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We Are Committed to Improving Our Practices to Combat Slavery And

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We Are Committed to Improving Our Practices to Combat Slavery And We are committed to improving our practices Our supply chains include: to combat slavery and human trafficking. Our UK business has in excess of 1,000 ORGANISATION'S STRUCTURE suppliers who provide a range of products and services including capital equipment, We are a bus operating company. We are a professional services, facilities, maintenance part of the ComfortDelGro Group ("Group"), repair & operating and support services and our ultimate parent company is the totalling nearly £200 million per year in spend. ComfortDelGro Corporation which has its Whilst all the Tier 1 suppliers are based in the head office in Singapore. The Group has over UK there are a handful whose operations and 24,000 employees worldwide and operates in Tier 2 supply chains are also performed outside seven countries. The Group has a global annual the UK. turnover of S$3.81billion. OUR POLICIES ON SLAVERY AND OUR BUSINESS HUMAN TRAFFICKING This statement covers all of the activities of We are committed to ensuring that there is no Braddell Limited. Metroline Limited is the most modern slavery or human trafficking in our substantial part of our business operating and supply chains or in any part of our business. is responsible for almost 20% of the London Our Procurement Policy and Supplier Code of bus market through our subsidiaries, Metroline Conduct reflects our commitment to acting Travel Limited and Metroline West Limited. ethically and with integrity in all our business Our parent company itself is responsible for relationships and to implementing and operating a bus refurbishment centre. Braddell enforcing effective 'systems and controls to also has an interest in operating express coach ensure slavery and human trafficking is not services in the Republic of Ireland through a taking place anywhere in our supply chains. wholly owned subsidiary, ComfortDelGro Irish Citylink, a joint venture with Stagecoach in The policy, has been built around and adopts Scotland, Scottish Citylink and a bus and coach elements of the of Ethical Trade Initiative (ETI) operation in South Wales. Base Code as a means of evaluating suppliers and contractors who may be considered high risk in terms of modern day slavery and selected sections of the Ten principles of the United Nations Global Compact. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN OUR EFFECTIVENESS IN TRAFFICKING COMBATING SLAVERY AND HUMAN As part of our initiative to identify and mitigate TRAFFICKING risk we have established an industry based risk We will use the following key performance matrix, developed an assessment tool, mapped indicators (KPls) to measure how effective we our first tier supply chain, identified those have been to ensure that slavery and human suppliers who accounted for 90% of our total trafficking is not taking place in any part of our spend along with those identified as operating business or supply chains: in High Risk Industries. This exercise will be carried our annually to identify changes in our Number of Supplier Assessments top suppliers. completed This process identified a number of suppliers Number of Assessment Non Compliance who have been or will be over the next 12 Notices issued months assessed against the Procurement Number of Ethical Procurement Policy criteria to ensure that these principles certificates obtained in the year are upheld. Following a review of the effectiveness of the SUPPLIER ADHERENCE TO OUR steps we have taken to ensure that there is no VALUES slavery or human trafficking in our supply chains we intend to extend the scope of the We have zero tolerance to slavery and human assessment to those suppliers outside the top trafficking. To ensure all those in our supply 90% and those who are in the second tier of chain and contractors comply with our ethics our supply chain. we have in place a Compliance team, which consists of from the following departments This statement is made pursuant to section who will be responsible for developing and 54(1) of the Modern Slavery Act 2015 and implementing policies, assessments and constitutes our Group's slavery and human remediation with non•conforming suppliers. trafficking statement for the financial year ending 31st December 2018. The compliance team will be led by the Head of Purchasing & Contracts and Human Resources. DIRECTOR TRAINING To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we Sean O’Shea provide training to our staff with key procurement personnel undertaking an independent and certified (Chartered Institute Date: September 2019 of Purchasing) yearly assessment on Ethical Procurement. Braddell Head Office, 3rd Floor, ComfortDelGro House, 329 Edgware Road, Cricklewood NW2 6JP T:020 8218 8888 • F:020 8218 8899 • www.metroline.co.uk .
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