Introduction
We are committed to constantly reviewing our employment practices, and the activities of our supply chain and ensuring compliance with the obligations under the Modern Slavery Act 2015. This statement sets out the policies and practices within our business that provide a framework aimed at ensuring our compliance to the requirements of the Act.
This statement refers to our primary review against the implementation of the Act and sets out certain actions that took place during the current financial year (2023/24.) We have also set out actions we intend to take in the next financial year to improve our position.
Our organisation and principal activities
Established in the United Kingdom by the initial acquisition of Universal Salvage Limited in 2007, the principal activity of Copart UK Limited is the provision of vehicle remarketing services to the UK insurance and automotive industries. The company provides sellers access through its online daily auctions to an active and geographically diverse buyer base, ensuring market value is achieved for vehicles sold. The company only operates in the UK and ROI.
Responsibilities
The HR Director has responsibility to ensure that all the company’s policies and procedures are up to date and properly meet the requirements that the policy is designed for. Such reviews are conducted annually as a minimum.
The Senior Leadership Team will review its approach to human rights and modern slavery annually to ensure that no changes have taken place that may have impacted upon its initial risk assessment.
Risk Assessment
During the 2015/16 business year the Senior Leadership Team led a review of the legislation and completed a risk assessment against our activities and concluded that in general the company does not have any area subject to high risk within the definition of the Act. The company believes that its review and this statement are proportionate to the identified generally low risk to modern slavery as described within the Act and consider its original review does not require amendment.
The Company’s Values are an integral part of the way the company operates and provides a framework that ensures that the behaviour of our employees meets or exceeds the minimum requirements set out in active employee related legislation. When necessary, the company will invoke its Disciplinary Policy & Procedure to ensure that its Values remain an integral part of its culture.
Due Diligence
Given the low risk the company has assessed itself as, and the type of operation the company conducts, we believe that its existing commercial due diligence practices are sufficient to ensure continual compliance to the requirements of the Act. This position will form part of its annual review process.
Our Policies & Procedures
The company has a number of relevant policies that will support its efforts to ensure compliance to the Act.
- Whistleblowing policy. The company encourages all its workers, customers, and other business partners to report any concerns related to their direct activities, or our supply chain. 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 very easy for workers to make disclosures, without fear of retaliation, by using its completely anonymous hotline. The hotline is well published to employees through our Employee Handbook, notice board posters and flyers.
- Employee Handbook. The company’s Employee Handbook makes it clear to all 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.
- Pay & Benefits. The company is committed to ensuring all employees receive pay and benefits that meet national standards. We pride ourselves on being an accredited Real Living Wage employer and review salaries regularly and at least once a year. All employees have access to see information on their pay and benefits. The company is committed to equal pay and benefits for men and women for work of equal value.
- Recruitment activity. The company primarily source potential candidates for employment through an online portal, as well as, when necessary, reputable employment agencies to source labour and will always verify the practices of any new agency it is using before accepting workers from that agency. When entering into a contract with any new agency the company would apply its Contract Approval Policy.
- Contract Approval Policy. The company is committed to ensuring that its suppliers adhere to the highest standards of ethics. The company will only work with reputable suppliers to ensure they meet the standards required. When a new supplier is identified, the company has a Contract Approval Policy where all contracts are verified by the company’s legal team and assurances received that the supplier meets the requirements of the legislation. The company already has a model contract which has been updated to include a requirement to agree compliance to the requirements of the Modern Slavery Act. Any identified violations of the legislation could lead to the termination of the suppliers’ relationship with the company.
- Corporate Social Responsibility Policy. The company has a Corporate Social Responsibility Policy that sets out its approach to continually improve upon our responsibilities to our business partners and employees, and continually reaffirms our desire to act in a responsible way and improve our performance in meeting legislative requirements and more. As part of its annual review, the policies listed above, and any other relevant policies will be reviewed and updated to ensure they include reference to and adequately ensure compliance with the requirements of all relevant legislation. These are available to all colleagues through our My Copart shared drive.
Employee Awareness & Management Training
New employees are made aware of the key aspects of the legislation upon joining the company, as well as understanding what they should do if they believe a supplier to the company is working in a way that could be considered as slavery.
All the company’s management team have been made aware of the obligations within the Act, the due diligence process the Senior Leadership Team have conducted and the actions required of all our managers to ensure that we comply with the requirements of the Act and that any suppliers who work with or for any manager is properly reviewed to ensure their compliance with the Act.
This Policy Statement will be reviewed annually and updated, as necessary.
On behalf of the board,
Jane Pocock
CEO UK & Ireland
Date: November 2nd, 2023