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Modern Slavery Act 2015

Cathedral Motor Company, trading as Arbury Motor Group, believes it is our responsibility to uphold the highest standards of ethical behaviour and personal integrity within our business operations. Wherever we do business, our employees are required to comply with all applicable laws, rules and regulations.

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. Arbury Motor Group has a zero-tolerance approach to modern slavery, and is fully committed to preventing slavery and human trafficking in our operations and supply chain. As a company, we are committed to protecting our organisation and those people at risk from exposure to slavery or human trafficking in our supply chain, both via our direct employees and those working on our behalf via third-party suppliers.

Organisational Structure and Background

Arbury Group are a diverse dealership franchise based in Bromsgrove, England, which offers a selection of car manufacturers in six locations across the Midlands. Throughout the organisation, we are proud to maintain a strong family ethos. The success we have built over the years is due to our team members’ hard work, delivering a premium service to every customer that steps through our doors. Each employee is highly trained, enthusiastic and knowledgeable about the range of vehicles we provide.

Our Employees

Each of our employees is provided with a written contract of employment, as well as being given access to a company handbook, which contains any policy that governs their employment. It is their personal responsibility to read the handbook and ensure they are fully aware of our obligations and the consequences associated with any breach of these. Our integrity is a crucial element for our organisation – it determines all that we do, as well as how we relate to each other and our customers.

A fundamental policy for Arbury Group is to conduct all our business with honesty and integrity, and to the highest standards of ethics, equality and fair dealing. Our employees play a significant role in maintaining these standards and ensuring we are compliant in all aspects of the regulations set out by the UK government.

To support our employees in maintaining these standards, we provide a confidential whistleblowing helpline that enables our employees to report any concerns related to their direct activities, or the supply chain of our organisation. This includes any circumstances that may enhance the risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for our employees to make a disclosure, without fear of retaliation. Any report submitted is reviewed by the most senior directors of Arbury Group.

Our Third-party Supply Chain

The nature of the automotive industry is a widespread, interconnected network that makes it very complicated to navigate – for this reason, it makes it challenging to effectively manage and completely mitigate the risk of modern slavery.

Both our new and used vehicle supply chains are multifaceted, as any vehicle in question will have its own individual supply chain for its various parts. From this, we understand that our vehicle supply chain ultimately begins with the sourcing and manufacturing of the raw materials used in its constructions. At Arbury Group, our relationship is with the vehicle manufacturer, and not directly with their supply chain. We are keen to engage with our suppliers to ensure they match our high standards and the rules set out by the Modern Slavery Act 2015, and filter this message through their own supply chain.

Arbury Group is committed to ensuring transparency in our business and in our approach to tackling modern slavery within our supply chains, we expect the same high standards from all of our contractors, suppliers and other business partners. For each supplier we interact with, we establish a relationship that embodies integrity and trust.

Due Diligence

At Arbury Group, we have conducted a risk assessment of our business to assess the risk of modern slavery and human trafficking. Based on the results of this assessment and as part of our initiative to identify and mitigate risk, we have undertaken the following actions:

  • Added an assessment of slavery and modern trafficking risk into our supplier due to diligence check – this includes requiring them to complete a questionnaire on their own policies around the issue.
  • Created an enhanced Code of Conduct that highlights the standard of compliance expected from all of our third-party suppliers in areas of the business we deem to be high risk. The suppliers and contractors we deem to be in high-risk business areas are required to sign a document that states that, while carrying out its obligations to Arbury Group, they shall comply and seek to ensure that each of its own subcontractors and suppliers involved in the provision of goods and services comply with our Modern Slavery Act Code of Conduct.
  • Developed and implemented training to our Management Teams to identify, assess, mitigate and report specifically on modern slavery.
  • Developed and communicated our modern slavery policy to all of our employees and those who we conduct business with.
  • Ensured that our confidential employee reporting line is clearly promoted in all of our locations.
  • Designed and developed a modern slavery poster that gives a brief overview of the signs to look out for, including how employees can report concerns regarding this important issue. These posters are displayed in our employee areas throughout our business.

Although the majority of the risks within our business rest with our manufactures and suppliers, we are not complacent and will continue to seek, identify and manage any potential risks related to modern slavery. We have endeavoured to put safety precautions in place to ensure that the working practices of those directly employed by us, or those whom we have a direct contractual arrangement with also have a similar zero tolerance to modern slavery.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes Arbury Group Ltd.’s slavery and human trafficking statement for the financial year ending 31 March 2019.

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