This statement covers the activities of ParkingEye Ltd. and is our Modern Slavery statement for the financial year ended 31 December 2019 required under the provisions of the Modern Slavery Act 2015 (the “Act”).
Modern slavery in all its forms of slavery and servitude, forced or compulsory labour and human trafficking is a heinous crime and we will not tolerate any such activities within our own operations or our supply chain. We are committed to stamping out modern slavery and are taking the appropriate steps to ensure that everyone who works for ParkingEye benefits from a working environment in which their fundamental human rights are respected and anyone that we do business with also upholds these principles.
The information in this statement details policies, processes and actions we have taken to ensure that slavery and human trafficking are not taking place in our supply chains or any part of our own business.
Our business and supply chain
We provide our services by combining our talent, creativity, software, technology and innovation with sector knowledge and proven skills and expertise underpinned by our scaled operational platforms.
We use a limited range of third party suppliers within the UK. We actively encourage supplier diversity and currently the majority of our supply base are classed as small and medium sized enterprises (SMEs).
When awarding contracts to suppliers, Parking Eye’s procurement team strives to understand the policies and practices of these suppliers and carries out due diligence checks.
The following company policies support us in ensuring that modern slavery is not taking place in our supply chains or business:
Human Rights Policy: ensures appropriate procedures are in place to prevent any breaches to international human rights standards, including the United Nations’ Universal Declaration of Human Rights (UDHR), the International Labour Organisation (ILO) core conventions on Labour Rights, and the Act.
Procurement Policy: sets out our strategic approach and the key principles and priorities that apply to all Parking Eye’s procurement activity ensuring we have control over our external expenditure and effectively manage our supply chain risks.
Supplier Requirements Standard: sets out our expectations of suppliers in terms of ethical procurement, financial soundness, information technology and data security and governance. It details the due diligence and risk assessment that is conducted on all suppliers ensuring compliance to relevant legislation including the Act.
These policies are available to all employees via our intranet site. The policies are managed by relevant department heads, and our risk management framework and reporting processes support the escalation of policy issues and management where identified in our business.
Tackling modern slavery – our people
To ensure that we recruit and treat employees fairly, avoiding modern slavery at all costs, our human resources (HR) policies set out our procedures on how we:
- recruit and select employees in a fair, lawful and professional manner, both for internal and external candidates
- treat all employees fairly during their employment and, if there is an occasion when an employee does not feel that they have been treated fairly, there are procedures in place to raise a grievance or involve local trade union, where they exist, or where this is a legal requirement to do so
- manage the exit of an employee from the business in a fair and consistent manner
Our Human Rights Policy details our commitments to labour and workplace rights. We provide fair working conditions for all our employees including terms and conditions of employment, remuneration, working hours, health and safety, resting time, holiday entitlements and benefits.
Our employees’ pay will not be lower than that required by law. Hours of work will be in line with the norm within that industry and in accordance with legislation and shall not be excessive. Employees shall not be contractually required to work more than 48 hours per week and overtime will only be worked on an optional basis. Forced or compulsory labour is prohibited. Employees will not be forced into involuntary labour and coercion at work is not acceptable. Financial penalty as a disciplinary sanction is prohibited. The employment models deployed will be in line with specific law and practices. Under these practices there will not be excessive use of alternative models, such as sub-contracting or labour-only contracting.
Employees can raise ethical concerns through our Open Door Policy and Speak Up Policy. Concerns about slavery and human trafficking would be considered to be an ethical concern and employees can raise these concerns openly and at any time in confidence.
In addition to this, we seek feedback from employees where we gauge how our people feel about working at ParkingEye. This enables managers to identify potential issues around culture that could lead to a failure of ethics, controls or governance before they occur. Slavery and human trafficking would be picked up as a potential issue through this assessment.
Tackling modern slavery – our supply chain
We seek to partner with suppliers who uphold our high standards of social, environmental and ethical conduct providing safe working conditions, treating workers with dignity and respect, acting fairly and ethically, and using environmentally responsible practices where practicable.
Analysis of our supply chain suggests that almost all of it is UK based. Given the robust UK legislative framework, the risk of infringement for our suppliers is low. Nevertheless, we recognise our responsibility to identify and address potential infringements linked to the goods and/or services we procure.
Therefore, we have taken steps to strengthen our ability to prevent and manage the risks of modern slavery in our supply chain, updating our Procurement Policy, Supplier Requirements Standard and Supplier Contract Terms and Conditions to reference the obligations of the Act.
Parking Eye’s procurement team works with colleagues and suppliers to ensure that all necessary due diligence checks are undertaken. If risks are identified during our due diligence, we work with suppliers to address them. Once a supplier is approved, in an ongoing process, we assess their record on human rights, social and environmental issues.
All suppliers are expected to comply with our Supplier Requirements Standard and ParkingEye reserves the right to terminate a relationship with a supplier or third party that is unable to demonstrate compliance or progress towards the eradication of modern slavery within its organisation and supply chain.
Training and communication
To make employees aware of the Act and the drivers of modern slavery, as well as the possible indicators, we share this statement with all employees through our internal communication channels and a copy of this statement will be available on the ParkingEye website (www.ParkingEye.com). Our procurement team is aware of the Act and our associated due diligence processes. Reporting on the efficacy of this policy is made to the Company’s board.
Plans for the next year
We will maintain effective and continued focus on employee awareness of how we expect employees to conduct business responsibly, focusing on treating people fairly and equally, acting lawfully and the process involved to raise ethical concerns.
Philip Boynes, CEO