Modern Slavery and Human Trafficking Statement for the Financial Year 2019
C H Jones Limited t/a Keyfuels understands the importance of conducting our business ethically and we place the same expectations on our supply chain.
This statement is made on behalf of Keyfuels, pursuant to section 54 of the Modern Slavery Act 2015 (“Act”) and sets out the steps we are taking to eliminate modern slavery from within our operations and supply chain.
We seek to reassure our customers, partners, investors and employees that modern slavery, including forced labour and human trafficking, has not unknowingly found its way into our supply chains. This statement is reviewed and, where necessary, updated prior to each new financial year demonstrating Keyfuels continuing commitment to our obligations under the Act.
Keyfuels is one of five UK based affiliated businesses owned by FLEETCOR UK Acquisition Limited which operates as a subsidiary of FLEETCOR Technologies, Inc.
Keyfuels operates out of its offices based in Walsall - Premier Business Park, Queen Street WS2 9PB and has approximately 50 staff members.
Our approach to Modern Slavery and Human Trafficking
Keyfuels is committed to adhering to and complying with the Act and does not knowingly employ or condone the use of forced labour, including child labour or bonded labour.
Recruiting of new employees includes identity, right to work and residency status checks to ensure potential employees are identified effectively and appropriately using official forms of identification. These background checks form the basis of Keyfuels being able to make an offer of employment to individuals who are successful during the interview process. Keyfuels recruits for full-time, part-time, temporary and fixed term positions.
Temporary workers are utilised within the business during periods of increased workload. However, all employees are on boarded into the business using the same defined policy and process as permanent employees and contractors.
Currently, Keyfuels does not provide standalone modern slavery training or related materials to its employees. Having said that, Keyfuels has adopted a number of supporting policy documents that highlight the company’s approach and expected standards. The current policies include but are not limited to:
- FLEETCOR UK Responsibility and Sustainability Policy
- FLEETCOR Code of Business Conduct and Ethics
- FLEETCOR UK and Europe Whistleblowing Policy
Training, including in relation to the relevant policies, is provided to all staff as part of the on boarding process and then refreshed annually, which includes a formal assessment to demonstrate understanding. Training completion rates are monitored and reported upon by the Compliance Department throughout the year.
Through our whistleblowing policy staff have the opportunity to report any unethical or illegal behaviours, such as modern slavery, through anonymous reporting to the Head of Compliance. Our Head of Compliance will independently investigate any report submitted. We have had no concerns raised by our employees regarding modern slavery throughout 2018.
The nature of our business is such that our supply chains are short. As a business, we are not directly responsible for the manufacture of goods. The production of our fuel cards is outsourced to suppliers who have their own policies, procedures and modern slavery statements relating to their provision of the services.
Keyfuels has taken the opportunity, presented through the creation of this statement, to review existing wording inserted into supplier contracts. Keyfuels continues to review its high-risk supplier contracts and where appropriate and deemed necessary, contractual provisions continue to be updated.
Risk Management /Risk Assessment
The nature of our business and our supply chain (provision of services rather than manufacturing products) is a relatively simple model, which allows us to assess the risk of potential modern slavery offences taking place as low. However, Keyfuels remains committed to ensuring modern slavery does not find a way into any existing, or future, supply chain relationships. The Keyfuels business is supported by a dedicated Legal Department who work closely with the Compliance Department and are responsible for agreeing acceptable contractual wording and the insertion of our expectations and standards into written agreements where the potential for modern slavery risk is identified.
Key performance Indicators (KPI)
Keyfuels does not currently consider its suppliers to be vulnerable to pressures around service level agreements, pricing and cost reduction. However, we remain mindful of how these areas, amongst others, can leave a business vulnerable to the risks of modern slavery, and we continue to monitor the impact of service level agreements on our suppliers. Whilst not identifying the need for KPIs to monitor performance we are to committed to regularly monitoring and reviewing our supply chain to ensure our assessment remains valid.
Modern slavery, human trafficking and forced labour continue to be one of the great human rights issues of our time. With thousands of victims of this despicable crime throughout the UK alone, it is critical that businesses act responsibly and work collaboratively to support the aspiration of eradicating this criminal activity from our society. Keyfuels remains committed to evidencing its ongoing compliance with its obligations in relation to modern slavery and will continue to monitor practices and policies to identify areas where improvements should be made.
C H Jones Limited