Introduction

 ‘Modern Slavery’ includes slavery, servitude, forced and compulsory labour, human trafficking and human exploitation.

Optare Plc, is part of the Hinduja Group as parent company.  Optare recognises the responsibility it has to take a robust approach and the organisation is absolutely committed to making sure that Modern Slavery is not taking place anywhere within its organisation, nor in any of its supply chains.

This statement applies to financial year ending on or after 1 April 2021.

Organisational structure

This statement covers the activities of Optare, in particular, the activities of manufacture, engineering, procurement and aftermarket. Our business includes a manufacturing site in Sherburn in Elmet, West Yorkshire and we have three Service Centres (Thurrock, Manchester and Rotherham).

Our supply chains include the procurement (sourcing and negotiation) and purchase of automotive components sourced from a range of Global businesses.

Relevant policies

The organisation operates the following that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy

The organisation 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.

• Business Ethics Policy

The organisation 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 and managing its supply chain.

• Supplier/Procurement agreements

The organisation is committed to ensuring that its suppliers adhere to the Modern Slavery Act. Suppliers are required to demonstrate that they provide safe working conditions where necessary.  Serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.

• Recruitment/Agency workers agreements

The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

• Reviewing on a regular basis subcontract terms and conditions
• Completion of Supplier Enlistment Form
• List of Approved Vendors
• Compliance of HMRC and Immigration regulations for all UK based workers

Training

The organisation requires relevant managers/professionals within the organisation to complete awareness updates on modern slavery.

This covers:

•   How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
•   How to identify the signs of slavery and human trafficking;
•   What initial steps should be taken if slavery or human trafficking is suspected;
•   How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
•   What steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

Awareness

The organisation will also raise awareness of modern slavery issues to staff, via the team briefing cascade and provide guidance on:

•   The basic principles of the Modern Slavery Act 2015;
•   How employees can identify and prevent slavery and human trafficking;
•   What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
•   External help available, for example the Modern Slavery Helpline.

Actions in 2019/20

Members of our Senior Leadership Team actively involved in the Governance (application and continuous monitoring) of this policy statement.

• Audit and compliance – Quality
• Legal – People Development and Finance
• Supply and Procurement – Design Engineering and Procurement
• Commercial – Sales

Going forward

• Group Policies updated to support the Modern Slavery Statement, including Whistleblowing Policy and Business Ethics Policy
• Anti-Slavery and Human Trafficking Policy created to support the Modern Slavery Statement
• Provide accessible support and advice on the intranet with links to websites and videos, via Stronger Together, Supply Chain Sustainability School and GLAA.
• Provide online training for relevant managers
• Revise provision of labour contracts to include key policies, including the Anti-Slavery and Human Trafficking Policy as appendices to the contract.

Board approval

This statement has been approved by the organisation’s board of directors, who will review and update it annually.

Signature:

Name:    Dr Andrew Palmer CMG                                     Date: March 2021

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 financial year ending March 2018.