Modern Slavery Act

Modern Slavery Act 2019 Statement

The Lind Group believes it is our responsibility to uphold the highest standards of ethical behaviour and personal integrity within our business operations. Wherever we do business, our employees are required to comply with all applicable laws, rules, and regulations.

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person's liberty and dignity for another person's gain. Lind has a zero-tolerance approach to modern slavery, and is fully committed to preventing slavery and human trafficking in our operations and supply chain. As a company we are committed to protecting our organisation and those people at risk from exposure to slavery or human trafficking in our supply chain, both via our direct employees and those working on our behalf via third party suppliers.

Organisational Structure and Background​
The Lind Group represents premium automotive brands including BMW Motorrad, Harley-Davidson, Porsche and Triumph from 9 dealerships across the UK. We're continually investing in our facilities, employees, business partners and customers to ensure we uphold our values and founding principals of Excellence, Integrity and Service. This is why we're recognised year after year for delivering exceptional customer experiences and our employees are renowned for their passion, enthusiasm and knowledge.

The Lind Group is a trading style of Lind Group Holding Company Limited which is a company registered in England with the company number: 06497578, our registered address is: Brook Farm, Five Oak Green Road, Tonbridge, Kent, TN11 0QN. Our subsidiary companies which are covered by this statement include: Lind AG Limited (trading as: Porsche Centre Tonbridge), Lind Motorrad Limited (trading as: Lind Motorrad), Lind US Limited (trading as: Lind Harley-Davidson, Guildford Harley-Davidson, Newmarket Harley-Davidson, Norwich Harley-Davidson, Reading Harley-Davidson and Lind H-D) and Lind Triumph Limited (trading as: Jack Lilley, Jack Lilley Triumph, Lind Triumph, Triumph East London, Triumph London and Triumph North London).

Our Employees
Our employees are all provided with a written contract of employment as well as access to a company handbook which contains any policy that governs their employment. Each employee has a personal responsibility to read the handbook, as well as to ensure that they fully understand our obligations and the consequences associated with any breach of those obligations. We are committed to uncompromising integrity in all that we do and how we relate to each other and to our customers.

It is a fundamental policy of Lind Group to conduct business with honesty and integrity and in accordance with the highest standards of ethics, equality and fair dealing. We appreciate the key role that Lind Group employees play in maintaining high standards and ensuring as a business we are compliant in all aspects of regulations set forth by the UK Government.

We encourage our employees to report any concerns related to the direct activities, or the supply chain of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. These reports are reviewed by the most senior directors of the Lind Group.

Our Third Party Supply Chain
The Motor Trade supply chain is one of the most complicated in any industry. The breadth, depth and interconnectedness of the automotive supply chain make it challenging to effectively manage and mitigate the risk of modern slavery. We also recognise that the nature of the motor industry is such that our supply chain for new and used vehicles is multifaceted as any given vehicle will have its own supply chain for the various component parts. We therefore understand that ultimately our vehicle supply chain begins with the sourcing and manufacturing of the raw materials required for any part of a vehicle. As our relationship is with the vehicle manufacturer and not with their supply chain, we're keen to engage with our suppliers to ensure that they match our high standards and the ethos of the Modern Slavery Act 2015 and filter this message down throughout their own supply chain.

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains and expect the same high standards from all of our contractors, suppliers and other business partners. We establish a relationship of trust and integrity with all our suppliers, which is built on mutually beneficial factors. The use of service provider contractors in our organisation is largely within our facilities support area but not limited to this part of our business.

Due Diligence
We have conducted a risk assessment of our business to assess the risk of modern slavery and human trafficking. Based upon the results of this assessment and as part of our initiative to identify and mitigate risk, we have undertaken the following actions:

  • Built the assessment of slavery and modern trafficking risk into our supplier due diligence process for areas of the business we deem to be high risk. We carry out appropriate due diligence on the supplier, including requiring them to complete a questionnaire on their own policies concerning the issue.
  • Developed a new Code of Conduct that highlights the standards of compliance expected from all third party suppliers in areas of the business we deem to be high risk. Third party suppliers and contractors we deem to be in high risk business areas are required to sign to say that whilst carrying out its obligations to the Lind Group they shall comply, and seek to ensure that each of its own subcontractors and suppliers involved in the provision of goods and services, comply with Lind Group Modern Slavery Act Code of Conduct.
  • Developed and implemented training to our Management Teams to identify, assess, mitigate and report specifically on modern slavery.
  • Developed and communicated our modern slavery policy to our employees and those who we conduct business with.
  • Ensured that our confidential employee reporting line is clearly promoted in all of our sites.
  • Designed and developed a Modern Slavery poster that gives a brief overview of the signs to look out for, including how employees can report concerns regarding modern slavery. These posters are displayed in our employee areas throughout our business.

Whilst ultimately the majority of risks within the business rest with our manufacturers and suppliers we are not complacent and will continue as a Company to seek to identify and manage any potential risks associated with Modern Slavery. We have endeavoured to put safeguards in place to ensure, so far as is reasonably practicable, that the working practices of those employed directly by us and those with whom we have a direct contractual arrangement with also have a similar zero tolerance to modern slavery.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes the Lind Group Holding Company Limited and it's subsidiary companies modern slavery and human trafficking statement for the financial year ending 04 April 2020.

Russ Dacre MBE - Owner and Managing Director, Lind Group