Slavery and Human Trafficking Statement
This statement is
made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”). and
constitutes our slavery and human trafficking statement for the financial year
ending 31st March 2025 (“FY2024”).
Our company
Norton Way Motors
Ltd (the “Company”) is owned by Marubeni Auto Investment and Marubeni Europe
plc who in turn is a wholly-owned subsidiary of Marubeni Corporation, one of
Japan’s largest trading and investment companies. The Company is headquartered
in Letchworth Garden City, Hertfordshire.
The Company is a
Multi Franchise Motor Dealer Group operating in the UK.
We supply New
& Used vehicles into both the Retail and Commercial sectors. We also
provide Servicing, Bodyshop facilities & Parts Provision.
Our principles
and values
It is the
Company’s policy that management and employees must comply with the highest
standards of business and ethical conduct in all dealings with customers,
suppliers, government officials and the wider community.
The Company’s
core values, in common with all companies in the Marubeni Group, are fairness,
innovation and harmony.
Our supply
chains
The Company
operates in partnership with seven Global Motor Franchise Partners as an
authorised franchisee.
We also sell the
products directly to the customer, Business to Business or through a
distributor network. We provide services including Finance and the sale of
General Insurance products and we are fully authorised by the Financial Conduct
Authority (FCA).
Relevant
policies
The Company is
committed to taking steps where reasonably practicable to ensure that modern
slavery is not taking place in any part of its own business or in any of its
supply chains.
We would also
draw attention to the Basic Supply Chain Sustainability Policy of our parent
company Marubeni Corporation, established in October 2008 (and subsequently
amended).
In January 2019,
Marubeni Corporation published the Basic Policy for Human Rights which sets our
commitments based on the UN’s Governing Principles on Business and Human
Rights.
Other relevant
policies of the Company are its Anti-Corruption Policy and its Business Conduct
Policy.
The modern
slavery risks
Adopting the
Modern Slavery Policy was a first step towards the Company having in place
systems to:
- identify
and assess potential risk areas in our supply chains;
- mitigate
the risk of slavery and human trafficking occurring in our supply chains;
and
- monitor
potential risk areas in our supply chains.
We recognised
that modern slavery may exist to a greater or lesser extent in most, if not all
countries and in most industries. Given the diverse range of our business
activities and the number of countries into which our supply chains extend, it
would be reasonable to assume that the Company must therefore be at risk in
respect of modern slavery to some extent.
Marubeni
Corporation distributed guidelines to relevant group companies to assist them
in efforts towards the prevention of human rights violations in their own
businesses and in their supply chains.
Having considered
these guidelines, the Company has established a methodology for the assessment
of risk of human rights violations. Whilst we have no information to suggest
that modern slavery exists in any of our supply chains, our initial analysis
suggests that certain businesses or product lines may represent a higher degree
of risk, and accordingly may require more detailed analysis and investigation.
Specific steps
already taken
- Held a
training Seminar with the Leadership Team to inform them of the
information.
- Circulated
training literature to staff & continue to update all staff on the
subject & encourage them to use the Modern Slavery Helpline if
required.
- Our
Modern Slavery Statement & Policy has been sent to our suppliers.
- We
continue to attend seminars held by stronger2together.org
- We
receive regular updates from the Office of the Anti-Slavery Commissioner
& utilise information & data from the Anti-Slavery Partnership
toolkit.
- We
prepare & deliver regular training for all members of staff.
- We
continue to look for innovative ways to heighten the awareness of the
Modern Slavery risk within our Company.
In driving the
performance of the business
Individual
contracts very often contain performance and delivery conditions. However, our
initial review would suggest that we have not established, in respect of any
particular supply chain or business and whether for internal use or for our
suppliers, any formal performance incentives or indicators of the type that may
unintentionally increase pressure on those who are producing the goods to a
level which might in turn create an environment where acceptable labour
standards are compromised.
Internal
organisation in relation to modern slavery
We have a
dedicated Team (representing HR, Finance and Commercial Operations) that report
to the Managing Director, who have overall responsibility for the Company's
response to the challenge of slavery and human trafficking and, in accordance
with the requirements of the Act, has signed this Statement below.
Effectiveness
As a result of
the steps taken, we are confident that the risks of modern slavery taking place
in our business or supply chains are now significantly reduced.
This Statement
relates to the Company’s financial year ended 31 March 2025.
