Brayleys Cars Limited (’the Company’) Slavery and Human Trafficking Statement

This statement sets out the steps the Company is currently, or will, take to ensure that slavery and human trafficking are not taking place in any of our supply chains. This statement 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 2024.

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 9 global vehicle brands, each operating under a franchise agreement. During the year ended 31st December 2024, the Company sold goods and services to the total of £624 million, employing an average of 768 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. 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.

Due Diligence Processes for Slavery and Human Trafficking

The Company’s principal suppliers are global vehicle manufacturers who supply vehicles and parts. The supply chains prior to a completed vehicle or a part are complex and multi layered and have many overseas elements. We are aware though that all of the manufacturers we deal with appear, on the basis of their public statements, to have in place robust measures to manage the risk of slavery and human trafficking being present in their own supply chains.

The Company also has numerous smaller suppliers at a more local level. 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

The principal suppliers are global vehicle manufacturers. Given the robust policies that they appear to have in place to manage the risk of slavery and human trafficking being present in their own supply chains, we consider this risk to be low.

Additionally, our operations are entirely based in the UK. Most of our workforce is directly employed in a well-regulated environment. We consider the risk of modern slavery within our direct operations to be low.

There are some very limited exceptions where certain job roles are subcontracted, such as cleaners and vehicle valeters.  We only engage with reputable contractors and we conduct a risk assessment of any of our suppliers who we consider may be exposed to such risks. We review right to work and modern salary risks with these suppliers prior to contracting with them and on an ongoing basis.

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 non-compliance 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 Chief Executive Officer or Human Resources Director 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 2024.

Approved by the Board of Directors on the 18th June 2025 and signed on its behalf by Amro Jayousi.