RAC Modern Slavery Statement

For the financial year January 2024 to December 2024

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Modern Slavery Act”). It constitutes RAC Group’s modern slavery and human trafficking statement for the financial year ending 31 December 2024.

Our structure

RAC provides a range of driving and mobility related services: breakdown assistance and related products, for both consumer and business customers; service, maintenance and repair services delivered through our mobile mechanics; and RAC branded retail insurance products underwritten by a range of leading insurers.

Our business is built around providing Complete Peace of Mind to our members for their driving needs. We are set up to deliver long term sustainable growth underpinned by a quality customer experience and enabled by digital platforms, data and our colleagues. As of 31 December 2024, RAC employs c.4,400 dedicated colleagues who carry out a broad range of roles across our breakdown and insurance divisions, Head Office and Contact Centres across the UK. In 2024, RAC’s c.1,700 strong patrol force attended approximately 2.2 million breakdowns. Full details of our businesses and subsidiaries are set out in our Annual Report and Accounts, which are available on our website.

RAC has a network of partners, contractors and suppliers which support it in running its business, both operationally and in the supply of goods and services. Although RAC’s outsourced services and supply chains are predominantly UK based, we do use a limited number of well-known and low risk third party suppliers for the provision of recovery services abroad; technology and consultancy services; and parts and products, from suppliers whose operations and/or supply chains span other jurisdictions.

We are mindful of our obligations as a responsible corporate citizen and the need to be alert to the ever-changing nature of modern slavery and the impact on our operations. We therefore continue to review and seek opportunities for further improvements in assessing and developing our approach to modern slavery as set out in this statement.

This statement applies to all companies in the RAC Group (meaning companies with RAC Group (Holdings) Limited as parent company) including RAC Motoring Services, RAC Financial Services Limited, RAC Brand Enterprises LLP and RAC Insurance Limited (the “RAC Group”).

Introduction from RAC CEO, Dave Hobday

We are committed to respecting and protecting the human rights of anyone who is affected by our operations, including employees, suppliers and contractors. This means that we take a zero-tolerance approach to offences under the Modern Slavery Act, or any other violation of human rights.

We are mindful of our responsibility to support transparency; to find and resolve problems; to review our business practices regularly; and to collaborate with others to protect the rights of workers, particularly those who are most vulnerable to abuses.

We conduct our business in a manner that protects human rights within our sphere of influence, and we are committed to upholding the principles and objectives of the Modern Slavery Act. We believe that doing the right thing builds trust, which in turn strengthens reputation and increases value. Ensuring we have a reputable and dependable supply chain not only helps us to safeguard the reputation and integrity of our business but also enables us to continue to provide a high standard of service to motorists and offer Complete Peace of Mind to our members resulting in a continued positive contribution to society.

Slavery and human trafficking: Our commitment

We acknowledge that colleagues, customers and suppliers are at the heart of everything we have achieved and are essential to our ongoing success – people are our business. To build on this, we are committed to taking all reasonable steps to ensure slavery and human trafficking do not feature in our business or supply chain. This is reflected through our internal systems and controls.

Business Environment

Many global factors continue to exacerbate the risks of people being exploited in 2024. The ongoing conflict in Ukraine, Gaza and most recently the fall of the Assad regime in Syria all create the potential for forced labour due to people being displaced from their home countries. Global economic inequality from rising living costs and unstable incomes also makes more people susceptible to modern slavery.

With UK businesses still facing cost pressures, we continue to use our policies and processes with our new and existing supply chain partners to guard against any such human rights abuses.

Modern Slavery Risk in RAC’s Supply Chain

As identified in the Global Slavery Index, RAC operates in an industry and jurisdiction where the risks of slavery and human trafficking are relatively low. Nevertheless, we acknowledge we are not immune from the risks of slavery and human trafficking and have a responsibility to be alert to any risk. We therefore ensure we are continually assessing these risks and mitigating against their occurrence through our supplier onboarding processes as well as our standard contractual requirements.

To strengthen our efforts further, we continue to build on the exercise of mapping our supply chain to increase our understanding of businesses with which we work, and to understand how their supply chains operate in turn. So far we have focused on our highest risk and business critical suppliers and are now moving on to mapping the rest of our supply chain. To date we have not identified any key risks or incidences of human slavery in our supply chain.

We have an enhanced Modern Slavery Due Diligence questionnaire which is utilised when considering contracting with suppliers who act in higher risk industries or areas. This enables us to better assess the risk of Modern Slavery entering our supply chain from the outset. Again, so far no key risks or incidences have been identified.

Policies

Modern Slavery Policy

Our Modern Slavery Policy confirms we will not tolerate or condone abuses of human rights within our business and will take seriously any allegations relating to breaches of human rights. It is an internal resource with user friendly guidance on the types of risks we should be identifying as an organisation, what steps can be taken to address these risks, and how to raise a concern. The policy is clear on the individual responsibilities of RAC colleagues and ensures we take collective corporate responsibility. The policy also reflects our commitment to acting ethically, with integrity and implementing and enforcing our policy across all our business relationships.

In addition to our Modern Slavery Policy, our ESG strategy sets out our vision for working sustainably to strengthen the RAC and create value for customers, colleagues, communities and the planet. The scope of our strategy covers safety and wellbeing, and ethical and sustainable sourcing.

Human Rights Policy

Our Human Rights Policy further enhances our approach, by stating our commitment to safeguarding human rights throughout our business and supply chain. It incorporates the United Nations Guiding Principles on Business and Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. This ensures RAC’s and our suppliers’ employees are treated fairly, with respect and dignity. It further underpins our Modern Slavery Policy by re-iterating our commitment to prevent all forms of forced labour and human trafficking.

RAC Code of Conduct

Our Code of Conduct sets out our minimum expectations on how colleagues conduct themselves at work and re-emphasises RAC’s values. RAC requires all its people to “Own It”, taking responsibility for their actions in all aspects of their work which includes taking responsibility to report any suspected wrongdoing. We ask our colleagues to “Handle it Together”, ensuring there is a zero-tolerance attitude to unlawful or discriminatory behaviour and a requirement to promote our principles of transparency, honesty, and operating in an ethical manner.

Breaches of our Code of Conduct carry potential disciplinary sanctions for RAC employees. Conversely, employees are incentivised to comply with the Code of Conduct through RAC’s reward structure.

Code of Conduct for Suppliers

RAC’s Code of Conduct for Suppliers requires that our suppliers ensure that they do not use forced labour, and that suppliers monitor and provide RAC with evidence of this in relation to their supply chains, upon request. As above, we continue to ensure all new supplier relationships, or renewals of existing relationships, reflect these requirements in our contracts, wherever possible.

Due diligence processes for slavery and human trafficking

As a first step in any purchasing process, RAC colleagues are required to undertake due diligence on any new supplier. Similarly, due diligence must be repeated annually or on significant relationship change for our material and key suppliers, and on contract renewal for all existing supplier relationships. Our internal due diligence checklist makes specific reference to considering the risks of modern slavery and human trafficking within the supplier relationship/supply chain. Any risks identified in the due diligence process (including any potential modern slavery risks) are then assessed by key stakeholders.

We have robust contract sign off processes which must be followed each time we enter into, or renew, contracts and a policy driven process for the annual review of our material and key supplier relationships. Both processes require steps to be undertaken and documented to consider, flag and appropriately deal with any risks associated with modern slavery and human trafficking. These processes provide assurance to our executive committee that appropriate due diligence has been undertaken, all risks have been considered, and appropriate actions regarding those risks have been taken.

As a minimum, every contract should require third parties to comply with all applicable laws. Our standard form contracts contain robust contractual terms to meet the requirements of the Modern Slavery Act, including controls to prevent slavery and human trafficking and an obligation to notify RAC immediately if a supplier becomes aware of any modern slavery within their supply chain.

Additionally, every contract should grant RAC a right to audit its suppliers, which allows RAC to assess a third party’s (and its employees’, agents’ and contractors’) compliance with the Modern Slavery Act.

Awareness and training

We place responsibility on every colleague in our business to uphold RAC’s legal and ethical obligations. Our policies are available to all colleagues on the RAC intranet. All colleagues, including new joiners must complete annual mandatory training on modern slavery as part of our computer based Essential Learning training programme.

The business ethics module, incorporating modern slavery prevention, forms part of the compulsory computer-based training undertaken by all new colleagues. Refresher training is undertaken by all colleagues annually. This will be updated in accordance with any future guidance published.

To emphasise the message, in line with the publication of this, our eighth modern slavery statement, we shall publish an update on the RAC intranet, to reiterate our colleagues’ obligations in supporting our commitment to combatting modern slavery and human trafficking.

Monitoring

RAC has internal procedures in place to ensure the business is clear on its obligations in respect of due diligence and ongoing reporting obligations to combat modern slavery and human trafficking. Should colleagues have concerns about modern slavery in RAC’s supply chain, they are directed to report these to our Director of Corporate Legal and/or Chief Risk and Legal Officer, who will onward report accordingly. No concerns have been reported this year regarding modern slavery.

Whistleblowing

Our Whistleblowing Policy encourages colleagues to report suspicions of wrongdoing, including suspected violations of the Modern Slavery Policy, via an independent third-party agency. Employees can report by using an online, secure web portal. Reports can be made anonymously and in confidence. All reports are directed to the Chair of the Board Risk and Audit Committee, who reviews any reported concerns and, where necessary, instructs that appropriate action is taken. No concerns have been reported this year regarding violations of our Modern Slavery Policy. Reports under the Whistleblowing Policy are reported and monitored at our Executive Risk and Audit Committee and our Board Risk and Audit Committee.

Key Priorities

Our focus for the next financial year will be to:

This statement signed on behalf of RAC’s Board of directors by Dave Hobday, CEO