MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
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.
Reflex Vehicle Hire Limited welcomed the introduction of the Modern Slavery Act 2015 and has a zero-tolerance approach to modern slavery. 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 in our own business or in any of our supply chains.
We are also committed to ensuring that we operate with transparency in our business 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 our suppliers, contractors and business partners and we expect that our suppliers will hold their suppliers to the same high standards.
This Statement takes into account the introduction of various measures throughout our supply chain management from 2020 onwards, with the aim of reducing the risk of slavery and trafficking activities being present within our business operations.
We look forward to working with our partners, contractors and suppliers to achieve these aims, both immediately and in the future to combat slavery and human trafficking.
2. Organisational structure and business
This statement covers the activities of Reflex Vehicle Hire Limited:
Reflex Vehicle Hire Limited is a vehicle rental Company that supplies a flexible commercial fleet within the UK. The Company provides fully equipped vehicles and also carries out vehicle tracking with the help of telematics, on-board cameras, driver fatigue monitors and driver profiling technology. It has an annual turnover of in excess of £38m. The organisation employs around 100 people.
3. Supply Chain
3.1. Supplier management:
We aim to foster long term relationships with suppliers we can trust, that understand our expectations and whom we can communicate with candidly. We favour new and existing suppliers who can demonstrate good practice and a commitment to combatting modern slavery. We require all new suppliers to complete a due diligence questionnaire which aids our assessment of whether prospective suppliers are suitably well governed.
Our supply chains include:
• Consultants and advisers
• Contractors and Subcontractors
• Suppliers of goods, supplies and materials for all stages of the vehicle rental cycle
We have had comprehensive anti-slavery and human trafficking contractual clauses prepared which will place strict contractual obligations on suppliers and allow us greater control and monitoring rights. We intend to insert these contractual clauses into all new supplier agreements that are deemed to present an increased risk of modern slavery.
We require all suppliers and contractors to confirm that they have in place their own equivalent anti slavery and human trafficking policies to at least the same standard as our own and to provide us with a copy of such. In doing so, we require suppliers to agree that they will not:
• use child labour
• allow inhumane treatment of their workforce
• practice discrimination; or
• allow or encourage working of excessive hours
In the event that our suppliers do not comply with our policies or their own policies, we reserve the right to terminate our relationship with them. However, if we became aware of slavery or human trafficking in our supply chain, we would alert the appropriate authorities and then take one of the following courses of action:
In the first instance, if appropriate and at all possible, we will seek to work with local NGO's (non-government organisation) and use our influence with the suppliers in question to improve conditions for the victims so that they are legitimately engaged in gainful employment. Improvements would be subject to strict proof and required with prompt deadlines.
In the event that the above clause is not possible, we will terminate our relationship with the supplier in question.
3.2. Countries of operation and supply
The organisation operates in the United Kingdom only.
3.3. Supplier risk analysis
We have analysed the risk profile of our Tier 1 suppliers by considering the countries where they are based and the products and services that they deliver. Recognised external data suggests the overall risk of modern slavery and human trafficking in tier 1 of our supply chain is low. If potentially higher risk suppliers are identified, we will seek assurances of good practice from them and place additional focus on applying the systems of control and monitoring referred to above.
Our main purchases, in volume and costs, are of vehicles (cars and vans), and vehicle parts and related products. As mentioned, we favour reputable manufacturers/suppliers of these products and at present we are satisfied that all have strong anti-slavery and human trafficking positions and are taking appropriate action to combat modern slavery in their own supply chains.
4. Our people
The personnel responsible for compliance with this Statement and the Anti-Slavery Policy, and for updating and improving our procedures in the forthcoming years, shall consist of involvement from the following departments:
• Board of Directors and Senior Leadership Team
• Human Resources
• Health and Safety
This Statement and the Anti-Slavery Policy will be subject to regular and ongoing reviews (at least annually) to ensure its effectiveness, and to update the requirements where further measures are identified.
It is our policy to conduct "right to work" checks on all direct employees prior to them commencing their roles with us. This includes checking that all staff recruited are of an appropriate age for employment and are eligible to live and work in the country of employment.
4.2. Relevant policies
This modern slavery statement sits alongside our Whistleblowing and Equal Opportunities policies. We regularly review and, as appropriate, update all policies.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will be implementing training for all of our staff, highlighting the requirements of the Act and our Anti-Slavery policy and its practical application in the workplace.
This training will be subject to refresher sessions as appropriate.
4.4. Awareness-raising Programme
As well as training staff, the organisation has raised awareness of modern slavery issues by circulating an email to staff that explains:
• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking;
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
• what external help is available, for example through the Modern Slavery Helpline.
4.5. Risk Analysis
As mentioned in section 2, we directly employ over 100 people in the UK.
Also working in the business is a casual labour force of around 40 people, who assist with services such as cleaning or car washing and it is deemed that this group are most at risk. We aim to be diligent across the board but ask our staff and particularly managers involved within these areas to be especially vigilant.
Notwithstanding the above paragraph, having considered the location of our operations and the roles being performed, we currently deem the overall risk of slavery and human trafficking existing within our direct employee population, or our agency and contract staff population to be low.
Nonetheless, we appreciate that risks exist for all businesses in all jurisdictions and that businesses have an obligation to minimise opportunities for those who look to exploit others for their own personal or financial gain.
5. Statement update
Our approach to combatting modern slavery in our business and in our supply-chain is continually evolving. We are committed to making progress and increasing and improving the effectiveness of our efforts year on year.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and was last updated for the financial year ending 31st December 2020.
Chairman & Managing Director Reflex Vehicle Hire Limited
1st March 2022