This Statement details the steps we have taken up to the end of September 2017 towards ensuring that slavery and human trafficking are not taking place either in our organisation or our supply chain. Zenith has a long-standing commitment to conducting business ethically and the prevention of slavery and human trafficking is an important part of that commitment.
This is Zenith’s second annual Modern Slavery Act Transparency Statement and shows the progress we have made in developing and maturing our strategy.
The Zenith Group employs over 550 employees in the UK. We are the UK's leading independent leasing, vehicle outsourcing and fleet management provider. In February 2017, we acquired Contract Vehicles Holdings Limited Group (CVL), a provider of commercial vehicle contract hire and fleet management solutions specialising in the HGV market. CVL published it’s own transparency Statement for the financial year ending 31st March 2016, but it is anticipated that next year Zenith Group will publish one statement for the whole group, including CVL.
Our supply chain
We have categorised our supply chain into four groups:
Non-direct / ad hoc
As reported in last year’s Statement, we focussed the launch of our Supplier Code of Conduct on the Core in-life suppliers (further details provided below).
Our policy commitment to preventing slavery and human trafficking is underpinned and supported by the following:
Our approach to assessing and managing risk
A collaborative approach with our supply chain, which encourages transparency. We will provide appropriate support, guidance and monitoring to tackle any reported issue. Serious or repeated violations may result in a termination of supply, reduced volume of business or non-inclusion in future tender opportunities
Annual training for key stakeholders within Zenith
A procurement policy incorporating pre-contractual supplier due diligence, comprehensive contractual agreements and periodic review
Supplier Code of Conduct
Annual risk assessment of the supply chain
Whistleblowing procedures within Zenith and contractual requirement for direct suppliers to monitor compliance and report any matters of concern
We assess risk in our supply chain through consultations with relevant internal stakeholders. Risk factors include: the location of the supplier, the nature / type of the goods or services provided, the level of control we have over the supplier, our perception of the supplier’s level of corporate governance - both in relation to its own activities and its supply chain.
Following this consultation process we have assessed our exposure to the risk of slavery and human trafficking as low for the following reasons:
We are entirely UK based.
Almost all of our direct suppliers have strong levels of corporate governance and are based in countries where slavery and human trafficking are low risk.
We perceive our greatest exposure to risk (albeit still limited) is further down our supply chains – broadly where workers receive low pay for low skill work, or where raw materials and manufacturing originate in high risk countries. Activities further down our supply chain are out of our direct control.
In response to press reports of forced labour in certain Indian mines which produce mica, a mineral which is used in the car paint industry, we conducted an investigation. Whilst we do not contract directly with car paint manufacturers, in one example we were able to obtain, from our direct supplier, assurance from a particular car paint manufacturer that the mica used in their paint was not sourced from the identified mines. Other manufacturers provided evidence of strong governance controls.
Concerns have also been expressed in the press regarding potential modern slavery in UK car wash operations. Zenith conducted an internal review and concluded that its direct supply chain undertakes this work in-house, for reasons of quality assurance, and does not utilise external car wash operations most likely to be affected.
Our due diligence processes
Our supply-chain due diligence processes are proportionate to the level of assessed risk and the level of control or influence we have in each relationship.
Where we take on a new supplier to our operational businesses we require them to respond to our pre-contractual due diligence questionnaire which specifically addresses slavery and human trafficking. All such new suppliers will also be required to agree to our Code of Conduct.
We are continuing to refresh the due diligence on our existing suppliers to our operational businesses. Our Supplier Code of Conduct has also been launched, as detailed further below.
We have delivered our first modern slavery and human trafficking classroom training session for key internal stakeholders. The session analysed modern slavery developments within the UK, with a particular focus on the automotive and fleet industries. This session will be refreshed and delivered by our Compliance Officer every year.
Our effectiveness in combating slavery and human trafficking
We have instigated and concluded the two reviews detailed above, and are satisfied that our direct supply chain has no involvement in the alleged activities. We nevertheless remain vigilant.
Our Supplier Code of Conduct has already been launched to our direct high spend suppliers, who account for approximately 50% of total spend by our operational businesses. Work continues to launch the Code across the remaining such suppliers.
This Statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and has been approved by the Board of Directors.
Chief Financial Officer