ANTI SLAVERY AND HUMAN TRAFFICKING STATEMENT

BOLTON CAR CENTRE LIMITED

The Modern Slavery Act 2015 (MSA 2015) focuses specifically on the issue of modern slavery to ensure offenders are suitably reprimanded with severe sentences. Modern slavery encompasses the offences of: ‘slavery’ where ownership is exercised over a person; ‘servitude’ which involves the obligation to provide service imposed by coercion; ‘forced or compulsory labour’ involves work or service exacted from any person under the menace of a penalty and for which the person has not offered themselves voluntarily; and ‘human trafficking’ concerns arranging or facilitating the travel of another with a view to exploiting them.

The MSA 2015 requires large businesses, with sales of over 36 million, to be transparent about their efforts to eradicate Slavery and Human Trafficking. This statement, therefore, explains the steps we have taken during the financial year to ensure that slavery and human trafficking is not taking place in any of our supply chains or any part of our business.

The Company operates new and used franchised motor retail dealerships and service centres across Bolton, Bury and Blackburn. Our principal activities concern the sale and servicing of automobiles.

We currently represent 3 vehicle manufacturers and operate from 3 dealerships. The Company currently employs approximately 60 people.

All Bolton Car Centre Limited employees are provided with full details of our code of conduct, whistleblowing policy and other Company policies, including this statement. These can be accessed by third parties on request, simply contact BCC Head Office (Higher Bridge Street, Bolton BL12HF) for a copy. Our policies are reviewed annually by the Company’s Human Resources department to ensure we remain compliant.

It is the Company’s policy that all employees must comply with the highest standards of business and ethical conduct in all dealings with customers, suppliers and the wider community.

As part of the Company’s induction process and throughout workers’ employment with us, we train all staff to treat others with respect and courtesy as well as ensuring they adhere to all relevant laws, regulations and standards. This is an ongoing due diligence process. We focus on ensuring our management team is not only aware of the requirements to be alert to modern slavery but can also address concerns raised by their team or any suppliers. If any worker is found in breach of our policies, we ensure suitable disciplinary action is taken which can include termination.

The principal areas in which there is a risk of human trafficking and slavery are those related to our supply chains. The Company operates in partnership with three global motor franchise partners as an authorised franchisee.

In relation to our supply chains, we use our reasonable endeavours to conduct risk assessments of the third parties we work with and investigate, where feasible, the working conditions of their workers.

The Company is committed to taking steps where reasonably practicable to ensure that modern slavery is not taking place in any part of its own business or in any of its supply chains. We aim to work with our colleagues and suppliers to ensure collaboration to remedy or mitigate such risks.

Our main protection against slavery is to ensure that all business activity complies with minimum wage legislation. We also require this of all contractors engaged with our business. We ensure all individuals have the right to work in the UK and that UK contractors only employ staff with the right to work in the UK.

We allow all individuals who work or provide services to us the right to freely choose employment and the right to associate freely with other individuals. Workers are free to choose whether to join a trade union or not and we offer an environment which is free from harassment and unlawful discrimination. We ensure our working practices are in accordance with the Equality Act 2010 and all employment legislation. We do not engage in forced or involuntary labour and have a zero-tolerance approach to the same, meaning we do not tolerate any of our suppliers engaging in such conduct. We require suppliers to certify that they do not participate in any forced or involuntary labour with their workers, subcontractors, agents or associates.

We aim to ensure that our performance indicators do not put pressure on or influence any modern slavery risk.

Bolton Car Centre Limited will only trade with those who fully comply with this statement or those who are taking steps towards full compliance.

This policy has been approved by the Company Director who will review and update as necessary on an annual basis.

For and on behalf of Bolton Car Centre Limited

JUNE 2021