Introduction

This Slavery and Human Trafficking Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 relating to Transparency in Supply Chains. This statement sets out the steps Intercounty Truck & Van Limited has continued to take to address the risk of slavery and human trafficking within its operations and supply chain.

Organisational Structure

Intercounty Truck & Van Limited has been operating as a Mercedes-Benz commercial vehicle franchise for over 20 years covering Northamptonshire, Cambridgeshire, Buckinghamshire, Bedfordshire and Lincolnshire with dedicated commercial vehicle dealerships to support our customer base.

The business unit operates autonomously drawing on support centrally from parent company Intercounty Limited in respect of health and safety, the environment, legal counsel, human resources, property, IT, insurance and finance.

Countries of Operation and Supply

Intercounty Truck & Van Limited operates in the United Kingdom.

Intercounty Truck & Van Limited remains committed to review and evaluate our supply chains to identify human trafficking risks and slavery risks and we continue to review all aspects of the supply chain function with zero tolerance for non-compliance.

Intercounty Truck and Van’s primary supply chain includes:

Commercial vehicle manufacturers

Commercial vehicle equipment suppliers

Manufacturers of goods and materials

Utilities and service providers

The procurement of services and supplies is undertaken professionally by supply chain and or procurement specialists within the central supply chain function or within the business unit. It is our intention to maintain long term relationships with customers and suppliers and we actively encourage collaborative working and good industry practice.

As a business we continue to support the Stronger Together Programme, and fully endorse the work being done to reduce forced labour and human trafficking in the United Kingdom and across the world.

 

Responsibility

Responsibility for the organisation’s anti-slavery and human trafficking initiatives is as follows:

• Policies: Human Resources

 

• Risk assessments: Procurement & Group H&S Management Team

 

• Investigations: Group Finance & HR/Compliance

 

• Training: Procurement & Human Resources

 

Relevant policies

Intercounty Truck & Van Limited is committed to ensuring there is no modern slavery or human trafficking in its supply chain or in any part of its business with a zero tolerance for non-compliance.

This statement reflects that commitment to acting ethically in all business units and to establishing an effective system to ensure slavery and human trafficking is not present in the supply chain. Intercounty Truck & Van Limited operates under a number of policies, which underpin our ethical approach to business:

• Whistleblowing policy -Intercounty encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact James Darragh BVH Group Director on 02890 849321.

 

• Employee code of conduct – Intercounty’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

 

• Supplier code of conduct – Intercounty 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 organisation 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 organisation’s supplier code of conduct will lead to the termination of the business relationship.

 

• Recruitment policy – Intercounty uses only specified, reputable employment agencies to source labour and where not possible seeks to verify the practices of any new agency it is using before accepting workers from that agency.

 

Compliance

Intercounty Truck & Van Limited assesses compliance in its existing supply chain and will continue to undertake due diligence when considering taking on new suppliers to include:

Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking

 

Evaluating the modern slavery and human trafficking risks of each new supplier

 

Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping

 

Conducting supplier audits or assessments which have a greater degree of focus on slavery and human trafficking where general risks are identified;

 

Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans;

 

Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular as evidenced by our participation in “Stronger Together” initiatives;

 

Invoking sanctions against suppliers who fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship;

 

Performance indicators

During 2022 there were no reported incidents or investigations associated with modern slavery and or human trafficking in Intercounty Truck & Van Limited or in any of its autonomous business units. The organisation continues to review its key performance indicators around modern slavery and human trafficking and as a result we will continue to:

• Require all staff working in procurement and HR to have completed training on modern slavery;
• Develop a system for supply chain verification prior to supplier on boarding; and
• Review existing supply chains

 

Recruitment & Training

Intercounty Truck and Van Limited undertakes selective pre-employment screening, references, conducts identity checks and confirmation of entitlement to work in the United Kingdom on all employees prior to commencement of employment.

New employees are given an overview of the essential policies and information in relation to Intercounty Truck & Van Limited policies, procedures and other matters such as whistle blowing, dignity at work, and equality. Looking ahead into 2023 and 2024 the introduction of a centralised H&S and HR online training portal and employee engagement platform will heighten levels of awareness, information and communication. Part of this exercise we see the development of a centralised dashboard to provide uniformity and heightened visibility to management teams around employee training. For all employees the ongoing process of training and communication around modern slavery and human trafficking with continue unabated utilising the very effective resources provided by Stronger Together across all media formats.

 

Awareness-raising programme

As well as training specific staff, the organisation has raised awareness of modern slavery issues by utilising the Stronger Together portfolio of multimedia resources to communicate, to highlight, to inform, to advise and to support, focusing on the key aspects of:

 

The basic principles of the Modern Slavery Act 2015;

 

How employers and employees can identify and prevent slavery and human trafficking;

 

What we all can do to highlight slavery or human trafficking issues to the relevant parties within the organisation and beyond;

 

Board approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015, for the financial year ending 30 September 2022. It applies to lntercounty Truck & Van Limited and has been approved by the Board of Directors.

 

Nick Skillman

Managing Director

Date 22nd May 2023