This statement sets out Hodgson Newcastle Limited'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 our statement and Anti-slavery Policy is consistent with our obligations under the Modern Slavery Act 2015 and reflects there is no slavery or human trafficking in its own business and its supply chains.
As part of the motor industry, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
Organisational structure and supply chains
Hodgson Newcastle Limited is a family business that started in 1959 our reputation for honesty, integrity, trust and fulfilling promises has remained at the heart of all we do. We are as committed and focused today on providing the North East with the very best, state of the art vehicles for social and domestic use.
We operate in the North East of England, we have two main sites and a Pre Delivery Inspection Centre. We sell, promote and deliver branded motor vehicles. Mazda, Suzuki and Toyota.
The Managing director and Senior Management team have overall responsibility for ensuring this policy is complaint with the Modern Slavery Act 2015 including legal and ethical obligations.
The automotive supply chain is one of the most complicated of any industry. There are many levels of suppliers between a Tier 1 supplier and. the source of raw materials that enter the manufacturing process.
The breadth and depth of the automotive supply chain make it challenging to effectively manage business and sustainability issues. Respecting human rights and environmental issues in the supply chain is ultimately our suppliers’ responsibility albeit we will take all steps reasonably possible to ensure slavery and human trafficking is not taking place in our supply chain.
Where possible, we build longstanding relationships with local suppliers and make clear our expectations of business behaviour.
With regards to national or international supply chains, we expect these entities to have suitable anti-slavery and human trafficking policies and processes.
Policy on Modern Slavery
Hodgson Newcastle Limited has a zero-tolerance approach to slavery and is committed to preventing acts of slavery and human trafficking from occurring within both its business and supply chain, and imposes those same high standards on its contractors, suppliers and other business partners.
Our Anti-Slavery Policy and statement reflects our commitment to acting ethically and with integrity in all our business relationships to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Due Diligence Processes
We are committed to identifying and assessing potential risk areas in our business and supply chain in order to mitigate the risk of slavery and human trafficking occurring.
Hodgson Newcastle Limited encourages all its workers, customers and other business partners to report any concerns related its direct activities, or those of its supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. We are committed to protecting those who report concerns regarding slavery and human trafficking. Employees, customers or others who have concerns can contact our HR team.
Training for Staff
The organisation will provide relevant training to all relevant staff by November 2019 and to new staff upon induction.
Any employee who breaches our Anti-Slavery policy may face disciplinary action which could result in dismissal. Further to that, we may terminate a business relationship with contractors or organisations should they too breach this policy.
Having reviewed our business and supply chains we are not aware of any instances of slavery or human trafficking. We will continue to monitor this and take action if necessary.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the current financial year 2018/19.
This statement may be changed at any time, without notice and is not part of any employee’s contract.
Mr S Hodgson
Hodgson Newcastle Limited
1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
1.3 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
1.4 This policy does not form part of any employee's contract of employment and we may amend it at any time.
2.Responsibility for the policy
2.1 The Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2.2 The Company’s HR Advisor has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it.
2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
2.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Company’s HR Advisor.
3. Compliance with the policy
3.1 You must ensure that you read, understand and comply with this policy.
3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3.3 You must notify your manager or the Company’s HR Adviser as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or the Company’s HR Advisor or report it in accordance with our Whistle-blowing Policy as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our suppliers to help them address coercive or exploitative work practices in their own business and supply chains.
3.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the Company’s HR Advisor.
3.7 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your line manager or the Company’s HR Advisor immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in our staff handbook.
4. Communication and awareness of this policy
4.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and further training will be provided as and when necessary.
5. Breaches of this policy
5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Mr S Hodgson
Hodgson Newcastle Limited