Modern slavery and human trafficking statement

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE YEAR ENDING MARCH 2021

1. This is IM Group’s fourth annual Modern Slavery and Human Trafficking Statement made pursuant to section 54.1 of the Modern Slavery Act 2015 for the year ending March 2021. It is made on behalf of all companies within IM Group. A list of the main companies within IM Group is set out in Appendix 1. This statement sets out the steps IM Group have taken and will take during this financial year to ensure that slavery and human trafficking is not taking place in any of our supply chains or in any part of our business and it also addresses those other matters set out in the Home Office statutory guidance.

IM Group is an active member of the Slave Free Alliance.


2. Structure and Supply Chains

IM Group, as the above diagram shows, embraces three core functions; property, automotive importation and finance. The activities undertaken by the relevant subsidiaries in these areas are complex and involve supply chains which in some instances stretch literally around the globe.


3. IM Group's policy in relation to modern slavery and human trafficking

IM Group is committed to opposing modern slavery in all its many forms and preventing it occurring either in our business or in our supply chains.
Our Chairman Lord Edmiston who supported the Modern Slavery Act from the government benches of the House of Lords has said this: "There are over 20 million people worldwide who are victims of involuntary servitude or compulsory labour. This is, therefore, not a problem which can be solved overnight but nor is it one which can be ignored. The Modern Slavery Act is an important step in the process and I have committed IM Group not just to be compliant with the Statute but to go beyond the minimum required and to try wherever we can assist in the elimination of these evil practices"

IM Group's policy in relation to modern slavery and human trafficking is accordingly one informed by its Chairman's deeply held beliefs and convictions: it is, therefore, to ensure that its business and suppliers do not directly or indirectly engage in practices which are prohibited by the Modern Slavery Act.


4. IM Group's due diligence procedures in relation to modern slavery and human trafficking in our business and supply chains

We have altered our standard terms of business so as to conclude provision to the following effect:

X agrees to use its best effort to ensure that neither it nor any of its subcontractors, vendors, agents or other associated third parties will utilize child, slave, prisoner or any other form of forced or involuntary labour, or engage in abusive employment or corrupt business practices or engage in any activity which constitutes an offence under any applicable laws in the countries in which it will manufacture the Goods/provide the Services which are the subject of this Agreement.

X agrees to use its best effort to comply with all applicable anti-corruption laws in the countries in which it will manufacture the Goods/provide the Services, and to ensure that neither it nor any of its subcontractors, vendors, agents or other associated third parties will engage in any form of commercial bribery, nor directly or indirectly provide or offer to provide, anything of value to or for the benefit of, any official or employee of a governmental authority or of any government-owned, government-controlled or government-affiliated entity to obtain or retain any contract, business opportunity or other business benefit, or to influence any act or decision of that person in his/her official capacity.

In case of non-compliance with the provisions of this Article by either party, the other party may terminate this Agreement in accordance with Article X under this Agreement.


5. Risk Assessment: The parts of our business and supply chains where there is a risk of modern and human trafficking taking place and the steps we have taken to assess and manage that risk

Before entering into any new agreement for the supply of any service or product we make an assessment – using a detailed schedule of criteria – as to whether the supplier is engaged in prohibited practices and we only enter into an agreement with that supplier if that assessment is positive.


6. Measuring Effectiveness: Our effectiveness in ensuring that modern slavery and human trafficking are not taking place in our business or in our supply chains


After 4 years of vigilance in this area we are confident that our business and supply chains are clear of any prohibited practices


7. Training for Staff: IM Group's staff training programme in relation to modern slavery and human trafficking

All senior staff have received a briefing with regard to the Modern Slavery Act as well as background material relating to the practices which are now prohibited by the Act. The staff will also receive during the course of this year in depth training with regard to:

a) Identifying prohibited practices.

b) What steps to take if any prohibited practices identified or suspected by them anywhere within our business or supply chain.

March 2021 – Approved by the IM Group Board of Directors

Gary Hutton
Executive Director

Annex 1 – The principal corporate entities operating within IM Group are set out below. Please note that this list is not all inclusive and this Statement relates to all companies which form part of IM Group whether or not they are currently trading and active and whether or not they are included in the list below.

Name of Entity Country Division
I.M. Group Limited England Parent
I.M. Facilities Limited England Automotive
International Motors Limited England Automotive
Subaru (UK) Limited England Automotive
Isuzu (UK) Limited England Automotive
I.M. Parts and Service Limited England Automotive
Daihatsu Vehicle Distributors Limited England Automotive
I.M. Trade Assist Limited England Automotive
Great Wall Motor Distributors (UK) Limited England Automotive
I.M. Insurance Limited Guernsey Insurance
International Motors Finance Limited (49%) England Automotive
I.M. Automotive Limited Ireland Automotive
I.M. European Motors Limited Ireland Automotive
I.M. Properties PLC England Property
I.M. Properties (Coleshill) Limited England Property
I.M. Properties Development Limited England Property
Spitfire Bespoke Homes Limited England Property
Specialist Motor Finance Limited England Finance
The Funding Corporation Limited England Finance
IMP Residential Capital Markets Limited England Property
IMP Investments HSBC Limited England Property
IM Properties Investments HSBC 2 Limited England Property
IMP Investments RBS Limited England Property
WATAD (UK) Properties Limited England Property
IMP Investments RBS 2 Limited England Property
IM Land 1 Limited England Property
IM Land 3 Limited England Property
IM Properties Strategic Land Group Limited England Property
IM Land 4 Limited England Property
IMP Hill Top Estates Limited England Property
IMP Investments LGB Limited England Property
IMP Investments SHB Limited England Property
IMP Investments Ltd England Property
Spitfire Properties (Newhall) Limited England Property
IM Properties (BVP 3) Limited England Property
IMP Development Management Limited England Property
IM. Land 2 Limited England Property
IMP Residential 2 Limited England Property
Specialist Motor Finance Services Limited England Financial
Specialist Motor Finance Group Limited England Financial
I.M. UK Trade Company Limited England Automotive
I.M. Properties (BVP 1) Limited England Property
International Motors Parts & Service Limited England Automotive
KVD Limited England Automotive
I.M. Holdings Limited England Property
I.M Financial Services Limited England Financial
I.M. Funding Limited England Financial
I.M. Finance Limited England Financial
Ensleigh Property Management Company Limited England Property
I.M. Group (Ensleigh) Limited England Property
I.M Properties Birmingham Development Limited England Property
I.M. Distribution Limited England Automotive
Mahindra Car Distributors (UK) Limited England Automotive
I.M. Equipment Limited England Automotive
I.M. Aviation Limited England Automotive
I.M. Properties (Croydon) Limited England Property
I.M. Properties (Milton Keynes) Limited England Property
Great Wall Motor Company Limited England Automotive
The Funding Corporation Group Limited England Financial
I.M. Properties (Dordon 2) Limited England Property
I.M. Properties (Logistics) Limited England Property
I.M. Properties Estates Limited England Property
I.M. Properties (Reading 2) Limited England Property
I.M. Property Trading Limited England Property
I M Properties (SHB) Limited England Property
I.M. Properties (Bristan) Limited England Property
I.M. Properties (Mell Square 1) Limited England Property
I.M Properties (BVP 2) Limited England Property
The Funding Corporation (1) Limited England Financial
The Funding Corporation (2) Limited England Financial
Cygnet Financial Services Limited England Financial
ACF Car Finance Limited England Financial
I.M. Properties (WHB) Limited England Property
Yorkshire Property Holdings Limited England Property
I.M. Properties (Guildford 2) Limited England Property
IM Properties (Magna Park) Limited England Property
I.M. Properties (Maidenhead) Limited England Property
I.M Assured Growth and Exit Plc England Property
I.M. Property Holdings Limited England Property
First Residential Investment Limited England Property
I.M. Properties (Longton) Limited England Property
I.M. Properties Investment Limited England Property
I.M. Properties Finance Limited England Property
I.M Properties (Birmingham) Limited England Property
I.M. Properties (Abbey) Limited England Property
BVP Residential Management Company Limited England Property
Milcote Close (Welford) Management Company Limited England Property
Brampton Property Development Limited England Property
Greenings (Long Crendon) Management Company Limited England Property
Upper Acres (Ettington) Management Company Limited England Property
Hillcroft (Gretton) Management Company Limited England Property
Ashwood (Hockley Heath) Management Company Limited England Property
Haseley Manor Management Company Limited England Property
Highworth (Broadway) Management Company Limited England Property
Regents Green (Leamington Spa) Estate Management Company Limited England Property
Green Gates (Maidenhead) Management Company Limited England Property
Spitfire Homes Holdings Limited England Property
St Marks Gate Management Company Limited England Property