MFG’s Modern Slavery Statement for Financial Year 2024
In accordance with Section 54 of the Modern Slavery Act 2015, this statement sets out Mars Challenger Jersey Topco Limited (being the ultimate parent company of the group) and all of its operating subsidiaries (collectively known as Motor Fuel Group (MFG or we or us)), approach to understanding potential modern slavery risks within its business and the actions that are being taken by MFG to ensure that there is no slavery or human trafficking in its business and supply chains. This statement relates to actions and activities for the financial year ending 31 December 2024 and the factual information included in this statement is accurate as at 31 December 2024.
MFG recognises its responsibility to take a proactive approach to slavery and human trafficking and is committed to preventing slavery and human trafficking in all areas of its business and supply chain.
MFG Business
The principal business of MFG is the ownership and operation of c.1200 service stations across Great Britain providing Fuel, EV Charging, Valeting, Forecourt Shop, ‘Food to Go’ and ancillary services. The majority of the business is operated via a contract management (franchise) model where MFG engages third party contract managers, who are self-employed, and are responsible for the day-to-day operation of their contracted service station. MFG also has c.27 direct managed sites where MFG owns and operates each station, employing all service station staff.
MFG currently operates in England, Scotland and Wales which it has assessed as relatively low risk in relation to slavery and human trafficking. It regularly reviews its countries of operation to assess if any activities or countries are high risk in relation to slavery or human trafficking.
Policies & Initiatives
The following actions are taken by MFG in relation to anti-slavery.
Policies:
MFG operates a number of internal policies and procedures which aim to ensure we conduct our business in a legally compliant and ethical manner. The 2024 release of the MFG Employee Handbook contains the following policies:
Corporate Social Responsibility
Highlights MFG’s social responsibilities to staff and the communities in which they operate, including MFG’s stance on modern slavery.
Whistleblowing Policy
Highlights MFG’s commitment to conducting business with honesty and integrity and its expectation on all employees to report all concerns, including those related to slavery and human trafficking, and its commitment that such disclosures can be made without fear of retaliation.
Equality and Diversity Policy
Highlights MFG’s approach to equal opportunities, conduct at work and the avoidance of discrimination at work.
Anti-Corruption and Bribery Policy
Sets out employee’s obligations in relation to any bribery, corruption or other breach and is in accordance with our whistleblowing policy.
Sanctions Policy
Highlights MFG’s obligation to comply with any sanction’s regime
imposed under relevant legislation.
Anti-Harassment and Bullying Policy
Highlights MFG’s commitment that their working environment will be free from harassment and bullying and ensuring all employees are treated, and treat others, with dignity and respect.
Each such policy explains how employees can identify and raise concerns to MFG.
MFG operates a robust recruitment process that includes eligibility to work in the UK checks. Only reputable employment agencies are used as a recruitment source.
These policies are reviewed and issued to all MFG staff annually.
Risk Assessments
The MFG Finance Director is responsible for maintaining MFG’s risk register which includes a review of the risk of our commercial activities in relation to identifying if there are any potential risks where modern slavery could occur. MFG has assessed the day-to-day operation of its fuel stations which are, as highlighted above, operated under a franchise model, and by virtue of operating in the forecourt sector there is a perceived higher risk for modern slavery and human trafficking activities given non-EEA nationals typically make up a high percentage of the working population. Modern slavery risks are regularly monitored and assessed by MFG in this identified risk area.
Furthermore, contract managers employ their staff directly so MFG has no direct control or employment relationship over the employment conditions of the individual whom is employed by the relevant contract manager. MFG’s contract management agreement, which is put in place with each contract manager, ensures the contract manager warrants and represents that they and their suppliers are not involved in and take reasonable steps to prevent slavery and human trafficking activities and that all their employees and workers are paid in compliance with all applicable laws. A breach of these provisions, amongst others, permit MFG to immediately terminate the contract manager agreement and MFG takes a robust approach to any non-compliance.
All staff that are employed by MFG (at the c.27 direct managed sites (as highlighted above)) have been, and continue to, paid the national living wage when working at such relevant site.
MFG has identified that there may be risk further down the fuel supply chain as some products initiate outside the EEA where typically there may not be as much focus on prevention of slavery and trafficking. However, going forward when entering into new contracts or renewing existing contracts, MFG is committed to requesting its suppliers to warrant and represent that they, and in turn their suppliers, are not involved in and take reasonable steps to prevent slavery and human trafficking activities.
Due Diligence
MFG carries out ‘right to work’ screening of all prospective employees during the recruitment process. Any suspected instances of slavery and human trafficking, would immediately be investigated and reported to the MFG Executive Team and regulatory authorities by the MFG HR Director. Any employees who have limited or conditional rights to remain/work in the UK are monitored by both the MFG HR department and relevant MFG Managing Director.
As part of the right to work screening, proof of address is obtained and checked and a third-party credit check for all prospective contract managers is carried out during the application process. All contract managers are assigned relevant ‘right to work’ training which is monitored. Any reports of non-compliance with employment legislation, e.g., minimum wage or discrimination is immediately investigated and if not rectified, contract manager agreements with the relevant contract manager are immediately terminated. Furthermore, any suspected instances of slavery and human trafficking are immediately investigated and reported to the MFG Executive Team and regulatory authorities by an MFG Managing Director. MFG co-operate fully with any investigations by the regulatory authorities into suspected non-compliance within the contract manager community.
Training & Awareness
The 2024 release of the Employee Handbook includes a section to provide an awareness of the Modern Slavery Act 2015, and an awareness of the key risks to MFG, employee personal responsibilities and how to report any concerns. This are reviewed annually. All employees are asked to re-read and re-sign the MFG Employee Handbook on an annual basis.
In addition, MFG sends regular bulletins to contract managers to remind them of their ‘right to work’ obligations in relation to the staff they employ and to highlight any changes in employment legislation, e.g., minimum wage.
Performance Indicators
MFG monitors and takes seriously all allegations, including those from contract managers, which raise any unfair working practices or modern slavery concerns. MFG reviews the level of adherence to mandatory training undertaken by contract managers and their staff concerning fair working practices to monitor compliance.
For the avoidance of doubt this statement applies to all the Companies outlined in the MFG Group Structure shown here.
Approval
This statement is approved by the Board of Directors of Motor Fuel Group.
Name: William Bannister (CEO) on behalf of the Board of Directors
Signature:
