Modern Slavery Policy
Modern Slavery Act 2015
Slavery and Human Trafficking Statement for Year Ended 31 March 2019
Certas Energy UK Ltd is opposed to slavery and human trafficking in any part of our activities or our supply chains. We are therefore committed to ensuring that we have adequate policies and procedures in place to identify and prevent these practices.
We met the turnover threshold applicable under section 54 of the Modern Slavery Act 2015 in the period covered by this statement.
We are a distributor of fuels and lubricants in the energy sector. Seasonal work is a feature of the industry in which we operate. More information on our business in available at www.certasenergy.co.uk
We are a part of the DCC Group. DCC is a leading international sales, marketing and support services group with a clear focus on performance and growth. Its headquarters are in Dublin, Ireland. It is listed on the London Stock Exchange and is a constituent of the FTSE 100 Index.
DCC currently has operations in 17 countries and employs over 12,000 people. Additional information on the Group is available at www.dcc.ie.
Our business is organised into the following business units:
Our Supply Chains
We only source products from reputable suppliers who are based the European Union.
The following table contains a summary of the activities that we consider present the highest risk of slavery and human trafficking in the industries in which we operate, with, in each case, a summary of the steps we have in place to avoid these affecting our activities or our supply chains.
|Industry Risk||Steps Taken|
|Our business identified that workers on manual car washes may be at risk of exploitation. This risk is substantially mitigated by the use of automated car washes on Certas forecourts.||Where the use of automated car washes is not possible, Certas appoints reputable contractors that comply with applicable employment standards to provide manual car wash services. Certas also carry out due diligence on their employment practices.|
Our Policies on Slavery and Human Trafficking
The DCC Code of Conduct sets out our Group’s commitment to acting ethically and with integrity towards our employees and in all our business relationships. Specifically, section 2 of the Code sets out our commitment to fair employment practices and section 14 of the Code sets out our commitment to preventing, as far as practicable, slavery and human trafficking in our supply chains.
In addition, the DCC Group Supply Chain Integrity Policy sets out the approach taken by every business in the DCC Group to ensuring that all the products we sell meet applicable legal and ethical standards.
Both of these documents are available at http://www.dcc.ie/responsibility/our-policies.
Our policy on slavery and human trafficking is set out in section 1 of this statement.
The requirements of our Code of Conduct, Group Supply Chain Integrity Policy and our own policy are reflected in the more detailed policies and procedures that we have in place in Certas Energy UK Ltd. These are addressed in more detail in section 6 of this statement.
Procedures on Slavery and Human Trafficking
As part of our compliance with the policies referred to above, we take the following steps:
· Assess potential risk areas in our supply chains;
· Mitigate the risk of slavery and human trafficking occurring in our supply chains, including by reviewing, where necessary, the controls that our suppliers have in place and carrying out other suitable checks;
· Monitor potential risk areas in our supply chains on a periodic basis.
Assurance and Key Performance Indicators
Responsibility for ensuring that our procedures are adequate and are adhered to in all areas of our activities rests with the directors of Certas Energy UK Ltd.
We report on compliance with the DCC Group Code of Conduct and Supply Chain Integrity Policy every six months.
Training and Awareness
We provide training to relevant employees on supply chain risks, including the risk of slavery and human trafficking at suitable intervals. Our participation in industry associations and our dealings with suppliers also provide information on where slavery and human trafficking risks may arise in the industries where we are active and best practice in avoiding them.
Nature of this Statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ended 31 March 2019.
This statement has been approved by the board of directors of Certas Energy UK Ltd.
Certas Energy UK Ltd
23rd May 2019