The Modern Slavery Act 2015
The Modern Slavery Act 2015 came into effect on 29th October 2015. This law requires manufacturers and retailers doing business in the UK which supply goods or services, who exceed the turnover threshold, to disclose information regarding their policies to eliminate slavery and human trafficking from their supply chain and within their business.
MBNI Truck & Van is a business that operates as a Mercedes-Benz Commercial Vehicle Dealership (MBNI Truck & Van). We have two sites across the UK – Belfast and Dungannon delivering a one stop shop for Sales, Repairs, Parts & Servicing to help manage the whole life of your Mercedes Van or Truck.
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 and
to implementing and enforcing effective systems and controls to ensure modern
slavery is not taking place anywhere in our own business or in any of our
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.
This policy does not form part of any employee's contract of employment and we may amend it at any time.
This policy allows for the following provisions:
- Freedom of workers to terminate employment
- Freedom of movement
- Freedom of association
- Prohibits any threat of violence, harassment and intimidation
- Prohibits child labour
- Prohibits discrimination
- Prohibits confiscation of workers’ original identification documents
The Mercedes-Benz UK Companies maintain written policies that strictly prohibit the use of slavery or human trafficking in their direct supply chains. These include the Mercedes-Benz UK Companies’ brochure entitled “Ethical Business – Our Shared Responsibility” in which they communicate their ethical principles and associated expectations to their supply chain. Their supplier code of conduct requires all suppliers to Mercedes-Benz UK Companies, to sign up to a sustainability clause which details all requirements around forced labour, slavery and human trafficking.
MBNI Truck & Van are committed to maintaining the highest ethical standards across our supply chains. The detection and prevention of modern slavery is the responsibility of those working for the Company or in association with the Company.
To achieve these standards, MBNI Truck & Van will ensure that:
- All our employees are made aware of the basic principles of the Modern Slavery Act 2015
- All new starters are trained on the risks our business faces in our supply chains
- All suppliers, contractors and business partners are aware of our zero-tolerance approach to modern slavery at the outset of our business relationship with them
Responsibility for the Policy
The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Human Resources Department has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Line managers 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.
The Company operates using the following internal policies to prevent slavery and human trafficking in its operations. These describe our approach to the identification of modern slavery risks.
- Whistleblowing policy: The Company has a whistleblowing policy in place to encourage all its workers, customers and all business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise in relation to slavery or human trafficking. The Company's whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact the Dealer Principal directly.
- Employee code of conduct: The Company's code makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour both when representing the business at all times and managing its supply chain. It is important that a new employee to the Company is provided with as much information as is reasonably practical to enable them to settle in and find their feet as soon as possible. At MBNI Truck & Van, all new starters are inducted and trained on the rules and procedures that clarify how they should treat fellow employees. The aim of this is to ensure harmony and respect amongst individuals and to promote good working practices. The Company recognises our legal obligation and will not tolerate acts which breach our policies. In all incidents, breaches will be investigated and if necessary suitable disciplinary action will be taken.
- Company Code of Conduct: We offer an environment which is free from harassment and unlawful discrimination. We ensure our working practices are in accordance with all relevant employment legislation including the Equality Act 2010, Protection from Harassment Act 1997 and the Health and Safety at work act 1974. We also allow all employees the right to join a trade union of their choice.
As part of the Mercedes-Benz UK commercial dealer franchise, MBNI Truck & Van ensure our employees continuously develop via on-line and face to face training to emphasise the importance of acting with integrity in line with Mercedes-Benz Ltd own internal Ethical Business Code.
MBNI Truck & Van focus on ensuring our management team understand the business requirements of the Modern Slavery Act 2015 and teach them how to address concerns raised by their team and/or any suppliers. Managers have undertaken some awareness training and this has been communicated to staff via weekly staff briefings and internal communications. This is an ongoing diligence process.
All persons working for us or on our behalf in any capacity must:
- Read, understand and comply with this policy, and avoid any activity that might lead to, or suggest, a breach of this policy.
- Notify their immediate manager as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future.
- 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.
Breaches of Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.
We will review and audit our Supply Chains, External Operations and Internal Operations on an ongoing basis to check compliance with the above policy, and to check that our policy is being implemented effectively.
This statement has been approved by the Company's Managing Director, who will review and update it annually.
Managing Director MBNI Truck & Van
Date: March 2021