Marshall Motor Holdings Limited and its subsidiary undertakings (referred to in this Modern Slavery Statement as “Marshall”) operate a variety of motor services including the sale of passenger cars and commercial vehicles, vehicle servicing, vehicle repair and associated activities.
Marshall is part of the Constellation Automotive Group (the “Group”) which operates a market‐leading business across the UK and Europe.
Modern slavery is a serious crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Marshall acknowledge that companies:
Marshall has a zero‐tolerance approach to modern slavery. Marshall is committed to:
The Modern Slavery Act 2015 (referred to in this statement as the “Act”) introduced changes in law focused on placing the issue of modern slavery at the forefront of decision making when engaging new suppliers and relationships and increasing transparency in supply chains. This includes the requirement for a statement to be disclosed (by businesses of a certain size) to set out what steps they have taken to ensure their business and supply chains are free from modern slavery.
This statement sets out the steps that Marshall has taken, and is taking, to ensure that it trades ethically, sources responsibly and works to prevent modern slavery and human trafficking throughout Marshall and in its supply chains.
In addition to Marshall Motor Holdings Limited, this statement covers the following entities within Marshall (who meet the threshold for reporting under the Act):
The registered office for Marshall at the date of this statement is c/o Marshall Volkswagen Milton Keynes, Greyfriars Court, Milton Keynes, Buckinghamshire MK10 0BN, United Kingdom.
Marshall’s principal suppliers are global vehicle manufacturers which supply Marshall with vehicles and parts for onward sale to customers and under whose dealer agreements Marshall operates its motor dealership businesses.
In addition, Marshall has commercial arrangements with vehicle finance and insurance providers which provide finance and insurance products to Marshall’s customers. Marshall also engages with other providers of goods and ancillary services (including oil and consumables supply, valeting services etc.).
This list is not exhaustive.
Marshall purchases a broad range of operational and professional services as expected for an organisation of its size and diversity. This includes legal, accountancy, information technology, insurance, cleaning, property maintenance and other back‐office functions.
Marshall expects all businesses in its supply chains to comply with its values and strives to ensure that it does not participate, or work with, suppliers that operate unfair and inappropriate working practices.
Marshall has implemented a Supplier Code of Conduct developed by the Group. As part of an ongoing process, suppliers will be provided with a copy of this Supplier Code of Conduct and details of Marshall’s requirements (as varied from time to time). Where appropriate, a supplier will be expected to comply with this Supplier Code of Conduct.
Marshall continues to both:
Marshall is committed to:
For this reason, Marshall has in place a number of policies, guidance and procedures which set out the standards of behaviour and core values that it expects of its employees.
Marshall’s employee portal provides employees with easy access to these policies and procedures (during recruitment and for future reference). The policies and procedures in the Marshall employee portal cover those elements of UK legislation applicable to an individual’s employment, including:
This above list is not exhaustive.
These policies set clear standards to the employees of Marshall for legal compliance. Disciplinary procedures are in place for any employee whose conduct does not meet the standard required.
During the year to which this statement relates, the Group has added to its policies.
As part of an initiative to identify and mitigate risk, Marshall operates an on‐boarding process for new material suppliers which includes a requirement for a prospective material supplier to confirm compliance with legislation, including the Act. A questionnaire regarding suppliers’ business practices is provided for material suppliers to complete during selection and/or contract negotiation. Marshall expects responses to be accurate and comprehensive. Any gaps or queries flagged in the review of the completed questionnaire will be referred back to the supplier for further information.
During the year to which this statement relates, the Group’s central procurement team have developed a bespoke modern slavery questionnaire. This is used, as part of a formal tender exercise, to perform enhanced due diligence where the industry in which the supplier operates is considered to present a higher risk of modern slavery – for example, the supply of branded workwear.
The information obtained during this due diligence process is used by Marshall to determine whether or not:
Where a supplier is successful in completing the on‐boarding process, various contractual obligations are included in the contractual terms of the agreement to ensure that the supplier complies with all legal obligations (which will include prohibitions against the use of forced, compulsory and/or trafficked labour).
Marshall expects its suppliers to hold their supply chain to the same high standards. Going forward, Marshall continues to:
The recruitment process operated by Marshall for the appointment of new employees is designed to operate in a legal and ethical manner and includes the following practices:
This list is not exhaustive.
Marshall does not employ any children who are under the legal minimum working age. All apprenticeship roles are offered, and fulfilled, in compliance with applicable law in this subject matter.
Marshall utilises reputable service providers, many of which are also subject to the Act. Our on‐boarding processes are designed to select supplier partners responsibly.
Any concerns raised during the on‐boarding process of a new supplier will be escalated to senior management. Marshall will not engage in a business relationship where the information provided by the supplier does not satisfy Marshall that the supplier complies with all applicable law as it relates to modern slavery, servitude, forced or compulsory labour and human trafficking.
Where a concern is identified after a supplier has been appointed, reasonable and practical checks will be carried out (to test whether our standards are being adhered to, and legislation and regulations relevant to the supplier are being complied with). Any instances of non‐compliance will be dealt with on a case‐by‐case basis and any remedial actions tailored appropriately.
As at the date of this statement, Marshall has not identified any instances or indications of slavery or human trafficking existing in its supply chain. In light of this, Marshall has not considered it necessary to put in place formal key performance indicators to assess its effectiveness in ensuring that slavery and human trafficking is not taking place in any part of Marshall’s business or supply chains. Marshall will continue to keep this position under review.
Marshall employs people in locations across the UK.
Appropriate training is provided and Marshall will continue to develop this training as legislation and standards evolve.
This statement is accessible to all.
Marshall has a Whistleblowing policy that applies to employees, consultants, agents, contractors, interns, casual workers, agency workers, business partners, sub‐contractors as well as any representatives or third parties acting on behalf of, or representing Marshall.
To help facilitate compliance with:
a confidential, independent whistleblowing help‐line is in place. Individuals are encouraged to use the help‐line to report any activity they are concerned about in any part of the Marshall’s business or its supply chain.
The help‐line is communicated through the Marshall Whistleblowing policy which:
The Marshall Whistleblowing policy is available at all times.
This statement is made pursuant to Section 54(1) of the Act and constitutes the slavery and human trafficking statement for Marshall for the financial year ending 2 April 2023. It has been approved by the Board of Directors, who will review it on an annual basis making updates as necessary.
Marshall is committed to the continuous improvement of its operations, processes, and knowledge, in eradicating modern slavery and human trafficking in its own business and wider supply chain.
Mark Hemus, Director
27 September 2023