IM Group (IMG (UK) Holdings Limited and its subsidiary
entities) recognises that the potential for modern slavery exists in many
sectors, and we must do everything we can to prevent any form of slavery, human
trafficking, or any other unethical behaviour.
We are dedicated to developing, implementing, and enforcing
effective systems and controls to ensure that we address the threat of modern
slavery within our business and in our supply chains.
We have zero-tolerance for slavery and human trafficking,
and we expect our supply chains to take the same stance.
This statement is IM Group’s seventh modern slavery
statement. It sets out the steps that IM Group and its subsidiary companies
have taken during the financial year ending December 2023 to combat slavery and
human trafficking in our business and supply chains.
Link as seen in Figure 1.
List of Active & Dormant Companies | IM Group
Our Business And Supply Chain
IM Group is a large, family owned, international company
established in 1977. The Group operates a diverse portfolio of companies in the
automotive, property and finance sectors. Our specialist independent, exporter
expertise and local market knowledge is used to support our business partners
to achieve our Modern slavery goals. Our head office is in Solihull with other
offices in the UK, Ireland, USA, China, Baltics and Nordic countries.
Employees:
Suppliers
Through our diverse business portfolio, we procure a wide
range of goods and services. Our core businesses each have a specific supply
chain footprint with different characteristics, challenges and opportunities.
We have mapped our suppliers in rank to high/medium/low risk
which enable us to prioritise our actions as below.
Governance
The IM Group board and the management board is made up of
the Chairman, Executive Director and Management Directors of IM Group’s
automobile and property businesses. Regular contribution to these quarterly
meetings is from HR, ESG, IT, Finance, Tax, Legal and Litigation teams.
Our compliance department works alongside the business
development team and property teams to design and implement our modern slavery
strategy in all our locations. The Director of Compliance who is part of the
ESG committee, reports to the board.
The Board has established an Environmental, Social and
Governance (ESG) committee that provides direction on the group’s long-term
approach to ESG, monitoring developments in this space and provides oversight
and support to the Board on the potential risk for modern slavery and our
approach. The ESG Committee is made up of MD’s, Senior Directors, HR and
Communications team members. The committee meet quarterly, and formal minutes
are taken.
Policies
We have developed global and local policies and practices to
set consistent standards throughout our operations and those most relevant to
Modern Slavery are:
• Business Code of Conduct Policy
• Supplier Code of Conduct
• Modern Slavery Policy
• Whistleblowing Policy
• Equality, Diversity, and
Inclusion Policy
• Anti-Bribery & Corruption
Policy
• HR policies relating to
employment including Grievance.
Our policy statements can be found here:
Modern Slavery Statement End of Year December 2022
Bribery & Corruption Policy Statement
Whistleblowing Policy Statement
Equality, Diversity, & Inclusion Policy Statement
The IM Group Modern Slavery policy reflects our
zero-tolerance approach to modern slavery in our business and our supply chains
and our long-standing commitment to:
• Acting ethically and with integrity in all our
business dealings and relationships.
·
Implementing effective systems and controls to
enable IM Group to identify, mitigate, address, and remediate any concern of
modern slavery or labour exploitation within our own business’ or that of our
supply chain.
• Ensuring that there is
transparency in our business and in our approach to tackling modern slavery
that is consistent with our disclosure obligations under the Modern Slavery Act
2015
• Encouraging openness and
providing support to anyone who raises concerns relating to Modern Slavery.
• Continue to promote awareness
with employees and across our supply chain and monitor performance to ensure
that the people we hire or who work in our supply chain are respected and are
free to work in an environment free from modern slavery or labour exploitation.
The standards align to the
principles of the Ethical Trading Initiative (ETI Base Code):
• Employment is freely chosen
• Freedom of association &
the right to collective bargaining are respected
• Working conditions are safe
& hygienic
• Child labour shall not be used
• Living wages are paid
• Working hours are not excessive
• No discrimination is practiced
• Regular employment is provided
• No harsh or inhumane treatment
is allowed
Whistleblowing
All employees are encouraged to be vigilant to unethical
practices and report concerns with regards to Modern Slavery and Labour
Exploitation. All allegations and concerns will be taken seriously. Action will
be taken to investigate any breaches of our policies. Our Modern Slavery Policy
found here confirms that our employees and supply chain partners have a
personal responsibility to report any actual or suspected instances of modern
slavery within our business or in our supply chain.
• Suspected instances of modern slavery must be reported to
an individual’s line manager (in the case of employees) and a member of the IMG
HR team at The Gate, HQ.
• Our policies are communicated internally via our
SharePoint policy section and externally via our website and issued, where
appropriate with contracts and terms and conditions. Suppliers and contractors
are informed of a number to call to whistle blow for any concerns, the number
is available within documents and on posters and TV screens in publicly
accessible places including building site washroom facilities and as part of
site induction process.
• IM policies are signed off by the Executive Director and
senior management on behalf of the Board and are reviewed on a regular rolling
basis.
• We have focused on the building sites and manual labour,
along with factories that manufacture parts for our automobile division as we
know that these present the highest human rights risks and are therefore a key
part in targeting our modern slavery programme effectively.
• All reports are treated confidentially, and we have
protection in place for those reporting with a genuine matter.
Due Diligence
Suppliers are asked to confirm their acceptance of our
approach to modern slavery. Our standard contract includes a contractual
obligation to comply with our clauses relating to the Modern Slavery policy. In
this way we explain that we do not tolerate slavery or human trafficking and
our suppliers are asked to confirm that they take the same approach in their
businesses and in their supply chain. As part of onboarding for all new
suppliers within the business, our due diligence process includes consideration
of suppliers Ethical and Environmental Practices and seek to identify potential
risk in the suppliers supply chain; this includes Modern Slavery. Suppliers for
Goods and Services are required, as part of the onboarding process, to confirm
that they will abide in their business to our policy in respect of Human
Rights.
For supplier management, we have a contract management
system facilitated by the Compliance department for the automobile and central
group sector of IM Group. Within the property business the commercial teams
have responsibility for ensuring compliance with our Modern Slavery policy.
In conjunction with our internal Supplier Code of Conduct
procedure and due diligence, we have implemented a modern slavery and human
trafficking process setting out the minimum labour standards that we require
from all members of our supply chain.
IM Group fosters long-term working relationships with its
supply chain members. Our commercial teams regularly engage with their supply
chain partners and the business development team to enable due diligence and
any remediation needed. We regularly assess our supply chain and conduct desk
top analysis that leads to enhanced checks. Teams regularly visit suppliers on
the ground and in factories where they try to engage with the workforce and
access the work environment. We ensure visits are conducted by different parts
of the business to enable the relationship and standards to remain professional
and ensure the ethical credentials are maintained.
In addition to our supply chain mapping, we evaluated the
nature and extent of our exposure to the risk of modern slavery occurring in
our supply chain by conducting a detailed slavery and human trafficking risk
assessment. We worked with Slave Free Alliance to identify high risk areas of
our business to focus on enhanced due diligence and to build capacity in those
areas identified as higher risk where individuals are more likely to be
vulnerable.
Where the assessment highlighted high-risk suppliers within
the supply chain, for example based on industry, location, employee
demographic, recruitment parameters etc…, enhanced due diligence protocol is
implemented, including:
• Where we identify instances where we are procuring
materials directly from countries on the Global Slavery Index, we will engage
with one of our internal or external auditors to carry out a satisfactory
ethical audit review prior to making an order. If other issues are identified,
appropriate investigative and remedial action is taken; and
• We have focused training for parts of the business
identified as more likely to encounter modern slavery and labour exploitation
and providing them with the upskilling to identify and escalate any concerns.
We understand that risk assessments are a snapshot in time
and do not replace our own continuing due diligence.
Risk Assessment and Management
IM Group, through its subsidiary companies directly and
indirectly, purchase products, materials, services, and labour from a diverse
portfolio of suppliers, distributors, labour agencies and professional service
suppliers. Our supply chain is complex, with multiple tiers stretching across
the globe. We have a broad range of suppliers both in size and in terms of the
products and services provided.
Identification
We consider that our most significant modern slavery risks
are in our supply chains where we undertake procurement activities and where
operations and managerial oversight are out of our direct control. This may be
due to manufacturers where we have minimal influence over, where we have
limited visibility of the workforce and where there is temporary labour hire.
Our procedures are designed to establish and assess areas of potential risk in
our business and supply chains. To monitor those identified to enable us to
reduce the risk of slavery and human trafficking occurring in our business and
supply chains and protect those who are vulnerable to modern slavery and labour
exploitation.
Some examples of the key supply chain risks that we have
identified are as follows:
• Complex supply chains with multiple tiers: the risk of
forced labour is the highest in lower tiers where IM group have little
visibility.
• Risk of indirect procurement of materials for our projects
which are at higher risk of being
produced by child labour or forced labour, for which we have
littler oversite/control.
• Employment issues included but not limited to Heath &
Safety concerns, significant use of agency workers, temporary workers and
migrant workers by our supply chain.
Effectiveness
We also continue to work with Slave-Free Alliance to
facilitate training for our staff and to ensure best practice is established
within our businesses.
We Partner With:
Founded in 2003, Grace Foundation is funded by IM Group. It
exists to transform young people’s lives through holistic education
experiences. Employees work closely with Grace Foundation through school
engagement programmes to enhance students’ personal development, wellbeing and
career aspirations. https://www.grace-foundation.org.uk/
The Heart of England Community Foundation exists to support
local giving and community investment across the West Midlands and
Warwickshire. The Fund supports our social value initiatives by administering
our company and project specific Community Funds.