Modern Slavery Statement
Modern Slavery Statement – 2023
Introduction to elmo
Elmo Drive Limited (referred to in this Modern Slavery Statement as “elmo”) operates elmodrive.co.uk, offering a subscriptions-based service for electric cars.
elmo is part of the Constellation Automotive Group (the “Group”) which operates a market‐leading business across the UK and Europe.
The registered office for Elmo Drive Limited at the date of this statement is Form 2, 18 Bartley Wood Business Park, Bartley Way, Hook, Hampshire, RG27 9XA.
What is Modern Slavery?
Modern slavery is a serious crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
elmo acknowledge that companies:
- have a vital role to play in conducting business in such a manner to prevent modern slavery;
- need to be vigilant to the issue; and
- must aim to continuously improve practices and processes in this area.
elmo has a zero‐tolerance approach to modern slavery. elmo is committed to:
- acting ethically and with integrity in its business dealings and relationships; and
- implementing appropriate and effective systems and procedures to try to ensure modern slavery does not take place anywhere within its control or influence.
The Modern Slavery Act 2015 (referred to in this statement as the “Act”) introduced changes in law focused on placing the issue of modern slavery at the forefront of decision making when engaging new suppliers and relationships, and increasing transparency in supply chains. This includes the requirement for a statement to be disclosed (by businesses of a certain size) to set out what steps they have taken to ensure their business and supply chains are free from modern slavery.
This statement sets out the steps that elmo has taken, and is taking, to ensure that it trades ethically, sources responsibly and works to prevent modern slavery and human trafficking throughout elmo and in its supply chains.
The goods, services and products elmo utilises in its operations are sourced from a range of national and international suppliers. These include sourcing of vehicles, and commercial arrangements with vendors including vehicle logistics providers and suppliers of ancillary vehicle services (such as warranty and servicing products).
This list is not exhaustive.
elmo also purchases a broad range of operational and professional services as expected for an organisation of its size and diversity. This includes legal, accountancy, information technology, insurance, cleaning, property maintenance and other back‐office functions.
elmo expects all businesses in its supply chains to comply with its values and strives to ensure that it does not participate, or work with, suppliers that operate unfair and inappropriate working practices.
elmo has developed and implemented a Supplier Code of Conduct. As part of an ongoing process, suppliers will be provided with a copy of this Supplier Code of Conduct and details of elmo’s requirements (as varied from time to time). Where appropriate, a supplier will be expected to comply with this Supplier Code of Conduct.
elmo continues to both:
- develop and distribute its Supplier Code of Conduct; and
- strengthen its contractual relationships with suppliers (as part of its tender and renewal processes).
elmo is committed to:
- operating in accordance with all applicable laws and regulations;
- working to high standards of professional and ethical behaviour; and
- ensuring there is no modern slavery or human trafficking in its business.
For this reason, elmo and the Group have in place a number of policies, guidance and procedures which set out the standards of behaviour and core values that it expects of its employees.
The elmo and Group policies are underpinned by the Group Code of Conduct which applies to all representatives including directors, officers, senior managers, employees, consultants, contractors, interns, casual and agency workers, volunteers and any individual working in the name of the elmo. Amongst other things, the Group Code of Conduct confirms the Group’s commitment to respecting human rights in connection with the business activities of the Group and to encouraging the Group’s suppliers and business partners to support appropriate labour standards in their own supply chains.
The Group has recently launched a new employee portal which provides employees with easy access to policies and procedures (during onboarding and for future reference). This new portal extends to elmo.
The policies and procedures in the new employee portal cover those elements of UK legislation applicable to an individual’s employment, including:
a new Dignity at Work policy, which emphasises the dedication to create an inclusive working environment and a culture of mutual respect and consideration, free from discrimination, harassment, bullying, violence, abuse, coercive behaviour and related misconduct;
- an Anti‐Bribery and Corruption policy;
- a Business Entertainment and Gifts policy;
- policies governing recruitment and hours of work; and
- a Whistleblowing policy, allowing employees to report concerns without fear of adverse treatment or reprisal (more information below).
The above list is not exhaustive.
The Group policies set clear standards to the employees of elmo for legal compliance. Disciplinary procedures are in place for any employee whose conduct does not meet the standard required.
During the year to which this statement relates, the Group has reviewed, added to and/or updated its central policies.
Due diligence of suppliers
As part of an initiative to identify and mitigate risk, elmo operates an on‐boarding process for new material suppliers which includes a requirement for a prospective material supplier to confirm compliance with legislation, including the Act. A questionnaire regarding suppliers’ business practices is provided for the supplier to complete during selection and/or contract negotiation. The questionnaire addresses the behaviours and ethics elmo expects of its suppliers. elmo expects responses to be accurate and comprehensive. Any gaps or queries flagged in the review of the completed questionnaire will be referred back to the supplier for further information.
The information obtained during this due diligence process is used by elmo to determine whether or not:
- the supplier complies with the values of elmo;
- the supplier can demonstrate good practice; and
- elmo should accept the supplier into its supply chain.
Where a supplier is successful in completing the on‐boarding process, specific prohibitions against the use of forced, compulsory and/or trafficked labour are included as part of the contracting process. A right to audit the supplier is included in elmo’s contractual terms (where appropriate).
elmo expects our suppliers to hold their supply chain to the same high standards.
Going forward, elmo continues to:
- strengthen its contractual relationships with suppliers (as part of its tender and renewal processes);
- review and improve its due diligence questionnaires and (where appropriate) expand its question set to provide further insight into a supplier’s compliance with the Act and its commitment to tackle this issue; and
- work to further embed the Supplier Code of Conduct and appropriate due diligence processes (including, where appropriate, the use of the Group’s central procurement team for the on‐ boarding of material suppliers).
The recruitment process operated by elmo for the appointment of new employees is designed to operate in a legal and ethical manner and includes the following practices:
- validating that the individual has the legal right to work in the country the position applies to;
- collating suitable references (where appropriate);
- requesting and reviewing identification documentation; and
- where appropriate, applying for a Disclosure and Barring Service check.
This list is not exhaustive
elmo does not employ any children who are under the legal minimum working age. All apprenticeship roles are offered, and fulfilled, in compliance with applicable law in this subject matter.
Risk assessment and effectiveness
elmo utilises reputable service providers, many of which are also subject to the Act. Our on‐boarding processes are designed to select supplier partners responsibly.
Any concerns raised during the on‐boarding process of a new supplier will be escalated to senior management. elmo will not engage in a business relationship where the information provided by the supplier does not satisfy elmo that the supplier complies with all applicable law as it relates to modern slavery, servitude, forced or compulsory labour and human trafficking.
Where a concern is identified after a supplier has been appointed, reasonable and practical checks will be carried out (to test whether our standards are being adhered to, and legislation and regulations relevant to the supplier are being complied with). Any instances of non‐compliance will be dealt with on a case‐by‐case basis and any remedial actions tailored appropriately.
As at the date of this statement, elmo has not identified any instances or indications of slavery or human trafficking existing in its supply chain. In light of this, elmo has not considered it necessary to put in place formal key performance indicators to assess its effectiveness in ensuring that slavery and human trafficking is not taking place in any part of elmo’s business or supply chains. elmo will continue to keep this position under review.
elmo employs people in locations across the UK.
Appropriate training is provided and elmo will continue to develop this training as legislation and standards evolve.
This statement is accessible to all.
The elmo / Group Whistleblowing policy applies to employees, consultants, agents, contractors, interns, casual workers, agency workers, business partners, sub‐contractors as well as any representatives or third parties acting on behalf of, or representing elmo.
To help facilitate compliance with:
- the core values of elmo;
- the expected standards of behaviour of employees; and
- the policies and procedures published by elmo,
a confidential, independent whistleblowing help‐line is in place. Individuals are encouraged to use the help‐line to report any activity they are concerned about in any part of the elmo’s business or its supply chain.
The help‐line is communicated through the elmo Whistleblowing policy which:
- contains comprehensive guidance on how to raise concerns;
- aims to encourage the reporting of suspected wrongdoing as soon as possible; and
- provides assurance that genuine concerns will be treated appropriately and seriously (even if they turn out to be unfounded).
The elmo and Group Whistleblowing policy is available at all times.
This statement is made pursuant to Section 54(1) of the Act and constitutes the slavery and human trafficking statement for elmo for the financial year ending 3 April 2024. It has been approved by the Board of Directors, who will review it on an annual basis making updates as necessary.
elmo is committed to the continuous improvement of its operations, processes, and knowledge, in eradicating modern slavery and human trafficking in its own business and wider supply chain.
Oliver Jones Managing Director