Modern Slavery Statement 2017
LeasePlan's approach to combatting slavery and human trafficking during 2016/17
- Since the implementation of the Modern Slavery Act 2015, LeasePlan has carried out the following: LeasePlan takes a risk-based approach to Modern Slavery focusing on the high risk countries. In addition to regular Supplier Sanction screening LeasePlan conducts Sanction screening on Adverse Media and Enforcement for all suppliers to the LeasePlan entities in India, Russia, Turkey, Brazil and Mexico.
- Modern Slavery provisions have been included in the LeasePlan Supplier Code of Conduct. All LeasePlan entities are required to ensure that their suppliers comply with the Supplier Code of Conduct or demonstrate that they have equivalent provisions in their own codes of conduct.
- On joining LeasePlan all employees are required to sign up to the LeasePlan Code of Conduct. This covers the LeasePlan principles of business that all employees are expected to follow: Honesty and Trust, Respect for Law, Human Rights, and Corporate Social Responsibility. Annually all employees are requested to sign an annual statement in relation to compliance with the Code of Conduct. Non-compliance with the LeasePlan Code of Conduct is taken seriously and any failure to comply with the Code of Conduct may lead to disciplinary action and could include termination of employment.
- LeasePlan UK implemented an Anti-Slavery Policy in October 2016 which is applicable to all employees, consultants and suppliers. This is accessible by all employees via the LeasePlan UK Infonet.
LeasePlan UK’s contractual documentation for consultancy and supply agreements have been updated to include Modern Slavery Provisions and give LeasePlan the right to terminate supply agreements if a supplier is found to be in breach.
- Any LeasePlan UK tender for the provision of new services now require potential Suppliers to provide details of their Modern Slavery Policies, Statements and assurance regarding compliance.
- LeasePlan has existing policies for reporting of Incidents and Whistleblowing to facilitate the reporting of incidents with regard to modern slavery and human trafficking.
- LeasePlan UK regularly conducts training for its procurement/buying teams. During 2017 this training has been updated to ensure that these teams understand the signs of modern slavery and what to do if they suspect this is taking place within our supply chain.
Modern Slavery Key Performance Indicators:
LeasePlan will know the effectiveness of the steps that it is taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices related to LeasePlan or its supply chain have been identified;
- LeasePlan UK training of procurement/buying teams in Modern Slavery has been completed;
- All employees have signed the Annual compliance Statement for the LeasePlan Code of Conduct; and
- Any adverse media reports for Suppliers in high risk areas identified as part of the Supplier CDD process are fully investigated to ensure that there is no modern slavery or human trafficking taking place or an alternative Supplier has been used.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes LeasePlan UK Limited’s and LeasePlan Corporation N.V’s slavery and human trafficking statement for the financial year ending 31 December 2016.
Date: 9 June 2017