MODERN SLAVERY STATEMENT – Year 2017

RONTEC ROADSIDE RETAIL LIMITED 

MODERN SLAVERY STATEMENT FOR FINANCIAL YEAR 2017

 

INTRODUCTION

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.

 

OUR BUSINESS

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:

  • England
  • Wales

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

Responsibility for the company’s anti-slavery initiatives is as follows:

Policies:

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.

 

Risk assessments:

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.

 

Investigations/due diligence:

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.

Training:

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.

 

RELEVANT POLICIES

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.

 

PERFORMANCE INDICATORS

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

Date:   19/12/2017