RAC Modern Slavery Statement 2019 - 2020

For the financial year January 2019 to December 2019

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It constitutes RAC Group’s modern slavery and human trafficking statement for the financial year ending 31 December 2019.

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

Introduction from RAC CEO, Dave Hobday

With a history dating back to 1897, we, at RAC, 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.

Over the course of our long history, RAC has established a reputation and brand that is built on trust and respect. We acknowledge that colleagues, customers and partners are at the heart of everything we have achieved and are essential to our ongoing success – people are our business. In order to build on this, we are committed to taking all reasonable steps to prevent any acts of modern slavery or human trafficking occurring within our supply chains. As such, we continue to assess our internal systems and controls to ensure they remain effective.

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 aim to empower RAC colleagues to take action against wrongdoing by making the reporting process as simple and stress-free as possible. This is enshrined in our Whistleblowing Policy. Aimed principally at RAC colleagues, this encourages them to report any wrongdoing, including any suspected violations of the Modern Slavery Act 2015, via an independent third party agency. Reports can be made anonymously and in confidence and all reports are directed to the Chair of the Board of Risk, Audit and Compliance 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 followed at all stages of a commercial relationship.

As a first step in the process, RAC colleagues are required to undertake due diligence on any new supplier. This year, the due diligence checklist was refreshed and now makes specific reference to considering the risks of modern slavery and human trafficking. Guidance is provided to colleagues in plain English with links to further resources and contact details of escalation points if a colleague suspects that an instance of modern slavery may have occurred. The guidance is published internally and is also available as a link on the intranet.

Our contract approval documentation is completed as part of our internal sign off process each time we enter into a new contract or where a contract is renewed. It requires confirmation that the risks associated with modern slavery and human trafficking have been considered and provides a specific opportunity to flag issues, and to list actions taken to remediate those issues. This provides assurance to our executive board that an appropriate level of due diligence has been undertaken and that we have appropriate contractual provisions reflecting the risks.

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 audit rights to RAC. As part of our commitment to continuous improvement, we have commenced a review of our standard form 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, RAC has the right to audit our suppliers which, amongst other things, assess compliance with the Modern Slavery Act.

Awareness and training

This year RAC launched its new RAC HERO Values; Handle it Together, Exceptional Service, Raise the Bar and Own It. Defining the values was an important step in defining the corporate culture which at its core embeds acting with integrity and being fair. This sets the expectation on employee behaviour, as the values were jointly developed with colleagues and born from customer feedback.

The first of these values, “Handle it together”, requires colleagues to work as one team, showing trust, respect, fairness and integrity. As part of this, colleagues must protect and promote principles of operating in a transparent, honest and ethical way and are encouraged to take personal responsibility for reporting any instances of actual or suspected wrongdoing.

As enshrined in these values, 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 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 reinforce the message, in line with the publication of this, our third 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 dedicated colleagues who carry out a broad range of roles within our Roadside Operations, Head Office and Contact Centres across the UK. In 2019, RAC’s patrol force of approximately 1,500 patrols attended 2.4 million breakdowns.

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).

As an innovative organisation, RAC is aware of the emerging risks and the need to be alert to the ever-changing nature of modern slavery and the impact on our operations. RAC will therefore continue to review, develop and extend its approach to modern slavery.

This statement has been formally approved by the RAC Board of Directors on 27 January 2020 and signed on its behalf.

Dave Hobday, CEO
Date: 27 January 2020