Modern Slavery Policy
Transdev plc and subsidiaries, Modern Slavery and Human Trafficking Statement 2018
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and is the Transdev plc slavery and human trafficking statement for the financial year ended 31st December 2018
Transdev plc is the holding company for a group of companies providing transport services in the UK. The principal trading entities are Transdev Blazefield Limited and Comet Car Hire (CCH) Limited. Transdev plc is in turn a wholly owned subsidiary of Transdev Group, a global provider of transport services incorporated in France and whose ultimate parent undertaking is Caisse des Dépôts et Consignations, a French public sector financial institution.
Transdev plc and its subsidiaries operate wholly within the UK and its suppliers are also predominantly based in the UK or Western Europe. We therefore consider that the risk of the business contracting with organisations engaged in or exposed to slavery or human trafficking is relatively low.
Our Commitment and Group Policies
Transdev Group and its subsidiaries are committed to achieving high standards of corporate social responsibility, underpinning its support for the United Nations’ Global Compact which Transdev has been a signatory to since 2003.
Transdev’s mission is to empower freedom to move for everyone every day. This places us at the heart of everyday life in our territories. It makes us a key player committed to serving general interests, developing local services and protecting the environment.
Because we are people serving people, we are committed to protect human rights in our activities, in all relations with our stakeholders:
- Workers must have a safe and healthy working environment that meets or exceeds applicable standards for occupational safety and health.
- Working hours must comply with applicable local laws regulating hours of work.
- Wages, compensation and benefits must comply with local law, including those relating to minimum wages, overtime hours and legally mandated benefits
- Harassment or discrimination against employees in any form is not acceptable. This includes, but is not limited to, gender, race, colour, caste, disability, veteran status, union membership, political beliefs, origin, religion, age, pregnancy or sexual orientation.
- Workers must be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation or harassment.
- Workers must have the right to associate freely, join labour unions, seek representation and join workers’ councils in accordance with local laws.
- We interact with local communities on the human rights impacts of our operations
More specifically, Transdev is adamantly opposed to any form of modern slavery.
- Child Labour must not be utilised and age of employment must be in accordance with local labour law and international standards
- Any form of forced or compulsory labour is unacceptable.
In addition to the Transdev Group Human Rights Statement detailed above, Transdev adheres to a Code of Ethics which outlines our ethical principles and reflect our commitment and the Group’s undertakings to all stakeholders. They also convey all the values that make Transdev a passionate, committed Group, and a high-performing reliable partner. It must be upheld by all our suppliers and service providers who undertake to respect it through our Supplier Charter. This Charter is aimed at ensuring that all suppliers to the Group adhere to high standards of ethical, environmental and social behaviour.
Due Diligence and Management
Ethics and Compliance at Transdev is monitored through the Transdev Ethics & Compliance Committee. This Committee is managed at Transdev Group level by the Risks, Engagements and Ethics Department, which co-ordinates, drives and monitors the deployment and application of the Transdev Group’s Ethics & Compliance policy. The Committee meets to evaluate successes achieved, difficulties encountered and incidents recorded. It can meet on an ad-hoc basis to discuss any sensitive issues.
Ethics and Compliance are upheld by:
- the Transdev Group Executive Directors and the entire management line,
- the Transdev Group Risks, Engagements and Ethics department,
- the Ethics and Compliance Coordinator of each operating country. The Ethics and Compliance Coordinator for the UK is Peter Brogden.
Within the UK specifically, Transdev operates a confidential whistleblowing hotline which can be used by all staff to report instances of concern in relation to modern slavery and human trafficking.
Training and KPI’s
In addition to our commitment to the Transdev Group Ethics and Compliance Committee we ensure that our senior managers in the UK receive appropriate training and that this is disseminated through the organisation.
Following a review of the actions taken this year to ensure our Group Human Rights Policy, Code of Ethics and Supplier Charter are fully integrated into the UK businesses we have identified further steps to be taken during the coming year which include:
- Increased visibility of the Modern Slavery Statement, Group Code of Ethics and Group Human Rights Statement at local level through incorporation onto the company mobile applications
- Increased frequency of UK Leadership team reviews
- Review content of current training undertaken
Company Secretary, Transdev plc