Modern Slavery Statement
This statement covers the activities of ParkingEye Ltd. and is our Modern Slavery statement for the financial year ended 31 December 2020 required under the provisions of the Modern Slavery Act 2015 (the “Act”).
Modern slavery in all its forms of slavery and servitude, forced or compulsory labour and human trafficking is a heinous crime and we will not tolerate any such activities within our own operations or our supply chain. We are committed to stamping out modern slavery and are taking the appropriate steps to ensure that everyone who works for ParkingEye benefits from a working environment in which their fundamental human rights are respected and that our supply chain upholds these principles.
The information in this statement details policies, processes and actions we have taken to ensure that slavery and human trafficking are not taking place in our supply chains or any part of our own business.
Our business and supply chain
ParkingEye Limited provide car park management services and car parking facilities to our clients and users combining our talent, creativity, software, technology and innovation with sector knowledge and proven skills and expertise underpinned by our scaled operational platforms. We provide Car Park Management Services for all sectors: NHS Hospitals and Medical Centres; Retail Outlets, Retail Parks; Supermarkets; Pubs and Restaurants; Hotels; Motorway Services; Transport; Education; Professional and Standalone Businesses; and Leisure and Tourism.
Established in 2004, ParkingEye has grown to become the largest supplier of Automatic Number Plate Recognition (ANPR) systems in the UK and has 3,500 parking facilities nationwide, 30% annual growth across the business and Zero sanction points on BPA AOS membership licence.
We were acquired by Macquarie Principle Finance and funds advised by MML Capital Partners in November 2018. From October 2013 to this acquisition, the Company was part of Capita plc. We are backed by bank and private equity investment and sits within a typical private equity holding company structure. ParkingEye Limited is the primary trading entity and takes responsibility for procurement for the Peggy Holdco Limited group. Our CEO, Philip Boynes, is ultimately responsible for Act compliance and good practice, supported by the Procurement, Legal, Risk and Compliance, HR, Health and Safety, Operations and Finance Functions and the wider Exec Team who support the business, setting boundaries and standards in driving commercial performance, whilst managing risk and ensuring a strong system of internal control.
ParkingEye has grown each year to the stage where we currently employ well over 350 members of staff based out of our Chorley offices and in the field. Although most of our workforce are recruited on a permanent basis, we use temporary staff within our admin and attendant services teams and use outsourced labour in IT, admin, technical and field operations.
Our key supplies are of data services, ANPR camera and payment machines to support our car park management offering. The majority of our supply relationships are long-standing, with less than 10% being new in the current financial year.
We use a limited range of third party suppliers 99.5% are within the UK with the remaining suppliers all being European based and of the 360 suppliers the breakdown is as follows:
Direct Supply of Goods and/or services: 350 88% of spend
Distributor Supply of Goods: 6 5% of spend
Sub-contract labour: 4 7% of spend
We actively encourage supplier diversity and currently the majority of our supply base are classed as small and medium sized enterprises (SMEs).
ParkingEye has reviewed its take on processes so that it undertakes relevant checks, (including requiring the details of sub-contracting) on Suppliers, in the onboarding process and thereafter.
When awarding contracts to suppliers in a tender, ParkingEye’s procurement team strives to understand the policies and practices of these suppliers and carries out more detailed due diligence checks for larger procurements.
Our company policies
The following company policies support us in ensuring that modern slavery is not taking place in our business or in our supply chains or business:
Employee Handbook: Provides a high-level summary of key areas of our policies and standards, providing a framework to ensure our people do the right thing; our stated expectation of our employees includes promoting good working practices. It also provides signposting to the Equality & Diversity Policy, Anti-harassment & Bullying policy, Speak Up Policy, Open Door Policy and Safety, Health and Environment Policy, which go into more detail of our approach in these areas.
Human Rights Policy, Ethical Code Statement and Corporate Responsibility Policy: commits to ensure appropriate procedures are in place to prevent any breaches to international human rights standards, including the United Nations’ Universal Declaration of Human Rights (UDHR), the International Labour Organisation (ILO) core conventions on Labour Rights and the United Nations Guiding Principles on Business and Human Rights Procurement Policy: sets out our strategic approach and the key principles and priorities that apply to all ParkingEye’s procurement activity ensuring we have control over our external expenditure and effectively manage our supply chain risks, set out our expectations of suppliers in terms of ethical procurement, financial soundness, information technology and data security and governance. It details the due diligence and risk assessment that is conducted on all suppliers ensuring compliance to relevant legislation including the Act.
These policies are available to all employees via our intranet site. The policies are managed by relevant department heads, and our risk management framework and reporting processes support the escalation of policy issues and management where identified in our business.
ParkingEye will look to develop a separate modern slavery policy for the year to 31st December 2021
Tackling modern slavery – our people
To ensure that we recruit and treat employees fairly, avoiding modern slavery at all costs, our human resources (HR) policies set out our procedures on how we:
- recruit and select employees in a fair, lawful and professional manner, both for internal and external candidates
- treat all employees fairly during their employment and, if there is an occasion when an employee does not feel that they have been treated fairly, there are procedures in place to raise a grievance or involve local trade union or other employee representative, where relevant, or where this is a legal requirement to do so
- manage the exit of an employee from the business in a fair and consistent manner.
and we ensure there are contractual obligations to ensure appropriate checks are undertaken by external recruiters.
Our Human Rights Policy details our commitments to labour and workplace rights. We provide fair working conditions for all our employees including terms and conditions of employment, remuneration, working hours, health and safety, resting time, holiday entitlements and benefits.
Our employees’ pay will not be lower than that required by law and under 25s are paid the minimum wage for 25 and overs. Hours of work will be in line with the norm within that industry and in accordance with legislation and shall not be excessive. Employees shall not be contractually required to work more than 48 hours per week and overtime will only be worked on an optional basis. Forced or compulsory labour is prohibited. Employees will not be forced into involuntary labour and coercion at work is not acceptable. Financial penalty as a disciplinary sanction is prohibited. The employment models deployed will be in line with specific law and practices. Under these practices there will not be excessive use of alternative models, such as sub-contracting or labour-only contracting.
Employees can raise ethical concerns through our Open Door Policy and Speak Up Policy. Concerns about slavery and human trafficking would be considered to be an ethical concern and employees can raise these concerns openly and at any time in confidence.
In addition to this, we seek feedback from employees where we gauge how our people feel about working at ParkingEye. This enables managers to identify potential issues around culture that could lead to a failure of ethics, controls or governance before they occur. Slavery and human trafficking would be picked up as a potential issue through this assessment.
We recognize the following areas of HR procurement as presenting a greater risk of modern slavery. Workers sourced via third party agencies and outsourced providers.
Tackling modern slavery – our supply chain
We seek to partner with suppliers who uphold our high standards of social, environmental and ethical conduct providing safe working conditions, treating workers with dignity and respect, acting fairly and ethically, and using environmentally responsible practices where practicable.
Analysis of our supply chain suggests that almost all of it is UK based. We have over-seas spend with only 3 suppliers, accounting for less than 0.5% of total spend. Given the robust UK legislative framework, the risk of infringement for our suppliers is low. Nevertheless, we recognise our responsibility to identify and address potential infringements linked to the goods and/or services we procure. We recognise the following areas of procurement as presenting a greater risk of Modern Slavery, the outsourcing of IT development work to third party resource in Poland and technical and business operations admin workstreams to a third party business utilising resource in India. We are putting in place a due diligence toolkit for outsourced labour to help us manage these higher risk areas.
During Q1 2020, we have undertaken a review of key suppliers within our Supply Chain both with a view to reducing complexity through consolidation and ensuring our supplier due diligence processes are kept current. As part of this process, we have also identified opportunities to further strengthen our ability to prevent and manage the risks of modern slavery in our supply chain, updating our Procurement Policy and Supplier Contract Terms and Conditions to reference the obligations of the Act. ParkingEye’s procurement team works with colleagues and suppliers to ensure that all necessary due diligence checks are undertaken. If risks are identified during our due diligence, we work with suppliers to address them. Once a supplier is approved, we assess their record on human rights, social and environmental issues as an ongoing task and in 2020, plan to audit the top 80% of our current suppliers, by spend in year and 100% by the year ending 31 December 2023.
All suppliers are expected to comply with our Supplier Standards set out within ParkingEye’s Procurement Policy and we are implementing a stronger communications strategy in 2020 to ensure visibility of our policies in this area and to ensure that all suppliers are aware ParkingEye reserves the right to terminate a relationship with a supplier or third party that is unable to demonstrate compliance or immediate action towards the eradication of modern slavery within its organisation and supply chain.
How we are reducing our HR risk
Risk is minimised by utilising our own in-house recruitment capability as the first option and only using reputable smaller agencies with appropriate accreditation and always verifying the practices of any new agency we are using before accepting workers from that agency, to ensure low risk, where recruitment is outsourced.
We operate self-assessment checking with all third parties and audit, if risk is highlighted. Where self-assessment leads to matters being disclosed that cause us concern, we would audit that supplier and that procurement (or the continued supply) would be paused for that process to be completed and the results evaluated.
We are in the process of setting out, formally, a Recruitment/Agency workers policy detailing this approach. In the coming year, we are working towards standing up a Quality Assurance Team to audit and check compliance. We have taken on a dedicated in-house recruiter whose remit includes tracking agency usage and monitoring the recruitment process.
How we are reducing supply chain risk
Throughout 2020, we are establishing an internal auditing process for the continual due diligence review of our existing supply chain which will include both financial stability, health and safety and Modern Slavery compliance.
Active Suppliers to December 2019 360
Top 80% of suppliers (No) 66
Non outsourced Sub-contract labour 5.5% of overall spend
Outsourced Sub-contract labour 1.5% of overall spend
Planned measures to improve in the year to 31 December 2020 and three years to 31 December 2023.
- Annual due diligence review of top 80%;
- 3 year cycle due diligence review for all supplier review; and
- Implementation of notifications for changes to supplier’s financial stability status on credit information platform.
We will report on our progress against these goals.
As a Car Park Management business, we strive for greater efficiency and use our expertise in technology and talent to drive continuous improvement. Where we ask the business and our supply chain to do more with less, we also strive for them to do this in a smart way, so we don’t compromise on our legal or ethical obligations
Training and communication
To make employees aware of the Act and the drivers of modern slavery, as well as the possible indicators we are putting in place a new training and awareness-raising programme in 2020, requiring all staff to have attended a Modern Slavery training module via our staff online learning platform. We provide access to relevant policies on the company’s intranet and share this statement with all employees through our internal communication channels and publish a copy of this statement on the ParkingEye website (www.ParkingEye.co.uk). Our procurement team and HODs are aware of the Act and our associated due diligence processes and we will be raising the profile of the issue of modern slavery and how employees, intermediaries and suppliers can combat it within the business or our supply chain. Reporting on the efficacy of this policy is made to the Company’s board.
Plans for the next year
We will maintain effective and continued focus on employee awareness of how we expect employees to conduct business responsibly, focusing on treating people fairly and equally, acting lawfully and the process involved to raise ethical concerns and devise programmes with our suppliers to improve compliance
This statement is made pursuant to s54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2020.
This statement was approved by the Board of ParkingEye Limited.
Philip Boynes, CEO
30 June 2020