Modern Slavery Statement 2018 - 2019

For the financial year January 2018 to December 2018

Introduction from RAC CEO, Dave Hobday

As an organisation, with a history dating back to 1897, we have a strong ethos of care and responsibility which means that we take a zero-tolerance approach to offences under the Modern Slavery Act 2015, or any other violation of human rights. We require the same from our suppliers, contractors and anyone else with whom we do business.

We are committed to upholding the principles and objectives of the Modern Slavery Act 2015. Ensuring that we have a reputable and dependable supply chain helps safeguard the reputation and integrity of our business and enables us to continue to provide a high standard of service to our members.

Slavery and human trafficking: our commitment

All members of the RAC Group are committed to helping combat slavery and human trafficking.

We promote protecting the integrity of our business as fundamental to how we operate. We are committed to taking all reasonable steps to prevent any acts of modern slavery or human trafficking occurring anywhere within our supply chains. As such, we continue to assess our internal systems and controls to ensure they are effective and improved where possible.

Our Modern Slavery Policy confirms that we will not tolerate or condone abuses of human rights within any part of our business and will take seriously any allegations that human rights have not been properly respected. Our Modern Slavery Policy 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 that as a business we take collective corporate responsibility. The policy also 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. Our Human Rights Policy further enhances our approach in this vitally important area.

We have also updated our Whistleblowing Policy. Aimed principally at our colleagues, this encourages them to report any wrongdoing, including any suspected violations of the Modern Slavery Act 2015. In October 2018, a new 24/7 service was launched, allowing colleagues to anonymously report concerns to an independent third party, Expolink. All complaints are referred to the Chair of the Risk and Audit Committee, who will review the concern and where necessary instruct that appropriate action be taken.

Due diligence processes for slavery and human trafficking

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 that no sector or industry is immune from the risks of slavery and human trafficking and we have a responsibility to be alert to the risk, however small. As such we have a set of standard requirements which must be incorporated into all of our contracts. This provides assurance to our executive board that we have appropriate contractual provisions in place with our customers and suppliers.

Our ‘Golden Rules’ document is completed as part of our internal sign off process each time we enter into a new contract or where a contract is renewed. Any deviation from the Golden Rules must be highlighted to the executive board for approval.

All RAC colleagues are directed under the Golden Rules to undertake due diligence on any new supplier. We have produced some user friendly, common sense guidance to what this due diligence exercise might entail. This is published internally and is also available as a link on our new supplier application form.

Every contract should contain a provision requiring suppliers to comply with all applicable laws in the supply of goods and performance of services and granting RAC audit rights. Our Golden Rules specifically instruct colleagues to consider the risk of slavery and human trafficking. As part of our commitment to continuous improvement, we have commenced a review of material contracts to ensure that each contract contains 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.

In addition, to provide further assurance that the risk of modern slavery and human trafficking is being addressed, our suppliers are subject to audit checks which, amongst other things, assess compliance with the Modern Slavery Act.

Awareness and training

We place responsibility on every colleague in our business to uphold our legal and ethical obligations. Our Modern Slavery Policy is available to all colleagues on our intranet. To reinforce this message, and to ensure we can audit understanding and awareness, all colleagues must complete 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 reinforce the message, in line with the publication of this, our second modern slavery statement, we have published an update on the RAC intranet, to reinforce the message to all colleagues of the role everyone in the organisation must play in supporting our commitment to combatting modern slavery and human trafficking.

Monitoring

RAC has in place internal procedures to ensure that the business is clear on its obligations in respect of due diligence and whistleblowing to combat modern slavery and human trafficking.

Specifically, we have in place systems to:

We also have a dedicated legal and compliance team, which consists of:

Who we are

RAC is a leading consumer motoring services organisation serving both private and business motorists. It does this through a nationwide, branded patrol base focusing primarily on vehicle repair and recovery. RAC also supports motorists with roadside assistance, insurance, buying used cars, vehicle inspections, telematics data and legal services.

RAC employs around 4,000 people who carry out a broad range of roles within our Roadside Operations, Head Office and Contact Centres across the UK. RAC has a network of partners, contractors and suppliers who support it in running its business, both operationally and in the supply of goods and services. RAC’s outsourced services and supply chains are predominantly UK based, other than recovery abroad and the wider supply chains for certain parts and products. RAC has a limited number of suppliers, direct and indirect, in higher risk jurisdictions (as identified in the Global Slavery Index).

This statement applies to all applicable companies in the RAC Group (meaning companies with RAC Group Limited as parent company) including, without limitation, RAC Motoring Services, RAC Financial Services Limited, RAC Brand Enterprises LLP and RAC Insurance Limited.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's modern slavery and human trafficking statement for the financial year January 2018 to December 2018.

Dave Hobday, CEO
Date: 28 March 2019