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MODERN SLAVERY STATEMENT & POLICY

INTRODUCTION

This document sets out the Modern Slavery statement and policy of EG On The Move Ltd, a company registered in England and Wales with company number 14960308 and registered office at Waterside Head Office, Haslingden Road, Guide, Blackburn, Lancashire, England, BB1 2FA is committed to preventing slavery and human trafficking in its business and supply chains, and to ensuring that its operations are conducted ethically and responsibly.
We have developed and implemented a Modern Slavery Policy, which reflects our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business or supply chains.
Our Modern Slavery Policy is aligned with the principles and standards of the United Nations Universal Declaration of Human Rights, the International Labour Organization's Declaration on Fundamental Principles and Rights at Work, and the UK Modern Slavery Act 2015.
The policy sets out our expectations and requirements for our suppliers and service providers, as well as our due diligence and risk assessment processes, our reporting and monitoring mechanisms, and our training and awareness-raising initiatives.

POLICY STATEMENT

EG On The Move is a Fuel Convenience and Food retailer employing over 1,700 staff in the UK . Our procurement activities take place in our head office in Blackburn (UK)

At EG On The Move, we are committed to delivering world-class convenience retail whilst improving the lives of others and delivering a positive impact on society.
We seek to act ethically and with integrity in all our business dealings and relationships and to imple-ment effective systems and controls to ensure modern slavery is not taking place anywhere in our busi-ness or in any of our supply chains.
We recognise that all businesses must be alert to risks of modern slavery and labour exploitation in the workplace and we are committed to taking a proactive approach to identify and mitigate risks.

OUR BUSINESS AND SUPPLY CHAINS

  • For Resale -
    We work with retail brand partners to deliver products and services to our customers across Grocery & Merchandise, Foodservice and Fuel. We aim to work with trusted brand partners that are well recognised globally or in their local markets and that have well-established Environmental, Social & Governance (ESG) policies and programs, including due diligence on human rights and modern slavery.
  • Good and Services Not for Resale -
    We also procure equipment and services from a range of suppliers and contractors to support our business, including for example: uniform suppliers, logistics companies, waste contractors, cleaning and landscaping contractors, construction and refurbishment companies, IT equipment and services.

SCOPE

The policy applies to all our employees, directors, officers, contractors, consultants, agents, and anyone else acting on our behalf.
The policy is available on our website and intranet and is incorporated into our contracts and agreements with our suppliers and service providers.

OUR DUE DILIGENCE AND RISK ASSESSMENT

We have conducted a risk assessment of our business and supply chains, taking into account factors such as the nature, location, and complexity of our operations, the sectors and markets we operate in, and the types and sources of our suppliers and service providers. We have identified the following areas as potentially high-risk for modern slavery and human trafficking:

  • The procurement of hardware and software from countries or regions where labour standards and human rights are not adequately enforced or protected, such as China, India, and Southeast Asia.
  • The outsourcing of some of our business functions to third-party service providers who may employ migrant workers, temporary staff, or subcontractors, who may be vulner-able to exploitation, abuse, or coercion.
  • Employment of staff, and the potential to provide fraudulent Right to Work documen-tation

We have implemented a due diligence process for our suppliers and service providers, which includes the following steps:

  • Requesting and reviewing information and documentation on their policies, proce-dures, and practices relating to modern slavery and human trafficking, such as codes of conduct, audit reports, certifications, and training records.
  • Evaluating and verifying their compliance with our Modern Slavery Policy and the UK Modern Slavery Act 2015, as well as with any applicable laws and regulations in their countries or regions of operation.
  • Conducting site visits and audits, either by ourselves or by independent third-party auditors, to assess their working conditions, labour standards, and human rights per-formance.
  • Requiring them to report any incidents or allegations of modern slavery and human trafficking in their business or supply chains, and to take appropriate remedial actions.
  • Terminating or suspending our relationship with them if they fail to comply with our Modern Slavery Policy or the UK Modern Slavery Act 2015, or if they are found to be involved in any form of modern slavery and human trafficking.
  • Supplier code of conduct requiring suppliers to confirm that they prohibit the use of forced, compulsory, bonded (including debt bondage) or indentured labour, involun-tary prison labour, slavery, servitude or trafficking of persons and unlawful child la-bour.

SUPPLIER CERTIFICATION, PROCUREMENT AND CONTRACTS

EGOTM require all current suppliers to certify their compliance with our Supplier Code of Conduct, or in the case of large corporate suppliers and franchisors, their own equivalent standard code.

OUR REPORTING AND MONITORING

We have established a reporting and monitoring system to measure and evaluate our progress and performance in preventing and combating modern slavery and human trafficking in our business and supply chains. The system includes the following elements:

  • Collecting and analysing data and information on our suppliers and service providers, such as their compliance status, audit results, incident reports, and corrective actions.
  • Tracking and reviewing our key performance indicators, such as the number and per-centage of our suppliers and service providers who have signed and adhered to our Modern Slavery Policy, the number and percentage of our suppliers and service pro-viders who have undergone due diligence and risk assessment, and the number and nature of any incidents or allegations of modern slavery and human trafficking in our business or supply chains.
  • Reporting and disclosing our activities, achievements, and challenges in relation to modern slavery and human trafficking, both internally and externally, such as through our annual Modern Slavery Statement, our corporate social responsibility report, our website, and our stakeholder engagement.
  • Seeking and obtaining feedback and input from our staff, suppliers, service providers, clients, and other relevant stakeholders, such as through surveys, interviews, consulta-tions, and complaints mechanisms.
  • Conducting regular reviews and evaluations of our Modern Slavery Policy and our re-porting and monitoring system and making improvements and adjustments as neces-sary.
  • Including right to work checks as part of our ongoing site audit requirements.

OUR TRAINING AND AWARENESS RAISING

We have developed and delivered a training and awareness-raising program to educate and inform our staff, suppliers, service providers, and other relevant stakeholders about the risks and impacts of modern slavery and human trafficking, and the roles and responsibilities of each party in preventing and combating them. The program includes the following components:

  • Providing mandatory online training courses on our Modern Slavery Policy and the UK Modern Slavery Act 2015 to all our staff, directors, officers, contractors, consultants, agents, and anyone else acting on our behalf, and requiring them to complete an as-sessment and sign a declaration of compliance.
  • Tracking and reviewing our key performance indicators, such as the number and per-centage of our suppliers and service providers who have signed and adhered to our Modern Slavery Policy, the number and percentage of our suppliers and service pro-viders who have undergone due diligence and risk assessment, and the number and nature of any incidents or allegations of modern slavery and human trafficking in our business or supply chains.
  • Distributing and disseminating materials and resources on modern slavery and human trafficking, such as leaflets, posters, brochures, newsletters, and videos, to our staff, suppliers, service providers, clients, and other relevant stakeholders, and making them available on our website and intranet.
  • Encouraging and supporting our staff, suppliers, service providers, and other relevant stakeholders to report any suspicions or concerns of modern slavery and human traf-ficking in our business or supply chains and providing them with clear and confidential channels and procedures to do so, such as a dedicated hotline, email address, or online form.
  • Partnering with NGOs to help educate our teams and provide confidential support when needed.

RISKS WE HAVE IDENTIFIED

  • Suppliers of EGOTM branded items in higher risk sectors – this includes suppliers of EGOTM staff uniforms, electric vehicle (EV) charging equipment and EGOTM branded electronic goods for resale.
  • Direct use of Labour providers to provide temporary staff at our sites. Our stand-ard policy excludes the use of Agency Labour.
  • Indirect use of labour providers to provide services to us, such as cleaning, logis-tics, construction, maintenance and site refurbishment.
  • Note that we have automated car washes on our forecourts at some locations, and also jet washes that are operated by our customers. We recognise that there are higher risks of modern slavery in the car wash sector, but these apply to attended hand car washes.

CONTROLS IN PLACE

  • Thorough Right To Work checking prior to recruitment, and ongoing monitoring of expiring visa documentation.
  • We are committed to ethical and socially responsible conduct in the workplace. We seek to comply with all employment legislation.
  • Code of Conduct required to be signed at onboarding and updated and re-communicated on a regular basis.
  • Published Whistleblowing Policy which gives employees, suppliers, customers and members of the public a confidential and anonymous access to report cases.
  • (Partnership with NGOs to provide continuing support education and advice)
  • Publicised Policies available to all staff; Modern Slavery, Whistleblowing, Dignity at Work, Anti-Bribery & Corruption.

CONCLUSION

We recognise that modern slavery and human trafficking are complex and evolving issues that require ongoing vigilance and collaboration. We are committed to continuously improving our policies, procedures, and practices to ensure that we are doing our part to eradicate these heinous crimes from our business and supply chains, and to uphold our values and standards of ethical and responsible conduct. We welcome any feedback or suggestions on how we can further enhance our efforts and performance in this regard.

This policy is not part of your contract of employment and does not create any contractual rights or obligations. It is intended to provide guidance and information on how we manage certain aspects of your employment. We may amend, suspend or revoke this policy at any time, with or without notice or consultation, at our sole discretion. Any changes will be communicated to you as soon as possible. This policy does not affect your statutory rights or any other contractual terms that apply to your employment. You should read this policy carefully and familiarise yourself with its contents. If you have any questions or concerns about this policy or how it applies to you, please contact your line manager or the HR department.