Introduction
This statement has been published in accordance with section 54(1) of the UK Modern Slavery Act 2015 (the Act). It sets out the steps that Unipart has taken during the financial year ended 31 December 2023 to prevent slavery, servitude, forced labour and human trafficking (together known as modern slavery) in our business and our supply chain.
This statement constitutes the Modern Slavery Transparency Statement for Unipart Group of Companies Limited and all its subsidiaries (referred to as Unipart), including the following UK subsidiaries which are required to publish a statement under the Act:
- Unipart Group Limited;
- Unipart Logistics Limited; and
- Unipart Rail Limited.
At Unipart, we are committed to upholding high ethical standards and acting with integrity wherever we operate. This commitment includes a respect of fundamental human rights and a zero-tolerance approach to modern slavery. We expect everyone acting on our behalf, as well as businesses across our supply chain, to adhere to the same standards.
Unipart Commitments
As a business, Unipart’s commitments are as follows:
- to comply with all relevant applicable modern slavery and human trafficking related laws in the countries in which we operate;
- to provide clear and accessible training to our employees on identifying the risks of modern slavery and human trafficking, and to provide a safe whistleblowing procedure for anonymous reporting of concerns;
- to carry out due diligence on and define clear expectations for those who we work with;
- to take a risk-based approach to our contracting processes and keep them under review, ensuring appropriate and proportionate provisions are included in contracts which prohibit modern slavery and human trafficking.
- to consistently and continually engage with our stakeholders and suppliers to assess the risk of modern slavery in our business and our supply chain.
Our Business and Supply Chain
Unipart is a leading provider of supply chain solutions and performance improvement technologies, providing products and services to the automotive, rail and public transport, technology, healthcare, aerospace and defence, consumer, retail and e-comm and industrial sectors.
Our Group philosophy is to understand the real and perceived needs of our customers better than anyone else and to serve them better than anyone else. We do this by delivering exceptional levels of service through the engagement and empowerment of our more than 12,000 colleagues across our operations in more than 20 countries worldwide. We achieve this through a common approach that we call The Unipart Way, through which we continuously review performance, identify improvements and make positive changes for our customers.
Corporate and social responsibility at Unipart is ingrained in our culture. We have a firm commitment to doing well by doing good, and believe that our customers, our people, our industry partners and the communities in which we operate are best served when all of our long-term prosperity and sustainability is intertwined. This belief has been at the heart of our ethos for more than three decades, and is embedded in everything we do.
Relevant Policies and Controls
Unipart is committed to conducting business fairly, transparently, honestly and openly. 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.
Our approach is underpinned by an established framework of policies, procedures and standards which cover human rights in general as well as minimising the risk of slavery or human trafficking occurring within our business or our supply chains.
Our Modern Slavery Policy sets out the responsibilities of those working for and on our behalf in upholding our zero-tolerance approach to modern slavery. Any breach of the 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 our trading relationship.
Our Human Rights Policy sets out our commitment to respecting fundamental human rights in all our activities.
Our Whistleblowing Policy enables colleagues to report any concerns, including those related to modern slavery and any other human rights violations, through our independent and confidential whistleblowing hotline and web-based reporting system. Reports can be made anonymously if desired in local language. All reports are reviewed and, where necessary, investigated. There were no reports relating to modern slavery made via our whistleblowing arrangements in the financial year ended 31 December 2023.
Conducting Business The Unipart Way sets out the ways in which we seek to be a responsible, ethical and supportive business and to earn, and retain, the trust and confidence of our many stakeholders. It incorporates the core principles set out in the Universal Declaration of Human Rights and our approach to modern slavery. The document is applicable to everyone who has an interest in Unipart: our customers, our suppliers, our people and other stakeholders.
The above policies, procedures and standards are published on Unipart’s intranet for colleagues to refer to and are subject to regular review.
Training and Employee Awareness
In accordance with our Compliance Policy, all Unipart colleagues in HR, Finance, Sales and Procurement, as well as those appointed to management and leadership roles, are required to complete mandatory training on the prevention of modern slavery, on joining Unipart. This training focuses on identifying the signs and risks of modern slavery and gives guidance on how to manage compliance with Unipart’s Modern Slavery Policy throughout the supply chain. Colleagues undertake refresher training at regular intervals to ensure continuing awareness of modern slavery and its prevention. All colleagues are made aware of Unipart’s policy and are encouraged to report any concerns they may have regarding modern slavery to their line manager or in accordance with our Whistleblowing Policy.
Risk of Modern Slavery in Operations
We continue to deem the risk of modern slavery occurring within our direct employee population to be low. Our recruitment practices for direct employees are designed to ensure that no colleagues are at risk of modern slavery: in the UK, for example, we confirm the identities of all new employees and their right to work, and pay our colleagues at least the National Living Wage directly into a bank account in their name.
We have identified that providers of agency workers and other sub-contracted individuals have a higher inherent risk of modern slavery and/or non-compliance with our Modern Slavery Policy. As a consequence, suppliers that provide agency staff to Unipart are subject to prior due diligence and regular compliance audits that include a review of the steps taken by them to avoid modern slavery.
Risk Assessment and Due Diligence in Our Supply Chain
During our supplier onboarding process, we assess our supply chain for potential areas of risk of non-compliance with the Modern Slavery Act 2015 by carrying out targeted due diligence following a risk assessment based on a number of factors, including geographic location, business sector and type of product or service supplied. We reserve a right to conduct supplier audits and access supplier premises and/or records as part of our due diligence process. Our procurement teams are responsible for carrying out these audits to ensure that our suppliers are responsible partners.
Our standard terms and conditions require that our suppliers (a) do not engage in any modern slavery practices; and (b) comply with our policies in respect of such, including the requirement to conduct proper and detailed checks of any agency or person used by the supplier. They also put an obligation on the supplier to notify us immediately of any actual or suspected non-compliance.
Continuous Improvement
We remain committed to continuously improving what we do and strengthening our approach to manage and reduce the risk of modern slavery within our business and supply chains. In 2024 we will continue to review our Modern Slavery and related policies and procedures and seek to identify additional improvements which will further enhance our processes and controls.
This statement was approved by the Board of Unipart Group of Companies Limited on 28 March 2024.
Darren Leigh
Group Chief Executive
28 March 2024
Our 2022 and 2021 modern slavery transparency statements can be viewed here and here.