MFG’s Modern Slavery Statement for Financial Year 2022
In accordance with Section 54 of the Modern Slavery Act 2015 this statement sets out CD&R Firefly Holdco Ltd and all its operating subsidiaries’ collectively known as Motor Fuel Group’s (MFG), approach to understanding potential modern slavery risks within its business and the actions that are being taken 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 2022.
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.
The principal business of MFG is the ownership and operation of over 900 service stations across Great Britain providing fuel, EV Charging, valeting, forecourt shop, ‘Food to Go’ and ancillary services. The majority of the business is delivered via a contract management (franchise) model where the business engages third party contract managers who are responsible for the day-to-day operation of their contracted service station. MFG also have ~ 23 direct managed sites where MFG owns and operates each station, employing all 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.
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 2022 release of the MFG Employee Handbook contains the following policies:
Corporate Social Responsibility
Makes clear to employees MFG’s social responsibilities to staff and the communities in which they operate, including the Company’s stance on modern slavery.
Makes clear to employees MFG’s commitment to conducting business with honesty and integrity and its expectation on all staff 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
Makes clear to employees MFG’s approach to equal opportunities, conduct at work and the avoidance of discrimination at work.
Anti-Corruption and Bribery Policy
Sets out employees obligations in relation to any bribery, corruption or other breach and is in accordance with our whistleblowing policy.
Highlights to all staff MFG’s obligation to comply with any sanctions regime imposed by the Government.
Anti-Harassment and Bullying Policy
Makes clear to employees MFG’s commitment that their working environment will be free from harassment and bullying and ensuring all staff are treated, and treat others with dignity and respect.
Each such policy explains how employees can identify and raise concerns.
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.
The HR Director and each head of function is responsible for reviewing (at least annually) each such policy/procedure, amending in accordance with business developments and legislative requirements seeking CEO approval.
The 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 currently believes that as we are not involved in activities where occurrences of modern slavery have been identified, we and our supply chain are both at low risk.
MFG believes that their highest risk is within the day-to-day operation of its fuel stations by the contract managers. Contract managers employ their staff directly so MFG has no direct control over the employment conditions of that labour. Also, the forecourt sector market is an industry where non-EEA nationals typically make up a high % of the working population so there is a greater potential for possible modern slavery or human trafficking activities. However, MFG’s Contract Management Agreement, which is put in place with each contract manager, ensures the contract manager warrants 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 employment legislation.
As of November 2021 all site staff at the direct managed stores have been paid the national living wage.
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 that they and in turn their suppliers are not involved in and take reasonable steps to prevent slavery and human trafficking activities.
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 executive team and authorities by the HR Director. Any employees who have limited right to remain/work in the UK are monitored by both the HR department and the relevant manager.
MFG carries out ‘right to work’ screening, proof of address and a third-party credit check for all prospective contract managers during the application process. Any time limited right to work arrangements are monitored on a weekly basis. Any reports of non-compliance with employment legislation, e.g., minimum wage or discrimination is immediately investigated and if not rectified contracts with the contract manager are terminated. Any suspected instances of slavery and human trafficking would immediately be investigated and reported to the executive team and authorities by the Operations Director. MFG co-operate fully with any investigations by the authorities into suspected non-compliance within the contract manager community.
Training & Awareness
The 2022 release of the Employee Handbook includes a section to provide an awareness of the Modern Slavery Act, and an awareness of the key risks to the company, employee personal responsibilities and how to report any concerns. This will be reviewed annually. All employees are asked to reread 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.
MFG currently considers it a reasonable indicator that slavery and human trafficking is not taking place within their business if the company has received no reports from any source, including employees, customers, suppliers, contract managers, law enforcement agencies or the public, to indicate that slavery and human trafficking practices have been identified in relation to the business or its third parties.
For the avoidance of doubt this statement applies to all the Companies outlined in the MFG Group Structure shown here.
This statement is approved by the Board of Directors of Motor Fuel Group.
Name: William Bannister (CEO) on behalf of the Board of Directors
Date: 23 June 2022