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This Statement is made pursuant to Section 54 (Part 6) of the Modern Slavery Act 2015 (‘Act’) and sets out the steps that The Colt Car Company Limited (‘CCC’) has taken during the previous financial year to ensure that slavery and human trafficking is not operating within either its own business or its supply chains.
This Statement has been approved by the Board of Directors and signed by Junichi Iwata, the Chairman of CCC.
CCC is the sole importer and distributor of Mitsubishi vehicles, parts and accessories in the United Kingdom. It is a wholly owned subsidiary of Mitsubishi Corporation based in Japan.
CCC works in alliance with an independent network of Mitsubishi franchised dealers throughout the United Kingdom. Whilst these dealerships are neither owned nor controlled by CCC, it nevertheless remains an important requirement that they operate to the same anti-slavery and anti- human trafficking principles applied by CCC in relation to its own business and to that of its supply chain.
CCC is also a minority stakeholder in a joint venture vehicle called Shogun Finance Limited which provides retail credit facilities to customers and used vehicle stocking finance to franchised dealers.
CCC’s Corporate Code of Conduct provides a set of rules based on both national and international standards to ensure CCC’s employees are upholding the highest level of ethical conduct in their day-to-day business.
CCC strives to ensure that it does not contribute towards adverse human rights impacts through its supply chains. There is an ongoing commitment to engage only those suppliers that uphold the same principles as CCC and where necessary ensure the implementation of corrective action measures. In the event that suppliers fail to take steps to cease or prevent adverse human rights impacts, CCC will reconsider its business relationships with those suppliers.
CCC source a wide range of goods and services from suppliers based in the United Kingdom and overseas.
In all of its dealings with those suppliers it strives to ensure that the highest ethical standards are reached at all times. As part of this ongoing requirement, there will be increased focus on the requirement for a long term commitment by those suppliers to eradicate slavery and human trafficking in their own businesses and supply chains.
An internal audit of all CCC direct suppliers has presented us with no immediate concerns. The vast majority of those suppliers are based in the United Kingdom and have been assessed as posing minimal risk in terms of non-compliance with the Act. In the case of those suppliers based abroad or that source goods from high risk countries outside of the UK, the manufacturing and production processes for CCC’s product lines are not fully visible and further investigation into these areas is yet to be undertaken but CCC will be requesting written undertakings from those suppliers in order to satisfy itself of their ongoing ability to comply with the Act.
A review of CCC’s existing Corporate Code of Conduct was conducted to ensure its relevance and compliance with the Act. A copy of the Corporate Code of Conduct can be found here.
A standard supplier contract clause has been drafted requiring compliance with the Act. In some more pertinent cases this will include enhanced audit/termination rights to ensure more vigilant monitoring of high risk suppliers.
CCC recognises the importance of maintaining constant vigilance to identify and address any impacts associated with slavery and human trafficking throughout its supply chains. In recognition of the salience of these issues, CCC’s is committed to continuing to enhance its capacity to identify, prevent and mitigate any actual or potential impacts in this field.