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Slavery and Human Trafficking Statement

INTRODUCTION

Introduction Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Barlow Motors Plc has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing appropriate and effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in our supply chains. The Modern Slavery Act 2015 (the “Act”) introduced changes in UK law focused on increasing transparency in supply chains. Specifically, large businesses are required to disclose the steps they have taken to ensure their business and supply chains are free from modern slavery. This statement sets out the steps we have and are taking to ensure that slavery and human trafficking are not taking place in any of our supply chains or businesses.

GROUP POLICY

Barlow Motors ltd is committed to improving our practices to combat modern day slavery and human trafficking of any kind within its own business and supply chains. Barlow Motors ltd.’s primary protection against slavery is to ensure that all business activity complies with minimum wage legislation. Barlow Motors ltd also requires this of its contractors. Barlow Motors ltd.’s first line of defence against human trafficking is to ensure that all Barlow Motors ltd Group employees have the right to work in the UK. Barlow Motors ltd also requires that UK contractors only employ staff with the right to work in the UK.

OUR SUPPLY CHAINS

Due to the breadth of its businesses and supply chains Barlow Motors ltd is not in a position to check every business relationship and avenue. The principal areas at higher risk of human trafficking and slavery are those related to our supply chains, in particular cleaning services, Valeting and Uniform suppliers.

Barlow Motors ltd sources and sells products and parts from a broad range of national and international suppliers. Our supplier and contractor approval process incorporates a review of the controls being undertaken by the supplier. To ensure that external supply chains comply with this policy Barlow Motors ltd requires that the business practices and supply chains of each supplier are in accordance with Barlow Motors ltd principles and monitors compliance by suitable levels of due diligence according to the level of risk which Barlow Motors ltd assesses of the potential for human trafficking and/or modern slavery.

Any instances of non-compliance of which Barlow Motors ltd is made aware will be assessed on a case-by-case basis. Remedial action will be taken and tailored to suit the circumstances. Barlow Motors ltd will only trade with those who fully comply with this statement or those who are taking steps towards full compliance. If Barlow Motors ltd is not satisfied with the steps being taken towards full compliance, it will temporarily suspend its business with that supplier (to the extent permitted under contract or by law). The ultimate sanction for the continual failure to comply will be for Barlow Motors ltd to cease to trade with that supplier (to the extent as permitted under contract or by law).

Barlow Motors will quickly and thoroughly investigate any claim or indication that any area of its business or supply chains is engaging in human trafficking or slave labour.

Any such claim coming to the attention of personnel within Barlow Motors ltd should be reported to senior management in accordance with our Whistleblowing Policy. The board of directors will be informed of the issue including the findings and outcome of the investigation.

TRAINING

All Barlow Motors ltd employees are provided with full details of Barlow Motors ltd Business Code of Conduct, Whistleblowing Policy and other company policies, including this statement. These are provided on the Barlow Motors ltd employee portal. All employees are encouraged to familiarise themselves with this information at induction and by regular training to raise awareness of the risks and consequence’s involved with modern day slavery and human trafficking along with email updates as the law changes. The Code of Conduct specifically outlines ethical business practice as integral to all our dealings and our expectation of compliance with applicable laws is absolute.

APPROVAL

This statement has been approved by the board of directors of Barlow Motors ltd, which we will review and update it as necessary on an annual basis.

Wolverhampton SEAT
01902 714 503 1 Evans Street
Off New Hampton Road West
Wolverhampton
West Midlands
WV6 0PL
Stoke SEAT
01782 377 200 Gordon Banks Drive
Trentham Lakes
Stoke on Trent
ST4 4FD
Stoke ŠKODA
01782 562 666 43 Talke Road
Newcastle-under-lyme
Staffordshire
ST5 7NL
Crewe ŠKODA
01270 584 669 Weston Road
Crewe
CW1 5XN

Barlow Motors Limited is an Appointed Representative of Automotive Compliance Ltd, who is authorised and regulated by the Financial Conduct Authority (FCA No 497010). Automotive Compliance Ltd’s permissions as a Principal Firm allows Barlow Motors Limited to act as a credit broker, not as a lender, for the introduction to a limited number of lenders and to act as an agent on behalf of the insurer for insurance distribution activities only.

We can introduce you to a selected panel of lenders, which includes manufacturer lenders linked directly to the franchises that we represent. An introduction to a lender does not amount to independent financial advice and we act as their agent for this introduction. Our approach is to introduce you first to the manufacturer lender linked directly to the particular franchise you are purchasing your vehicle from, who are usually able to offer the best available package for you, taking into account both interest rates and other contributions. If they are unable to make you an offer of finance, we then seek to introduce you to whichever of the other lenders on our panel is able to make the next best offer of finance for you. Our aim is to secure the best deal you are eligible for from our panel of lenders. Lenders may pay a fixed commission to us for introducing you to them, calculated by reference to the vehicle model or amount you borrow. Different lenders may pay different commissions for such introductions, and manufacturer lenders linked directly to the franchises that we represent may also provide preferential rates to us for the funding of our vehicle stock and also provide financial support for our training and marketing. But any such amounts they and other lenders pay us will not affect the amounts you pay under your finance agreement, all of which are set by the lender concerned. If you ask us what the amount of commission is, we will tell you in good time before the Finance agreement is executed. All finance applications are subject to status, terms and conditions apply, UK residents only, 18’s or over. Guarantees may be required.

You can check this on the FCA Register by visiting the www.fca.org.uk or by contacting the FCA direct on 0800 111 6768.

Registered Companies House: BARLOW MOTORS LIMITED: Address: 1 Evans Street, Whitmore Reans, Wolverhampton, West Midlands, WV6 0PL (05583716)

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