Modern Slavery Statement
This statement applies to SDC Trailers Ltd. (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 1st January to 31st December 2019.
B) ORGANISATIONAL STRUCTURE
SDC is part of the CIMC Group; a global player within the container, trailer and tanker industries, with annual sales of 110,000 vehicles. Supported by CIMC, SDC follows its own mission and values as we continue to build our future and achieve our vision.
Established in 1978, SDC has grown to be the UK and Ireland's largest semi-trailer manufacturer. We now have four manufacturing plants, based in Toomebridge, Magherafelt, Antrim and Mansfield.
SDC supply trailers to a wide range of companies and have built relationships with the industry’s leading logistics operators, supermarket chains and hire companies.
The labour supplied to SDC Trailers Ltd. in pursuance of its operation is carried out predominantly in the UK
The Group considers that modern slavery encompasses:
· Human trafficking;
· Forced work, through mental or physical threat;
· Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
· Being dehumanised, treated as a commodity or being bought or sold as property;
· Being physically constrained or to have restriction placed on freedom of movement.
SDC Trailers Ltd. acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. SDC Trailers Ltd. We understands that this requires an ongoing review of both our internal practices in relation to our labour force and, additionally, our supply chains.
SDC Trailers Ltd. does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the SDC Trailers Ltd. in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in UK and Republic of Ireland.
E) SUPPLY CHAINS
In order to fulfil its activities, SDC Trailers Limited main supply chains include those related to trailer components from UK and Europe. We have zero tolerance to Slavery and Human Trafficking. We expect all those in our supply chain to comply with our values.
F) POTENTIAL EXPOSURE
In general, SDC Trailers Ltd. considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
SDC Trailers Ltd. carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its main suppliers.
SDC Trailers Ltd. has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, SDC Trailers Ltd. has taken the following steps to ensure that modern slavery is not taking place:
· Review of our Recruitment systems to ensure recruitment practices remain legally compliant.
· Use of the Whistleblowing policy in relation to Modern Slavery and Human Trafficking.
· We have Issued a Modern Slavery questionnaire to our main suppliers. Any concerns arising from this will result in sanctions to bring about immediate improvement/termination of the supplier relationship.
· We strictly use reputable recruitment agencies to source labour who are registered with the REC.
· We check that all potential employees have the right to work in the UK.
H) KEY PERFORMANCE INDICATORS
SDC Trailers Ltd. has set out the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the SDC Trailers Ltd. or its supply chains.
We intend to monitor the following KPIs over the next financial year to measure how effective the processes have been:
· The number of suppliers who have completed and returned the SDC Modern Slavery Questionnaire and have supplied a copy of their Modern Slavery Policy.
· Record of any Whilstle Blowing incidents and the actions taken to rectify issues.
· Completion of a review of our Modern Slavery policy to ensure it continues to be fit for purpose.
The SDC Trailers Ltd. has the following policies which further define its stance on modern slavery:
· Modern Slavery Policy
· Recruitment Policy and Procedures
· Making a protected Disclosure Policy
· Purchasing Policy
· Employee Handbook Statement
· Bullying Prevention Policy
· Corporate Social Responsibility Policy
J) SLAVERY COMPLIANCE OFFICER
The SDC Trailers Ltd. has a Slavery Compliance Officer, Jane Millar, Human Resources Manager to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the SDC Trailers Ltd. obligations in this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010 and will be reviewed for each financial year. It has been approved by the Executive Management team who will undertake to ensure its regular update and implementation of its values and objectives.
Chief Executive Officer
1st January 2019
Invest NI Grant for Research and Development
SDC Trailers has received an Invest NI Grant for Research and Development, supporting company innovation in services, products and processes. Part financed by the Investment for Growth and Jobs Programme for Northern Ireland co financed by the European Regional Development Fund. The curtainside project will be implemented over the next 18 months and aims to maintain and enhance SDC reputation as a leading trailer supplier in its markets
SDC Trailers Tax Strategy
This document sets out the tax strategy of SDC Trailers Limited and the group of UK companies of which it is a member. It is published on SDC’s website and is publicly available to all stakeholders for the purposes of complying with paragraph 16(2) of Schedule 19 of the Finance Act 2016.
The group ensures the strategy is:
adopted and followed consistently by all subsidiaries; and
in line with the group’s approach to corporate governance and risk management.
Group Tax Commitment
SDC and its fellow UK group members pay tax in accordance with all relevant laws and regulations in the countries in which the group operates. SDC’s approach is based on the following principles:
Tax Risk Management and Governance
The group operates an effective tax control framework to identify key tax risks and manages those risks through appropriately designed and operated controls. In operating our tax risk management and governance processes, SDC has a low appetite towards tax risk. We are committed to full compliance with our tax obligations, paying the right amount of tax at the right time. We seek to ensure that our tax arrangements remain consistent with a low risk assessment, both in financial and reputational terms.
This is ensured through:
submitting all tax returns on time and having supporting documentation to support each return filed;
paying all taxes at the right time; and
maintaining tax accounting arrangements which are accurate and comply with legislation.
The group have identified tax risks, which are maintained on risk registers that are reviewed regularly by the finance team.
SDC does not engage in any artificial tax arrangements. It has a strong commercial focus and to meet its objective to control unnecessary costs, the group utilises tax reliefs and allowances prescribed by the legislation in the way in which they are intended to be used. Transactions between group companies are conducted on an arms-length basis in accordance with appropriate transfer pricing rules. This ensures the group’s profits are taxed where economic activities are performed.
The group’s annual Corporation Tax returns are prepared by external advisors and reviewed for accuracy and completeness by the finance team before submission to HMRC
When considered necessary, the finance team engages external advisors to provide technical expertise when required.
Relationship with HMRC
SDC and its fellow group members are committed to acting with integrity at all times and engage with HMRC openly and constructively. We feel this is the best way to ensure that we pay the right tax at the right time and to maintain a good working relationship with HMRC. Where appropriate we endeavour to engage with HMRC as soon as possible in any areas of material uncertainty, so as to minimise our tax risk and to provide greater certainty for both parties in advance of formal tax filings.
This tax strategy has been approved by the Board of Directors and is effective for the period ending 31 December 2017. It will be reviewed and updated where appropriate annually. The Board is responsible for setting and monitoring the strategy and the finance team is accountable to the Board for the implementation of the strategy and management of tax risk.