This Statement details the steps we have taken up to the end of March 2022* towards ensuring that slavery and human trafficking are not taking place either in our organisation or our supply chain. Zenith has a long-standing commitment to conducting business ethically and the prevention of slavery and human trafficking is an important part of that commitment.
This is Zenith’s sixth Modern Slavery Act Transparency Statement and shows the progress we have made in developing and maturing our strategy.
We have had zero incidents, allegations, or reports of modern slavery within Zenith or our supply chain.
We have assessed our exposure to the risk of slavery and human trafficking as low. An explanation of this assessment can be found in the ‘Our approach to assessing and managing risk’ section below.
The Zenith Group includes Zenith Vehicle Contracts Limited, Provecta Car Plan Limited, Leasedrive Limited, ZenAuto Limited, Contract Vehicles Limited, Contract Vehicle Fleet Services Limited, Contract Vehicles Rentals Limited and Zenith Remarketing Limited (“We”, “Us”, “Our”).
The Zenith Group employs over 1000 employees in the UK. We are the UK’s leading independent leasing, vehicle outsourcing and fleet management provider.
We are based across seventeen locations. Two of these are offices; based in Leeds and Altrincham. Colleagues at these locations undertake administration, customer services, sales, and professional-skilled roles.
We also have eleven rental yards and four HGV workshops. The roles at these sites include administration, skilled automotive mechanics, technicians and welders.
In 2021, we launched an agile working policy. This allows colleagues to work from home at times, taking into consideration the needs of the customer, the wider business and their team.
Our supply chain
Our supply chain includes suppliers of both goods and services and is geographically diverse across the UK. Services provided include vehicle manufacturers, essential fleet management services, such as glass and tyre replacements, licence checking, emergency assistance, and garage repair networks. We also use IT and service administration suppliers.
In 2020 we began to categorise our supply chain based upon the following criteria:
Full compliance and due diligence. Includes contingency planning where applicable due to the criticality of supply.
Active management with defined business and contractual owners. Regular reviews, monitoring and SLA adherence.
Change of supply would be a considered approach.
Active management is not practical or viable. Full compliance and due diligence would still apply but not active management and monitoring.
Examples include our office landlords, the DVLA, and some systems providers. Change of supply is not generally an option or would not be practical.
Change of supply would be relatively easy.
We accept that our current categorisation only applies to tier one of our supply chain. We are working with our suppliers to understand the additional tiers of the supply chain and as the business matures we continue to refine and develop this.
Our policy commitment to preventing slavery and human trafficking is underpinned and supported by the following:
- A collaborative approach with our supply chain, which encourages transparency. We will provide appropriate support, guidance and monitoring to tackle any reported issue. Serious or repeated violations may result in a termination of supply, reduced volume of business or non-inclusion in future tender opportunities;
- On-going training for key stakeholders within Zenith.;
- A supplier lifecycle and procurement policy incorporating pre-contractual supplier due diligence, comprehensive contractual agreements and periodic review;
- An Environmental, Social and Governance (ESG) policy outlining our commitment to upholding human rights including combatting slavery and human trafficking;
- Supplier Code of Conduct;
- Annual risk assessment of the supply chain;
- Whistleblowing procedures within Zenith;
- The introduction of a contractual requirement for direct suppliers to our operational business to monitor compliance and report any matters of concern;
- Supplier Governance and Risk Forum with a clear and defined terms of reference;
- A third-party governance, risk and compliance (GRC) software system.
Our approach to assessing and managing risk
We categorise individual suppliers into one of four categories defined in the ‘Our Supply Chain’ section above. We assess an individual supplier’s risk by considering the following factors:
- Compliance controls
- Data Protection
- Information Security
- Employee screening
- Human rights and labour conditions
- Business continuity planning
- The supplier’s control, governance and management of their own suppliers
- The nature/type of the goods or services provided
- The location of the supplier
- Zenith transactional spend with the supplier
Assessing Modern Slavery risk within the supply chain
We take the following steps to identify modern slavery risk areas within our supply chain as a whole:
- Completing consultations with relevant internal stakeholders when assessing a supplier’s risk
- Regularly reviewing press reports, the Anti-Slavery Commissioner website, and publications from the Gangmasters and Labour Abuse Authority (GLAA) and Human Rights charities
- Completing internal investigations where potential areas of risk are identified within the supply chain. More information can be found in the ‘Our effectiveness in combatting modern slavery and human trafficking’ section below.
We have assessed our modern slavery risk as low based on the following:
- Our office locations being entirely UK-based
- Our employees are generally skilled professionals
- Our employees are largely directly employed by Zenith
- All employees are subject to pre-employment screening checks covering their right to work in the UK, and reference checks
- We have minimal use of temporary or agency employment
- Regular internal training and communications to increase awareness of modern slavery and whistleblowing
- Suppliers are subject to our pre-contractual due diligence processes covering modern slavery and ongoing monitoring.
We perceive our greatest exposure to risk (albeit limited) is further down our supply chains – for example where the sourcing of raw materials used in the production of vehicles occurs in countries with weak labour standards. We continue to take steps as an organisation to understand the suppliers further down our supply chain. This process is being co-ordinated by our supplier governance and risk forum.
Our due diligence processes
Our supply-chain due diligence processes are proportionate to the level of assessed risk and the level of control or influence we have in each relationship.
Where we take on a new supplier to our business, we require them to respond to our pre-contractual due diligence questionnaire. The questionnaire specifically addresses slavery and human trafficking. The questionnaire must be completed prior to contract award and services being provided by the supplier to Zenith.
The completed questionnaire is reviewed by our subject matter experts in the Supplier Governance and Risk Forum. Any identified risks are managed by the supplier owner with support and guidance offered by Compliance, Legal and Information Security teams where appropriate.
All new suppliers are required to agree to our Code of Conduct. Any supplier issues that sit outside of our risk appetite may result in Zenith not engaging further with them. For existing suppliers, it may result in a termination of supply, reduced volume of business or non-inclusion in future tender opportunities.
Our review processes for existing suppliers is determined by how we have categorised the suppliers as defined above; business critical, dependent, medium or low. All business-critical suppliers are reviewed annually. The review process and frequency for all other supplier categorisations is determined by a range of factors such as the products and services they offer and any risks that they present, amongst other things.
Where areas of risk have been highlighted within our supply chain, we complete enhanced due diligence. We have reported on our enhanced due diligence processes in previous statements. Examples include an analysis of hand car washes, waste management suppliers and vehicle manufacturers following the mica scandal.
We deliver annual Modern Slavery training sessions to key stakeholders across the business. Key stakeholders are defined as employees that have a significant supplier relationship, or employees working in departments with suppliers in higher risk industries.
The sessions are delivered by Group Compliance in a workshop environment and include:
- Insight into Modern Slavery legislation;
- Zenith’s obligations in relation to Modern Slavery;
- Developments regarding criminal investigations and prosecutions within the UK;
- Overview of our existing risk assessment;
- Discussion on any new risks and steps to mitigate those risks.
Our colleagues also receive regular training and communications on whistleblowing and have access to a third-party hotline. This training raises awareness of eligible concerns that can be reported to this hotline, including actual or suspected instances of modern slavery.
Understanding of modern slavery is assessed through a learning management system that sends daily questions to colleagues. Whistleblowing is also included in the question library. The tool measures knowledge and reports against KPIs.
Our effectiveness in combating slavery and human trafficking
1. Zenith’s operations
We have the following controls in place to ensure that modern slavery is not present within our own operations:
- Pre-employment screening – of all employees including right to work checks
- Annual training for stakeholders – over the next 12 months, in addition to the workshop training, we intend to launch computer-based training on modern slavery to colleagues
- Independent third-party whistleblowing hotline – colleagues can report instances of modern slavery to HR directly, their manager or through an independent third-party hotline.
2. Our supply chain
As stated in previous statements, the two main sectors of potential concern within Zenith group’s supply chain are:
- Hand car washes within Zenith car and van supply chain
- Recycling/waste disposal within the full business supply chain
To mitigate this risk our suppliers are contractually required to valet all vehicles on site and should not utilise independent hand car washes. We complete ongoing monitoring of these suppliers to ensure that they continue to complete vehicle valeting on-site.
In our 2020 statement, we highlighted cobalt mining as a growing modern slavery risk for the automotive industry. This risk continues to increase as demand for electric vehicles grows. We have engaged with our vehicle manufacturers on this matter, in addition to completing our own investigation into their human rights and supply chain controls. We are comfortable that our vehicle manufacturers controls and procedures are effective to ensure that modern slavery is not present within their supply chain, that they are sourcing cobalt ethically and not from illegal mines.
Many manufacturers are also members of the Global Battery Initiative and Fair Cobalt Alliance, for example Tesla. However, we remain vigilant to the risk associated with cobalt mining, especially as the demand for electric vehicles grows. We will continue to review this by working collaboratively with our vehicle manufacturers and regularly reviewing this risk.
Zenith’s Supplier Governance and Risk Forum continues to operate. The forum’s membership, responsibilities and powers are documented in a Terms of Reference which is approved by the forum. Any investigations, such as those into hand car washes, mica paint or cobalt mining are tracked through this forum. The forum monitors regulatory change that impacts our supply chain including modern slavery. Any actions required will be managed by the forum.
Suppliers, customers and third parties that we engage with can report instances of modern slavery to Zenith directly or their relationship manager.
3. 2022 and beyond
In 2022, we intend to take the following steps to tackle slavery and human trafficking:
- Refresh our risk assessment with formal workshops involving key stakeholders from our people team, procurement and colleagues with supplier management responsibilities
- Launch an anti-slavery and human trafficking policy
- Launch computer-based training on modern slavery through our learning management system (LMS)
- Assess understanding of modern slavery including awareness of our reporting procedures via a daily learning tool.
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.
Chief Financial Officer
*This statement covers the period August 2020 to the end of March 2022 to align with the end of our financial year.