This statement sets out how Halfords Group Plc (“Halfords”) complies with the Modern Slavery Act 2015 (the “MSA”).
It also explains how we comply with the new guidance in relation to the MSA, which was released by the Government in October 2017.
As a business, we wholly support the purpose of the MSA which is to promote transparency in supply chains and we also note that since the new guidance is intended to drive best practice it will assist businesses with tackling Modern Slavery. This is to be done by encouraging organisations to provide information in relation to six categories, which are set out in Section 54(5) of the MSA.
Halfords operates retail stores across the UK and Ireland and garages throughout the UK. Its main trading subsidiaries are Halfords Limited and Halfords Autocentres Limited and the products we sell are sourced from a broad range of national and international suppliers. Our international supplier relationships are managed by a dedicated Halfords Global Sourcing (“HGS”) team with colleagues based in Hong Kong, Taiwan and Shanghai.
Additionally, in October 2019, Halfords established a Compliance Committee (the “Committee”) in order to provide the necessary internal oversight and governance. Our compliance with the MSA will be discussed as part of this Committee, which will subsequently report to Halfords Group plc’s Audit Committee.
Halfords has established an Ethical Trading Statement which is available on our website at: Ethical Trading. This details how we comply with the legislation which is applicable to Ethical Trading, and also sets out the standards we expect of our suppliers. In particular, this Ethical Trading Statement addresses such matters as: conditions of employment; wages and benefits; child labour; modern slavery (which may also be referred to as forced labour) and human trafficking. It also includes other related matters such as safety and environmental policies.
To ensure that our policies and standards are communicated as effectively as possible, we have established a specific Code of Conduct which applies specifically to the organisations that supply us with the goods we sell. Our Code of Conduct on ethical trading includes compliance with our policy on modern slavery and human trafficking.
This approach allows us to set both general standards across the whole of our business and at the same time, it also enables us to require additional information from those businesses in our supply chain in the areas where we have assessed that there may be increased risks.
We operate robust due diligence processes in relation to the MSA whereby we undertake practical steps that include inspections and audits of the factories, warehouses and tied accommodation operated by our suppliers. These inspections and audits help to ensure that our standards are being implemented by our suppliers throughout their businesses and that they are also in compliance with local legislation and regulations.
We assess any instances of non-compliance on a case-by-case basis and then tailor remedial action appropriately. We will only trade with those companies which already fully comply with these requirements or which are taking verifiable steps towards full compliance.
As referred to above, we consider that the risk of modern slavery is greatest in our supply chain and so we have taken the following steps to assess and manage that risk:
The responses from suppliers to these supply chain audits have been positive. While such audits are always on-going and our aim is to repeat them regularly, the completed replies we have received so far have identified good standards and high levels of compliance. We have not unearthed any adverse findings.
To ensure the effectiveness of our approach in regard to ensuring compliance with both the MSA and the new Section 54(5) guidance, we have, in addition to the matters described above, adopted the following approach:
Halfords’ colleagues have received training in a variety of areas relating to how we seek to operate as an ethical business. This includes: Anti Bribery and Corruption training which has been carried out both in the UK and overseas with our colleagues in HGS. The bespoke training sessions for our HGS teams were given by the local offices of an international law firm and were provided in both English and the local languages, such as Mandarin Chinese. This training has since been repeated in the UK and will be further refreshed and delivered again when appropriate.
This statement was approved by our Board of Directors on 6 February 2020 and will be reviewed on an annual basis.