Introduction

This statement is made on behalf of the UK companies, APD Group Limited and APD business management Limited, hereafter referred to as ‘APD’ to address section 45 (1) of the Modern Slavery Act 2015.

Registered office: 10 Queen Street Place, London, EC4R 1AG.

APD is committed to continually improving its practices to combat slavery and human trafficking and has zero tolerance of modern slavery in all its different forms, both in its business and supply chain.

This is our first modern slavery statement following the introduction of the Modern Slavery Act 2015. APD, having an annual turnover of less than £36m, is not subject to section 54(6) of the Act, but as a responsible supplier and employer, the Company chooses to define the following anti-slavery and human trafficking statement, for the financial year ending on 31 December 2018.

APD aims to be transparent about its approach to modern slavery, and this statement outlines its outlook to tackling modern slavery where it can.

Our business – Structure, Business and Supply Chains

APD Group Limited is the holding company for APD Business Management Limited which specialises in the provision of business management services, technology and training to the automotive and leisure industries. Focused and committed to working with manufacturers, distributors and their dealer networks, it delivers proven, innovative solutions across more than 80 countries.

APD operates in Europe, Africa, Asia and South America, with its head office of operations located in the UK.

Supply Chain Management

As a software and professional services provider, APD does not have a supply chain (local or international) where modern slavery or human trafficking would be a risk. As general rule, contractors and suppliers used by APD are therefore not likely to be susceptible to this risk.

APD is committed to acting ethically and with integrity in all its business relationships and implementing and enforcing effective systems and controls to ensure slavery and human trafficking do not occur anywhere in the business or supply chains.

Policies in relation to Slavery and Human Trafficking

APD’s policy to this effect is included in the Employee and Sub-Contractor Handbooks, within:

• the Corporate social responsibility statement
• the Anti-Bribery and Corruption policy
• our Equal Opportunities policy.

Employees access these policies via our internal systems and are re-published when any changes are made.

Identified risks and steps taken to prevent and manage the risks

APD is currently in the process of reviewing the anti-slavery systems and controls to:

• Identify, assess and monitor potential risk areas in the supply chains.
• Mitigate the risk of slavery and human trafficking occurring in the supply chains across the global entity.
• Develop a specific modern slavery policy and include it in all global handbooks.
• Establish our Whistleblowing policy to encourage employees to speak up and report any wrongdoing.

This will support existing policies setting out the APD’s approach to being inclusive and diverse, employee well-being and employee consultation and engagement.

Due Diligence Process for Slavery and Human Trafficking in our Business and Supply Chains

As part of our focus to identify and mitigate risk:

• APD will continue to monitor and assess potential risks across the business and our supply chains.
• The procurement and sales team will include risk assessments as part of their processes and report any potential risks.
• Implementation of our Whistleblowing policy & protection for whistleblowers.
• Implementation of Modern Slavery policy in all handbooks.

Recruitment and Selection

APD follows a clearly defined recruitment and selection process, ensuring that only reputable agencies are used to source employees.

All subsidiaries of APD will help to ensure appropriate controls are in place to enable employees to have the right to work and are therefore protected by relevant employment legislation, including but not limited to checking for right-to-work documents, visas and passports.

Effectiveness in combatting Slavery and Human Trafficking

APD understands that it has a responsibility to continue to assess and mitigate the risk of modern slavery. While APD continues to make progress in this area, future developments will be to understand the nature of that risk, establish policies and implement controls to manage any risk that arises.

APD aims to:

• Extend the modern slavery training to all employees.
• Monitor best practice perspectives and approaches to modern slavery, including those of APD’s customers, and ensure APD is in line with these approaches where applicable to our business.

Training on slavery and human trafficking

• Detailed training updates to all relevant personnel within the procurement/sales teams
• Updates to our internal training platform to broaden knowledge of this critical area amongst all global employees

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the financial year ending 31 December 2018.

Signed by Jonno Francis, Operations Director