Anti-Slavery Human Trafficking Statement

Introduction
This statement sets out D. M. Keith's 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 2019/2020.

As part of Automotive Industry, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking. D. M. Keith is committed to acting ethically and with integrity and transparency in all business dealings.

The Company is 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.
During the financial year, the Company has taken the following steps, in relation to its subsidiary companies and otherwise, to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its business:

All employees are paid in accordance with the Company’s obligations in respect of the National Minimum Wage and National Living Wage and benefit from annual leave in accordance with the Working Time Regulations 1998 together with other benefits which exceed statutory obligations.

This statement covers the activities of D. M. Keith. We continue to be owned and run by the Keith family. We have ten sites across Yorkshire & Lincolnshire.
The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

• We review the risk assessments from the third party Companies who provide subcontract employees, annually, and at any point in the year when the employees change.  

High-risk activities
The following activities are considered to be at high risk of slavery or human trafficking:

• Valeting by a third-party provider
• Dealership cleaning by a third-party provider

• Risk assessments: Review copies of the personal identification during the onboarding process, ensure that all employees are paid in accordance with the Company’s obligations in respect of the National Minimum Wage and National Living Wage and benefit from annual leave in accordance with the Working Time Regulations 1998 together with other benefits which exceed statutory obligations.
• Investigations/due diligence: Angus Keith, Director and Rachel Thompson, HR Director are responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
• Training: Training has been received from the third party supplier as part of the contract negotiation with ourselves to better understand and respond to the identified slavery and human trafficking risks.

Relevant policies
The Company 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:

• Whistleblowing policy - The Company encourages all its workers, customers and other business partners 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 workers to make disclosures, without fear of retaliation.
• Employee handbook - The Company's handbook 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 and ethical behaviour when operating abroad and managing its supply chain.
• Recruitment policy – D. M. Keith conducts robust checks on any new employee including eligibility to work in the UK to safeguard against human trafficking or individuals being forced to work against their will. The Company 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. Where we engage contractors, for example via an agency or a personal services company, the manager responsible for the engagement is required to confirm that the terms of the engagement are in accordance with our Modern Slavery Statement and our Ethical Policy.

Supplier code of conduct
The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the Company's supplier code of conduct will lead to the termination of the business relationship.

The Company has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the Company reviews and evaluates potential suppliers before they enter the supply chain. Existing suppliers are also reviewed and evaluated annually.

Training
The Company requires that the Senior Management within the Company complete training on modern slavery.

The Company's modern slavery training covers

• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within the Company;
• what external help is available, for example through the Modern Slavery Helpline,
• what steps the Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chains.

Board approval
This statement has been approved by the Company's board of directors, who will review and update it annually. The Board of Directors of the Company approved this statement April 2021.