Governance

Modern Slavery and Human Trafficking Policy

Car And Cab Care Ltd

Section 1

Our Commitment

Car And Cab Care Ltd (referred to as “the Company,” “we,” or “us”) is fundamentally opposed to all forms of modern slavery and human trafficking. We are committed to conducting our business ethically and with integrity, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

This policy reflects our commitment to acting ethically and with integrity in all our business relationships and to upholding the spirit and letter of the Modern Slavery Act 2015.

Section 2

Policy Scope and Application

This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including:

Employees (permanent, fixed-term, and temporary)
Directors and Officers
Agency workers and temporary staff
Contractors, sub-contractors, and consultants
Suppliers and business partners

The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Section 3

Definition of Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced or compulsory labour, and human trafficking. Human trafficking involves arranging or facilitating the travel of another person with a view to that person being exploited.

Key elements include:

Slavery — Exercising powers of ownership over a person.
Servitude — The obligation to provide services imposed by the use of coercion.
Forced or Compulsory Labour — Any work or service exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.
Human Trafficking — The movement of persons through force, coercion, or deception for the purpose of exploitation.

Section 4

Due Diligence and Risk Assessment in Operations

The transport and logistics sector, particularly involving long-distance haulage, warehousing, and international supply chains, carries inherent risks related to worker exploitation and trafficking. Car And Cab Care Ltd addresses these risks through:

a. Supply Chain Management

We expect our direct suppliers, sub-contractors, and partners to have in place anti-slavery and human trafficking policies and procedures.

Supplier Vetting — We conduct due diligence on new suppliers and periodically review existing suppliers, especially those providing temporary labour, cleaning services, or those involved in international vehicle or component sourcing.
Contractual Clauses — Our contracts with suppliers include specific clauses requiring them to comply with the Modern Slavery Act 2015 and provide documentation proving their compliance.
Right to Audit — We reserve the right to audit suppliers where we identify heightened risks or receive reports of non-compliance.

b. Recruitment and Employment

Verifiable Employment — We ensure all employees have the legal right to work in the UK and that their employment is voluntary and free from coercion.
Wage Compliance — We comply with all applicable employment laws, including those relating to minimum wage, working time, and annual leave.
Direct Payment — Wages are paid directly into a bank account in the worker’s name. We do not permit deductions from wages that are not legally allowed.
Staff Accommodation — We prohibit forced or compulsory use of company-owned accommodation and ensure no employee is charged excessive rent or fees.

c. Vehicle and Site Audits

We instruct transport managers and site supervisors to be vigilant for signs of exploitation, particularly at vehicle loading/unloading points, rest stops, and in accommodation provided to drivers or temporary workers.

Section 5

Training and Awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking, we provide training to relevant staff, including procurement teams, HR staff, and management. Training covers:

The legal obligations under the Modern Slavery Act 2015.
Recognising the key indicators of modern slavery and human trafficking.
What steps to take if they suspect an instance of modern slavery.

Section 6

Reporting and Whistleblowing

We encourage all employees, customers, and suppliers to report any concerns related to modern slavery or human trafficking at the earliest possible stage.

Internal Reporting — Concerns should be reported to the departmental manager, or directly to the HR Department or Compliance Officer.
Whistleblowing Protection — We are committed to ensuring no one suffers detrimental treatment as a result of reporting in good faith their suspicion that modern slavery is taking place in any part of our business or supply chain.
External Reporting — Where appropriate, we support employees in reporting concerns to external bodies such as the Modern Slavery Helpline (08000 121 700) or the relevant government authorities.

Section 7

Breach of Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We may terminate our relationship with contractors, suppliers, or business partners if they breach this policy.

Section 8

Policy Review

This policy will be reviewed annually by the Board of Directors and updated as necessary to reflect changes in legislation, operational practices, and any identified areas of increased risk.