This Statement details the steps we have taken up to the end of November 2017 towards ensuring that slavery and human trafficking are not taking place either in our organisation or our supply chain. Contract Vehicles Limited (CVL) will not knowingly support or deal with any business involved in modern slavery or human trafficking.
This is CVL’s second annual Modern Slavery Act Transparency Statement and shows the progress we have made in developing and maturing our strategy.
CVL is a private limited company providing commercial vehicle contract hire, leasing and fleet management services to UK based companies as well as UK and Irish operations of global businesses. Generally these customers use CVL’s fleet management services for activities confined to the UK and Eire, but some customers transit goods throughout the EU, EEA, Russia and Switzerland.
CVL employs over 120 employees in the UK. In February 2017, we were acquired by the Zenith Group.
It is anticipated that next year Zenith Group will publish one statement for the whole group, including CVL.
Our supply chain
Like Zenith, we have now categorised our supply chain into four groups:
• Core in-life
• Wider network
• Large corporate
• Non-direct / ad hoc
As a Zenith Group company, we have adopted the Environmental & Corporate Social Responsibility Policy, which embeds a specific commitment to preventing slavery and human trafficking. This Policy commitment will be underpinned by the following:
• A collaborative approach with our supply chain, which encourages transparency
• A procurement policy incorporating pre-contractual supplier due diligence
• Regular risk assessments
• Annual training for key stakeholders
• Whistleblowing procedures
We will launch a Supplier Code of Conduct (“Code”) which communicates our ethical approach to doing business to our suppliers, including slavery and human trafficking. The Code requires our suppliers to have in place effective policies and procedures which reflect similar ethical commitments and to cascade this down their own supply chain. Any violations must be reported to CVL and failure to adhere to the Code may result in a termination of supply, reduced volume of business or non-inclusion in future tender opportunities.
Our approach to assessing and managing risk
We have assessed our exposure to the risk of slavery and human trafficking as low for the following reasons:
• We are entirely UK based.
• Almost all of our direct suppliers have strong levels of corporate governance and are based in countries where slavery and human trafficking are low risk.
• Where services are provided in the EEA, Russia and Switzerland we subcontract to companies operating within the EU. The subcontractor will then appoint an approved partner or franchisee.
• We perceive our greatest exposure to risk (albeit still limited) is further down our supply chains – broadly where workers receive low pay for low skill work, or where raw materials and manufacturing originate in high risk countries. Activities further down our supply chain are out of our direct control.
Going forward, we will adopt Zenith’s approach to assessing and managing risk.
Our due diligence processes
As a Zenith Group company, we will adopt Zenith’s supply-chain due diligence processes, which are proportionate to the level of assessed risk.
Where we take on a new supplier to our operational businesses we will require them to respond to our pre-contractual due diligence questionnaire which specifically addresses slavery and human trafficking. All such new suppliers will also be required to agree to our Code of Conduct.
We will refresh the due diligence on our existing suppliers to our operational businesses. Our Code will be launched initially across the core in-life suppliers, which represent the vast majority of our supply-chain. Subsequently we will look to launch the Code, where possible, across the large corporate and non-direct / ad hoc supplier groups.
Key internal stakeholders have been provided with Zenith’s training materials and will receive classroom training sessions shortly. Future sessions will be refreshed and delivered by Zenith’s Compliance Officer.
Our effectiveness in combating slavery and human trafficking
We will track various metrics throughout the course of the year and report on these in our subsequent, combined Statement from the Zenith group.
This Statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and has been approved by the Board of Directors.