MJT Securities Limited and its subsidiary companies (the “Group”) comprise of Motor Dealerships, Vehicle Leasing, Property holding and development and exporters. The size of the companies and nature of the business mean that the turnover of its subsidiary companies can vary from year to year, taking them above and below the threshold. For that reason the Group makes this modern slavery statement on behalf of all of the Group subsidiary companies, all of whom adopt its terms.
The actions mentioned in this statement are undertaken at parent company and subsidiary level as appropriate to the action.
Organisation Structure and Supply Chains
The Group operates through autonomous divisions and operating companies all reporting to the Group Board of Directors.
A predominance of our goods and services are UK sourced, however, the Board recognise that our supplier’s might source from abroad, and that Unit Export Limited in particular look globally for products. For this reason the Group’s supply chain is geographically diverse and includes some countries where there is a risk of modern slavery and child labour.
The Group’s trade in automobiles and associated parts, whilst bought from UK companies might have parts originating from abroad. As a result the Group can be often several steps removed from the procurement of goods, which increases the risks.
The Group’s sub-contractors supply their own labour, some of which is presently from other countries. There is a risk that some foreign labour could have been trafficked, despite the due diligence the Group applies in appointing such contractors.
Policies on modern slavery
The Group has a dedicated Modern Slavery Policy which is applicable to all of the Group’s employees and companies. The Modern Slavery Policy is owned by the Board of Directors and reviewed on an annual basis.
The Group’s Whistle Blowing Policy and procedure is published in the Company Handbook available to all employees. It has been open to staff and third parties to report any suspected unlawful behaviour, breach of Group policies or any other matters that fall below established standards or practice. In 2019, the Group updated it’s Whistle Blowing Policy to make explicit reference to modern slavery, acknowledging its importance.
Due Diligence Process and Risk Assessment
The Group has a long history of sourcing materials and products setting the standards it requires its subcontractors to meet. This in itself, however, is not sufficient to give the Group comfort that its supply chain is free from modern slavery.
Group tenders are awarded on a best value basis. This ensures that other factors such as the long term value of suitability and health and safely are as important in awarding tenders as price.
The Group has considered the risk profile of our business and our business partners. We comply, and will continue to comply with the highest professional standards. Any business partners, whether they be subcontractors or suppliers with our business must therefore adhere to these very high standards.
Going forward we will insist that all of our suppliers and contractors comply with our values.
In addition to the above, the Group has reviewed all of its current suppliers and business partners to assess potential risk areas. We are not aware of any breaches or cause for concern. We will continue to review this on a periodic basis.
The Group will know the effectiveness of the steps that it is taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices related to the Group or its supply chain have been identified;
- Any adverse media reports for suppliers in high risk areas identified as part of the supplier due diligence process are fully investigated to ensure that there is no modern slavery or human trafficking taking place or an alternative supplier has been used; and
- To ensure that all employees have read the new policy on an annual basis. This will be automated from April 2019 with the introduction of the new HR software.
It should be noted that during 2018 no negative indicators were reported.
Training for all staff
The Group Policy on modern slavery is to be communicated with all staff through a memo and will be available in the Group’s HR system for all employees to review.
The Group also has a set of values, published in the Employee Handbook. These are regularly reviewed and all staff are appraised against them as part of their annual review. This affects their overall rating, which can impact any promotion prospects or annual bonuses if applicable. Poor scores in these areas may result in a capability review.
This statement is made pursuant to section54(1) of the Modern Slavery Act 2015 and constitutes the Group’s slavery and human trafficking statement for the financial year ending 31 December 2020.
For more information about Modern Slavery, click here