicle repair, fleet management, vehicle rental and legal services, all predominantly (but not exclusively) in the automotive sector.
The Redde Group is committed to carrying on its business in a responsible and ethical manner that respects the rights and dignity of individuals and the communities where it operates and provides its services. The Redde Group’s policy is not to tolerate modern slavery or human trafficking and expects the same approach and commitment from those with which it does business.
Redde Group’s Approach
As United Kingdom based businesses the Redde Group’s direct suppliers are primarily based in the United Kingdom. A risk-based approach is used to identify and assess the risks of modern slavery or human trafficking occurring within its businesses or direct supply chain. This risk assessment is reviewed from time to time but so far the Redde Group has assessed these risks as low.
The Redde Group is committed to endeavouring to avoid modern slavery or human trafficking taking place in its direct supply chains or in any part of its businesses. The Redde Group’s Modern Slavery and Human Trafficking Policy reflects its commitment to acting ethically and with integrity in all its business relationships and to implementing systems and controls to reduce the risk of modern slavery and human trafficking occurring in its direct supply chains.
In addition to its Modern Slavery and Human Trafficking policy the Redde Group subsidiaries have between them a range of staff policies including ethics and anti-corruption and a whistleblowing policy to enable an easy communication channel for staff who have concerns. Practices and policies will not, however, be identical across all subsidiary businesses and the Redde Group will try to harmonise these policies in so far as the different businesses will allow.
All Redde Group polices are reviewed periodically.
In the financial year ended 30th June 2018 the Redde Group developed a supplier code of conduct setting out the actions and behaviour expected of suppliers. This code is being implemented in stages as is an extended due diligence processes undertaken when considering taking on new, and when reviewing existing, suppliers.
To ensure a good understanding of the risks of modern slavery and human trafficking in its business and direct supply chains, Redde Group is proposing to require relevant, key employees to complete an online training course on modern slavery and human trafficking and progress has been made towards sourcing a suitable supplier to provide this service.
To date no issues of concern have been discovered but the Redde Group will assess any situations of concern regarding modern slavery and human trafficking on a case by case basis. The Redde Group’s phased implementation its supplier code of practice and its revised due diligence and supplier set-up and review processes will assist in this respect and the whistleblowing policy and will enable staff to raise issues of concern.
Redde Group’s principle businesses each have their own compliance departments which are key points of contact both internally and externally and will assist in ensuring that the Redde Group takes all reasonable steps to comply with its statutory obligations.
The Redde Group will continue to monitor and develop its practices and procedures to help combat modern slavery and human trafficking and to better assist in mitigating the risks of modern slavery and human trafficking occurring in any part of its business or direct supply chains. This will include:
- continuing the rolling review of policies;
- broadening and monitoring the application of the new supplier processes;
- broadening and monitoring the application of the supplier code of conduct; and
- implementing a training programme.
The Board of Directors of Redde plc has approved this policy statement and it has been signed on its behalf by:
Name: Martin Ward
Position: CEO of Redde
Date: 26th October 2018