Modern Slavery Statement
This Statement details the steps we have taken towards ensuring that slavery and human trafficking are not taking place either in our organisation or our supply chain. FleetEurope has a long-standing commitment to conducting business ethically and the prevention of slavery and human trafficking is an important part of that commitment.
Following the risk assessment which is detailed later in this Statement, we have assessed our exposure to the risk of slavery and human trafficking as low.
FleetEurope is a leading independent leasing, vehicle outsourcing and fleet management provider.
Our supply chain
We have categorised our supply chain into four groups:
- Core in-life
- Wider network
- Large corporate
- Non-direct / ad hoc
This policy supports our commitment to limiting the risk of modern slavery occurring within our own business or infiltrating our supply chains or any other business relationship
The policy applies to all persons working for or on our behalf in any capacity, including employees, directors, officers, agency workers, contractors, consultants, volunteers, interns and any other third party representative.
We expect all who have, or seek to have a business relationship with the Company to familiarise themselves with this policy and to act at all times in a way that is consistent with its values
Our commitment is underpinned by the following:
- Zero tolerance approach, reinforced by the staff handbook and staff training
- A procurement policy incorporating pre-contractual supplier due diligence
- Regular risk assessments
- Whistleblowing procedures
We also have a Supplier Code of Conduct (“SCC”) which communicates our ethical approach to doing business to our suppliers, including slavery and human trafficking. The SCC requires our suppliers to have in place effective policies and procedures which reflect similar ethical commitments and to cascade this down their own supply chain. Any violations must be reported to FleetEurope and failure to adhere to the SCC may result in a termination of supply, reduced volume of business or non-inclusion in future tender opportunities.
Our approach to assessing and managing risk
We assess risk in our supply chain through consultations with relevant internal stakeholders. Risk factors include: the location of the supplier, the nature / type of the goods or services provided, the level of control we have over the supplier, the levels of corporate governance demonstrated by the supplier and the supplier’s own supply chain.
Following this consultation process we have assessed our exposure to the risk of slavery and human trafficking as low for the following reasons:
- We are entirely UK based.
- Almost all of our direct suppliers have strong levels of corporate governance and are based in countries where slavery and human trafficking are low risk.
- We perceive our greatest exposure to risk (albeit still limited) is further down our supply chains – broadly where workers receive low pay for low skill work, or where raw materials and manufacturing originate in high risk countries. Activities further down our supply chain are out of our direct control. As such we have focussed our efforts on our direct suppliers, most of which are UK-based and therefore obliged to comply with the Modern Slavery Act as well.
- We believe that our anti-slavery and human trafficking strategy described in this Statement is proportionate to the risks we face in our business and supply chain and any risks are mitigated by existing and new policies, procedures, training and diligent procurement processes.
Our due diligence processes
Our supply-chain due diligence processes are proportionate to the level of assessed risk and the level of control or influence we have in each relationship.
Where we take on a new supplier we require them to respond to our pre-contractual due diligence questionnaire which specifically addresses slavery and human trafficking. All new suppliers are also required to agree to our SCC.
Our SCC has been launched initially across the core in-life suppliers which represent the vast majority of our supply-chain on renewal of their current contracts. Subsequently we will look to launch the Code, where possible, across the large corporate and non-direct / ad hoc supplier groups when their contracts are renewed. We will also aim to conduct monitoring and audit of target suppliers to ensure compliance with the SCC.
All new starters are issued with the Staff Handbook which includes a reinforced commitment to anti-slavery alongside the policy commitment in the Environmental & Corporate Social Responsibility Policy.
Our effectiveness in combating slavery and human trafficking
We track various metrics throughout the course of the year and report on these in our subsequent Statement.
This Statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and has been approved by FleetEurope’s Board of Directors.