IMO CAR WASH GROUP LIMITED
ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT
IMO structure and business
We are a developer and operator of car wash sites in Europe and Australia. Our ultimate parent company is International Car Wash Group Ltd, whose head office is in the United Kingdom. We have over 800 employees worldwide.
Our business is organised into over 700 operating sites across Europe. We have a global annual turnover of £206 million.
The senior management team comprises: Mike Smith, Executive Chairman; Jonathan Booth, Deputy CEO; Nilesh Pandya, CFO.
Our supply chains
Our supply chains include self-employed car wash operators, chemical and equipment suppliers, maintenance contractors and brush manufacturers.
We expect organisations and individuals from whom we procure products and services and other companies we engage with to ensure their goods, materials and labour related supply chains:
- Fully comply with the Modern Slavery Act 2015; and are
- Transparent, accountable and auditable; and are
- Free from ethical ambiguities
Individuals with evidence of non-compliance with the Modern Slavery Act in connection with our supply chains are encouraged to follow the reporting procedure outlined in our Whistleblowing Policy.
Our policy on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Due diligence processes for slavery and human trafficking
We have in place arrangements to:
- Identify and assess potential risk areas in our supply chains
- Mitigate the risk of slavery and human trafficking occurring in our supply chains
- Monitor potential risk areas in our supply chains
- Protect whistle blowers
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure all contractors and those in our supply chain comply with our values we have in place supply chain overview processes managed by the relevant cross-functional representatives from the following departments:
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will provide training to relevant staff during their induction training. All Directors have been briefed on the subject.
Our effectiveness in combating slavery and human trafficking
- Agreed responsibilities for this policy and statement and received unanimous support from our Senior Management team.
- Given responsibility and awareness training to members of staff who manage our relationships with our supply chain and contractors.
- Raised awareness to key member of staff who regularly interact with our supply chain and contractors.
- Incorporated the Anti-Slavery and Human Trafficking Policy in our standard set of Company policies and as part of our induction programme for all new employees.
- Seek to impose in new contracts that we enter into provisions for termination in the event of a modern slavery or human trafficking compliance breach by suppliers or contractors. This may be structured to cover termination for breach of any law.
- Act promptly when a compliance breach has been identified.
- Prepare the statement on an annual basis.
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 31 December 2018.