Modern Slavery Statement
Modern Slavery Statement for the Financial Year 2019/20
This statement is made in pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Car Benefit Holdings Limited (CBH) and all Group Companies have taken, will take and is continuing to take to ensure that modern slavery or human trafficking is not taking place within all businesses within our business operations throughout the entire CBH Group or within our supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. CBH Group has a zero tolerance approach to any form of modern slavery or human trafficking. We are committed to acting ethically and with integrity and transparency in all business activities and to putting effective systems and controls in place to safeguard against any form of modern slavery or human trafficking taking place within CBH or our supply chain.
Definitions of “Group Companies”
Car Benefit Holdings Limited – a non-trading parent company which holds 100% of the shares in all Group subsidiaries as detailed below.
Car Benefit Solutions Limited – holds all intellectual property vested in the Group and provides consultancy and management services to employer clients.
Car Benefit Finance Limited – provides Employee Car Ownership Scheme (ECOS) solutions to UK Corporate Sector clients. The company provides a complete turnkey solution inclusive of funding, taking residual value and maintenance risk and providing all employee services.
Car Benefit Loans Limited – provides client employee interest free loans associated with ECOS solutions operated through Car Benefit Finance Limited.
Car Benefit Car Schemes Limited – provides ECOS solutions to the UK Automotive Sector.
Car Benefit Schemes LLP – provides consultancy and management services to employer clients.
Car Benefit Energy Finance Limited – provided an Employee Car Ownership Scheme (ECOS) solution for a dedicated Corporate Sector client.
Collectively the Group Companies are referred to as “CBH Group”.
Business Activity Summary
- CBH Group, under its trading style of Car Benefit Solutions (CBS), is the leading provider of Employee Car Ownership Schemes in the UK, delivering turn-key solutions from scheme design through to implementation, funding and scheme operation and was established in 2002.
- The first scheme was launched in February 2003 within a few years the company was a partner of choice to some of the UK’s biggest blue chip clients.
- In 2007 a premium automotive manufacturer approached CBS looking for an ECOS solution, and the first Manufacturer Sponsored ECOS facilitated by CBS was implemented.
- Today, CBS operates schemes for over 25 manufacturer brands at over 2000 UK dealerships; delivering almost 30,000 annual registrations to the Automotive sector.
Our mission is
To create the most intelligent and value adding Employee Car Ownership Schemes and deliver them to our customers
with ease and simplicity.
Through our desire to develop and share our knowledge and expertise
Through our willingness to adapt and evolve to meet our customer’s needs
Through our commitment to our values
Our core values are
We work hard and with passion to make a difference, to achieve our goals, to be the best, so that we are always proud of ourselves, our team, and of CBS.
We do things in the right way, to build trust in each other, to reward the support and loyalty shown by others, because we are a team and because we care.
We strive for excellence and we challenge ourselves to always ask questions, to listen to others and to seek out new ideas so that we may learn, improve and evolve.
We willingly take on our responsibilities and are committed to owning the challenges that we face and seizing the opportunities that present themselves.
We come together to enjoy our work and enjoy being part of a team so that together we make the journey a fun one.
We will conduct due diligence across our supply chain including Motor Manufacturers, Dealer Groups, Corporate Clients, Banks, Funders and Suppliers to ensure they comply with their legal obligations.
We foster long standing relationships where possible with our suppliers and we will aim to receive confirmation from all our suppliers that they:
- Have taken steps to eradicate modern slavery and human trafficking within their business
- Hold their own suppliers to account over modern slavery and human trafficking
- Pay their employees at least the National Minimum Wage or the National Living Wage as appropriate (UK based suppliers)
- Pay their employees any prevailing minimum wage applicable within their country of operation (international suppliers)
We reserve the right to request the termination of a contract with a supplier at any time should instances of modern slavery or human trafficking come to light.
We have implemented and communicated several internal policies to ensure that we are conducting our business in an ethical and transparent manner, with special emphasis on slavery and human trafficking, and these include:
- Modern Slavery Policy
- Recruitment Policy
- Whistleblowing Policy
- Anti-Bribery and Corruption Policy
- Anti-Money Laundering Policy
- CBS Code of Conduct
- Compliance Breach Policy
- Vulnerable Customer Policy
We continue to provide access for staff to an Employee Assistance Programme for free advice and counselling on a range of issues including if they are subject to or witness any evidence of modern slavery or human trafficking be evident.
Over the next 12 months we will continue to evolve, strengthen and review our approach to managing the risk of modern slavery or human trafficking within our business and supply chains. We will build on the positive actions taken over the last 12 months with regards to training, risk assessment and awareness and will continue to take action in the following areas:
- Training of new staff to build awareness of the policy and associated processes
- Provide refresher training for existing staff through the Learning Management System including the creation of an online course for Anti-Slavery Day for all employees to complete
- Contact our suppliers for their policies relating to Modern Slavery and Human Trafficking
- Conduct an assessment of our suppliers in terms of their country or origin and industry to identify any high risk issues
- Ensure we keep abreast of any development within modern slavery and human trafficking
- Continue to embed our core values and our customer centricity values to continue to operate ethically and transparently
- Educate and support in relation to modern slavery and human trafficking through the work of our newly appointment equality champions and the work they are doing on diversity and inclusion
Our Board Approval
This statement has been approved by the Board of the Directors of Car Benefit Holdings Limited and will be updated annually in accordance within the requirements of the Modern Slavery Act 2015.
Modern Slavery & Human Trafficking Policy
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. We have 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 effective systems and controls to ensure modern slavery is not taking place anywhere throughout CBH or in any of our supply chains.
We are also committed to ensuring there is transparency in all CBH businesses and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
Responsibility for the Policy
The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Head of People, Culture & Values has primary and day to day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and will work with relevant colleagues relating to the auditing of internal control systems and procedures to ensure they are effective in countering modern slavery.
The Management Board and Management Team at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Head of People, Culture & Values.
Compliance with the Policy
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of the business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your manager or the Head of People, Culture & Values as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the business or supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the compliance officer.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
Communication and Awareness of the Policy
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
Our zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. This will also be contained on our website.
Breaches of this Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
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