MODERN SLAVERY ACT TRANSPARENCY STATEMENT

INTRODUCTION

This is the Modern Slavery Transparency Statement of Supagard Limited ("Supagard") for the financial year ending 31 December 2020. This statement is made pursuant to s.54(1) of the Modern Slavery Act 2015.

Supagard is committed to operating with integrity and accountability. That commitment applies both within the organisation and in our relationships with suppliers.

We adopt a zero-tolerance approach to slavery and human trafficking. We are committed to taking all reasonably practicable steps to ensure that slavery and human trafficking is not present either in our operations or supply chains.

Supagard recognises that slavery and human trafficking are not issues which are confined to the overseas sector. In particular, we recognise and are assessing the risks that arise from the use of foreign and migrant labour, and from supply chains both in the UK and overseas.

ABOUT SUPAGARD

Our business

The Supagard group is one of the UK's market leader of quality car care products. This Statement is made in respect of the operations of Supagard Limited.

The focus of our business is people, and our responsibility begins with the way we treat our staff and invest in their potential through training and personal development.

POLICIES AND PROCEDURES

Supagard has an existing compliance programme comprising policies, procedures and requirements for employees, suppliers in relation to human rights, ethical practices and modern slavery. This includes robust checks and verification in respect of migrant workers; a whistleblowing policy to encourage reports from staff of unethical conduct; and a central register of recruitment agents and supplier contracts. We only work with trusted agents and suppliers and we require all potential employees to provide evidence of entitlement to work in the UK.

In direct response to the risk of slavery and human trafficking, Supagard has built on its existing compliance framework by:

Updating our Whistleblowing policy to ensure coverage of suspected slavery and human trafficking incidents
Amending and implementing our Anti-Slavery Policy so that it can be shared with our suppliers and recruitment agencies
Taking external legal advice on the application of the Modern Slavery Act 2015 to our business
Communicating our senior management’s strong support for the aims of the Modern Slavery Act 2015 and our zero tolerance approach to slavery and human trafficking
Conducting a risk assessment of our business and our supply chains (as detailed below)
Identifying Key Performance Indicators against which to assess our progress in managing the risks of slavery and human trafficking in our business and our supply chains (as detailed further below)

DUE DILIGENCE IN OUR SUPPLY CHAINS

As part of our zero tolerance approach to slavery and human trafficking, Supagard will only work with those who provide assurances on their working practices and commitment to combating slavery and human trafficking in their own businesses and supply chains.

We endeavour to conduct regular Risk Assessments of our supply chains. Where we identify suppliers to be “at risk” of slavery and human trafficking we will seek compliance assurances from them; exercise right to terminate early for failure to comply with applicable laws and our Anti Slavery Policy etc.

KEY PERFORMANCE INDICATORS (“KPIs”)

We will use the following KPIs to measure how effective we have been to ensure that slavery and human trafficking is not taking place in our business or supply chains:

Any and all incidents or complaints of slavery and human trafficking reported to the Finance Department, whether under our Whistleblowing Policy or otherwise, are investigated within 24 hours
Monitoring the response rate of “at risk” suppliers to our request that they advise us on the steps taken to ensure slavery and human trafficking is not taking place in their business or supply chains
Numbers of staff trained on our Anti-Slavery Policy and updated Whistleblowing Policy;
Remedial action taken following non-compliances found during audits

FUTURE STEPS

Supagard believes in increased transparency in how businesses are playing their part in preventing slavery and human trafficking. We will continue to monitor the effectiveness of our compliance programme and take necessary steps to address any instances of slavery and human trafficking on an ongoing basis. We will publish an updated Modern Slavery Act Transparency Statement in each financial year.

Any queries in relation to this Modern Slavery Act Transparency Statement should be addressed to the Finance Team, Supagard Limited, 19-29 Gavinton Street, Glasgow, G44 3EF or by email to: Pauline.Paterson@supgard.com.

This Modern Slavery Act Transparency Statement was approved by the Board of Directors of Supagard Limited on 31 May 2021.

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