Unipart Modern Slavery and Human Trafficking Statement for the financial year ended 31 December 2020 made pursuant to the Modern Slavery Act 2015
Unipart is a leading provider of manufacturing, logistics and consultancy services. We are a diverse organisation with a range of operations both in the UK and overseas with a common approach that we call “The Unipart Way”.
Corporate responsibility at Unipart is ingrained in our culture and is woven into the philosophy and values that are at the heart of our organisation and underpin everything that Unipart does.
Our booklet “Conducting Business the Unipart Way” sets out the principles which apply across the organisation and incorporate the core principles set out in the Universal Declaration of Human Rights. A copy of this booklet is provided to all our employees and published on the corporate website. We apply these principles to all our stakeholders including our suppliers.
Unipart Policy on Modern Slavery and Human Trafficking
Unipart is committed to conducting business transparently, honestly, openly and fairly. We seek to operate responsibly wherever we work in the world and to engage with our stakeholders to manage the social, environmental and ethical impact of our activities in the different markets in which we operate.
It is the policy of Unipart that each company within the Unipart Group and each director, officer and employee of any Group company complies in all respects with all applicable UK laws, and (in addition and where relevant) local laws of overseas countries, standards and principles relating to modern slavery in each of the jurisdictions in which a Unipart company trades, operates or has any other activity. Companies within the Group must establish and enforce effective compliance procedures including in their supply chains.
Due Diligence in Supply Chains
Unipart’s standard terms and conditions set out the requirements for suppliers to not engage in any modern slavery practice, and to comply with Unipart’s policies in respect of such, including the requirement for suppliers to conduct proper and detailed checks of any agency or person used by the supplier, and an obligation for the supplier to notify Unipart immediately of any actual or suspected non-compliance.
Targeted due diligence is deployed by Unipart following a risk assessment of suppliers based on a number of factors including geographic location, business sector, type of product or service supplied. Unipart reserves its right to conduct supplier audits and access supplier premises and records to fulfil its due diligence.
Providers of agency workers and other sub-contracted people are identified as having a higher inherent risk of non-compliance with Unipart’s Modern Slavery and Human Trafficking policy. As a consequence, suppliers that provide agency staff to Unipart are subject to regular compliance audits that include a review of the steps taken by the supplier to avoid modern slavery and human trafficking.
Recruitment Practices
Unipart is committed to respecting fundamental human rights in all its activities. Recruitment processes for direct employees are designed to ensure that no employees are at risk of modern slavery or human trafficking. For example, in the UK, Unipart confirms the identities of all new employees and their right to work, and pays its employees at least the National Living Wage.
Effectiveness
Unipart adopts a zero tolerance approach to non-compliance with its Modern Slavery and Human Trafficking policy. Any breach of this policy would be regarded as a serious matter and is likely to result in disciplinary action, dismissal, or, in the case of suppliers, termination of trading relationship.
Unipart reviews all internal processes for effectiveness and during 2020 introduced a number of enhancements. These include additional training to all of its managers that engage with suppliers and to all new employees to supplement the ongoing training set out below for existing employees in Procurement and Human Resources functions. Unipart introduced a confidential text service available to all employees to support Unipart’s existing Whistleblowing policy and procedures, maximising the opportunities for all colleagues to access the support and help they need if they suspect any form of wrongdoing.
Training
All new employees in positions of management and leadership as well as all new employees into Human Resources and Procurement are required to complete mandatory training on the prevention of modern slavery and human trafficking. Training focuses on identifying the signs and risks of modern slavery and human trafficking, and gives guidance on how to manage compliance with the Group’s policy throughout its supply chain. This training is repeated at regular intervals to ensure that knowledge is kept up to date. All employees are made aware of the Group’s policy and Unipart encourages all employees to report any concerns they may have regarding modern slavery and human trafficking either to their line manager or in accordance with the Whistleblowing policy.
This Statement was approved by the Board of Unipart Group of Companies Limited and signed by the Chairman on 30 June 2021. It covers all operating businesses and divisions of Unipart, details of which can be found at www.unipart.com.
John M Neill
Chairman and Group Chief Executive
Unipart Group of Companies
30 June 2021