MODERN SLAVERY STATEMENT – Year 2017
RONTEC ROADSIDE RETAIL LIMITED
MODERN SLAVERY STATEMENT FOR FINANCIAL YEAR 2017
This statement sets out Rontec Roadside Retail Ltd and its subsidiary Companies (the Group) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st October 2016 to 30th September 2017.
As part of the forecourt retail industry the company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
The Group is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
The principle business of the Group is the ownership and operation of 240 forecourt service stations through a business model of engaging with third parties (known as Commission Operators) acting as our agent and providing services in relation to the day to day operation of their contracted forecourt.
The main business activities include:
- Fuel sales
- Cash wash and valet facilities
- Retail shop sales
- Fast food franchise operations
Countries of operation and supply
The company currently operates in the following countries:
The Group regularly reviews its countries of operation to assess whether or not particular activities or countries are high risk in relation to slavery or human trafficking.
Responsibility for the company’s anti-slavery initiatives is as follows:
The Group operates a number of internal policies and procedures to provide guidance to ensure we conduct our business in a legally compliant and ethical manner. All policies are reviewed and approved by the company’s Managing Director. All policies are reviewed regularly and amended in accordance with new legislative requirements or changes within the business.
The Board is responsible for reviewing the risk of our commercial activities to understand if there are any potential risks where Modern Slavery could occur.
Having risk-assessed our business the Board has identified that as we are not involved in activities where occurrences of modern slavery have been identified, we and our supply chain are both at low risk of having modern slavery occur.
We believe that the highest risk to our business is within the operation of our service stations, where direct labour is engaged via a third party employer (known as the Commission Operator). In this respect we have little direct control over the employment practices and activities of the independent retailer at the forecourt. We have implemented a Commission Operator Agreement that strongly encourages ethical employment activities.
We have identified that there is a significant minority of Non-EU Nationals within the working population within the retail sector, this is not specifically limited to our business but an industry wide trend so there is a potential opportunity for human trafficking and forced labour activities.
To ensure compliance with the numerous legislative requirements linked to employee’s right to work in the UK, we carryout regular screening of our employees both during the recruitment process and periodically thereafter. If there are any suspected instances of Slavery and Human Trafficking, this would be immediately investigated by the Head of Human Resources and findings provided to the Managing Director so appropriate action can be taken.
The Group provides on-line training to all its employees to provide an awareness of the Modern Slavery Act, and an awareness of the key risks to the company, their personal responsibilities and how to report any concerns.
As well as training staff, the company has raised awareness of modern slavery issues to its third party Commission Operators via the information bulletins.
The Group operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Anti-slavery Policy – The policy sets out the Group’s stance on modern slavery and explains how employees can identify and raise concerns.
- Whistleblowing policy – The Group encourages all its employees to report any
concerns related to the direct activities, or the supply chains of, the company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The company’s whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.
- Employee code of conduct – The Group’s code makes clear to employees the actions and behaviour expected of them when representing the company. The company strives to maintain the highest standards of employee conduct.
- Recruitment Procedure -We operate a robust recruitment process that includes
eligibility to work in the UK checks, proof of residency and references for all new employees. The Group uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
- Commission Operator – Eligibility to Work in the UK screening – We conduct pre-contract screening as part of the first stage in the application process for all interested parties wanting to take on the operation of one of our Forecourts. This includes eligibility to work in the UK documentation check, proof of address and completion of a third party criminal and credit check. If any concerns are highlighted during this process, the application is terminated. Periodically checks are carried out
to ensure all Commissions Operators remain eligible to work in the UK, those who status has changed, their Commission Operator Agreement is terminated.
- Audits – Specific authorised Rontec Employees conduct periodical checks to ensure that employment practices of our Commission Operators are in line with the requirements of the Immigration Act 2016.
The Group considers that there are two reasonable indicators that slavery and I or human trafficking is not taking place within our business if:
- If we receive no reports from either law enforcement agencies, employees, Commission Operators, their workers or the public to indicate that slavery and I or human trafficking practices have been identified in relation to our business, our trading partners or suppliers.
- That none of our third party Commission Operators appear on the Sanction List.
Board Approval of Statement
This statement was approved by the Board
G.M. Ronson CBE