Morelli Group Limited

1. Introduction

This statement sets out the actions that Morelli Group Limited (Morelli) has taken to understand the potential risks to its business from modern slavery and to ensure that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to the financial year ending 31st May 2019.

Morelli recognises that it has a responsibility to take a robust approach to preventing slavery and human trafficking.

Morelli is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

2. Organisational structure and supply chains

This statement covers the activities of Morelli, based in Enfield, United Kingdom.

Morelli is a supplier of a variety of paint related materials, dry goods and consumables within the automotive repair industry sector. Our Supply Chains primarily comprise organisations within the UK or Europe and we do not normally operate outside these countries. Morelli avoids contracting with suppliers or sub-contractors located in areas where there is a higher risk of slavery and human trafficking than there is in the UK or Europe. We expect our suppliers to prevent and avoid slavery and human trafficking in their supply chains in higher risk countries. We also recognise that slavery and human trafficking does occur in the UK and Europe.

3. Morelli Group’s approach to preventing slavery and human trafficking

3.1. Relevant policies

The following policies define the steps the Morelli has taken to prevent slavery and human trafficking in its operations and supply chain:

• Code of Ethics – applicable to all Morelli employees

• Procurement Policy –this policy applies to all procurement activity in the UK and requires Morelli to adhere to social and ethical standards, and human and labour standards in the procurement of goods and services. Our standard terms and conditions for suppliers also require suppliers to uphold human and labour rights and (in the UK) to prevent slavery and human trafficking in their own operations and supply chains.

• Business Integrity Policy – it is important to Morelli that any fraud, misconduct or wrongdoing by workers or officers of the Company that would threaten the integrity of the business, including any actions that might raise the risk of slavery or human trafficking, is reported and properly dealt with. The Company encourages all employees to raise any concerns that they may have about the conduct of others in their business dealings on behalf of the Company or about the way in which the business is run using the procedures outlined in this policy.

• Policy for Recruitment/Agency workers – Morelli uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency before accepting workers from that agency. In the UK, a requirement to comply with the Modern Slavery Act 2015 will be contained in our updated supplier contracts and existing suppliers will be required to comply on renewal.

3.2. Processes and practices

3.2.1. Within our own operations

Adherence to relevant employment legislation promotes human rights and largely prevents modern slavery. Morelli has a responsibility to ensure that workers are not being exploited, that they are safe at work and that relevant employment, health and safety and human rights laws are adhered to.

A suspected case of slavery or human trafficking within the Company’s own operations should be raised using the whistle blowing policy.

Due Diligence: Morelli takes the following steps to ensure there is no slavery or human trafficking within its own operations:

• All employees have a contract of employment that sets out the rights and obligations arising from their employment, including the notice period needed for them to terminate the contract and leave the Company’s employment. Employees are free to serve notice at any time.

• The Company carries out verification of an employee’s identity and ongoing right to work in the UK and does not seek to withhold any of an employee’s identity documents or passport.

• The Company pays all its employees the living wage and adheres to all legislation in respect of working time and statutory time off, providing for minimum amounts of holiday, time off for personal emergencies, sickness and maternity/paternity leave and minimum rest breaks and periods.

3.2.2. Within our supply chain

Morelli recognises that our supply chain contributes the greatest risks for Slavery and Human Trafficking and as such our relationship with the supply base is a critical part of our commitment to eliminating modern slavery. Morelli annually procures in excess of £20m of goods and services through its supply chain, of which 85% is with organisations in the UK, 14% with companies within the European Union and North America and 1% from the rest of the world.

Morelli undertakes robust due diligence when taking on all new suppliers and regularly reviews its existing supply chain. Key suppliers have been communicated with to provide a copy of their Modern Slavery Statement, where applicable, or has been accessed through their respective websites and to provide proof of their due diligence in preventing modern Slavery and trafficking within both their own organisations and their supply chain.

3.3. Training and awareness-building

Morelli ensures that all new joiners to the company are briefed on the Modern Slavery Act 2015 as part of their induction. Employees who have roles dealing with suppliers, such as the Procurement Team, attend regular training sessions to help them understand the risks of human trafficking and how to spot potential dangers through both the initial supplier on boarding process and subsequent suppliers reviews and assessments.

4. Responsibility

Responsibility for Morelli’s initiatives addressing slavery and human trafficking is as follows.

4.1. Policies:

Responsibility for policies is:

• Human Resources – Managing Director, for policies related to the prevention of slavery and human trafficking in our own operations

• Procurement – Managing Director for policies related to the prevention of slavery and human trafficking in our supply chain.

4.2. Due diligence:

In our own operation, the Human Resources team are responsible for ensuring that the Company adheres to all employment law in the due diligence checks undertaken during different stages of employment, from initial recruitment onward.

In our procurement and supply chain management activities, the Company’s Procurement management team are responsible for undertaking due diligence activities, and for such activities related to slavery and human trafficking, they take input from other parts of the business, including Legal, HR and Sustainability.

5. Board approval

Morelli’s Board of Directors has approved this statement for the Financial Year ending on 31st May 2019

Director’s signature:
graham

Director’s name: GRAHAM PARKER

Date: 14th May 2019