Brayleys Cars

Limited Slavery and Human Trafficking Statement

This statement sets out the steps we have or are taking to ensure that slavery and human trafficking are not taking place in any of our supply chains and is made pursuant to section 54(1) of the Modern Slavery Acts 2015 and constitutes the company’s slavery and human trafficking statement for the financial year ended 31st December 2021.

Company Structure

Brayleys Cars Limited is a private company, whose principal activities are the sale of new and used cars, vehicle servicing and associated activities. We represent 6 global vehicle brands, each operating under a franchise agreement. During the year ended 31sth December 2021, the company sold goods and services to the total of £158 million, employing an average of 273 staff. All of its operations are in the United Kingdom.

Our Policies

Family values, including treating others with respect and acting with fairness, honesty and integrity, are held dear by the board and we are therefore committed to preventing acts of modern slavery and human trafficking from occurring both within the company and its supply chains. We expect and require the same standards from our suppliers and staff. It is our stated policy to treat every visitor to Brayleys as a “Welcomed guest in our home. Every day. Every time. Without fail. No exceptions.” and this belief extends to the way we engage with our staff and suppliers.

Due Diligence Processes for Slavery and Human Trafficking

The company’s principal suppliers are global vehicle manufacturers who supply vehicles and parts, and the supply chain prior to a completed vehicle is complex and multi layered and has many overseas elements. This makes it challenging for Brayleys Cars Ltd, as a franchised motor retailer, to see or manage any issues in that supply chain. Respecting human rights and environmental issues in that supply chain is ultimately our manufacturers responsibility and the measures that they take are set out in their own Modern Slavery statements. However, the company also has numerous smaller suppliers at a more local level and we seek to identify and do business with companies that have values consistent with ours, including applying these expectations to their own supply chain. With regard to our own workforce, our employee pay structure honours the national living/minimum wage rate as a minimum and employees are expected to act with honesty and integrity at all times.

Risk Assessment

• We conduct a risk assessment of any of our suppliers who we consider may be exposed to such risks.

• We engage with significant group suppliers to explain our policy on anti-slavery and human trafficking.

• Where we suspect there is a high risk of such activity within a suppliers’ organisation we insist that the supplier self-reports to us on their safe guarding controls.

• If necessary, we will introduce explicit contractual commitments with suppliers to confirm that they comply with the Modern Slavery Act 2015

• We reserve the right to terminate our relationship with any supplier if issues of noncompliance are discovered.

Effectiveness in Combating Slavery and Human Trafficking

At this time, we have not identified any instances or indications that either slavery or human trafficking occurs in our supply chain, so we have not considered it necessary to adopt any performance indicators. However, our ongoing work with our suppliers should indicate if any of them are not implementing appropriate measures or cannot provide the necessary confirmations to us.

Training of Staff

As part of the company induction process and throughout their employment with us, we train all staff to treat others with respect and courtesy as well as ensuring they adhere to all relevant laws, regulations and standards. Including the need to be aware of the risks around modern slavery and to whom any concerns should be addressed to within the company.

Reporting of Modern Slavery or Human Trafficking

Any employees, supplier or member of the public can write, in confidence to the Managing Director or Group Human Resources Manager at our Registered Office address to raise any concern, issue or suspicion of modern slavery in any part of our business or supply chain. The nature of the complaint will determine the company’s next course of action.

Approval

This Statement is made in pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st December 2021.

Approved by the board of directors on 23rd March 2022 and signed on its behalf by:

Paul Brayley

Managing Director