Modern Slavery Statement

This statement applies to the Steven Eagell Group of Companies (referred to in this statement as ‘the Group’). The information included is made pursuant to the Modern Slavery Act 2015 and refers to the financial year 2021.

Group Structure

Established in Milton Keynes in 2002, the Group has subsequently grown to be the largest Toyota and Lexus dealer group in the UK with a Head Office in Milton Keynes and now operates 44 dealerships across the South East, East of England and the Midlands.

Our official Toyota and Lexus sites offer the full range of sales and after-sales facilities.

The Group is owned and controlled by a Board of four Directors and has approximately 1200 staff employed across its sites. Work is carried out wholly in the United Kingdom.

Our sites are currently located in the following areas:

Lexus:

Birmingham, Cambridge, Canterbury, Gatwick, Hatfield, Ipswich, King’s Lynn, Milton Keynes, Solihull, Southend, Tunbridge Wells and Wolverhampton.

Toyota:

Ashford, Aylesbury, Bedford, Birmingham, Bishops Stortford, Bromsgrove, Canterbury, Cambridge, Chelmsford, Colchester, Gatwick, Hereford, Horsham, Ipswich, King’s Lynn, Letchworth, Luton, Milton Keynes, Northampton, Oxford, Peterborough, Rayleigh, Romford, Solihull, St Albans, St Ives, Stourbridge, Tamworth, Tunbridge Wells, Watford, Wolverhampton and Worcester.

Definitions

The Group considers that modern slavery encompasses:

• human trafficking
• forced work, through mental or physical threat
• being owned or controlled by an employer through mental or physical abuse or the threat of abuse
• being dehumanised, treated as a commodity or being bought or sold as property
• being physically constrained or to have restriction placed on freedom of movement.

Commitment

The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015 and understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Group does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.

Supply Chains

In order to fulfil its activities, the main supply chains of the Group include those related to the supply of motor vehicles from Toyota GB, the supply of various motor vehicle parts and accessories and other business related supplies such as provision of HR support, training, etc. We understand that the Group’s first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.

Potential Exposure

In general, the Group considers its exposure to slavery/human trafficking to be limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any Group that supplies goods and/or services to it.

Our Ongoing Commitment

The Group carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its Group or supply chains, including conducting a review of the controls of three of its suppliers.

The Group has not, to its knowledge, conducted any business with another Group which has been found to have involved itself with modern slavery.

As part of our modern slavery strategy during the next financial year, the Group will continue to monitor the progress we have made and to build on our progress to date.

In the coming year, the Group is committed to conducting further modern slavery audits on key suppliers, focusing on quickly identifying any deviations from legal requirements and our expectations as a customer.

The Group plan to expand the information and training given to staff, providing awareness communications to its employees and to include modern slavery and human trafficking as part of the induction training programme for new employees.

Policies

The Group has a Modern Slavery policy included in its Employee Handbook of policies and procedures which is available to all employees, supported by our policy on bribery and corruption.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.