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SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR PEUGEOT MOTOR COMPANY PLO CITROËN U.K.
LIMITED, PEUGEOT CITROËN AUTOMOBILES UK LIMITED AND THEIR RESPECTIVE SUBSIDIARY COMPANIES FOR THE FINANCIAL YEAR ENDING ON 31 DECEMBER 2019.
Peugeot Motor Company PLC, Citroën U.K. Limited and Peugeot Citroën Automobiles UK Limited are part of the Peugeot SA (Groupe PSA) group of companies and follow the and principles that Groupe PSA adopts globally. Groupe PSA is a Worldwide automobile group, which bases its development on the pnnciples of socially, and environmentally responsib/e action and conduct in all the countries in Which it is established and in its vari0uS sectorS Of activity. We are committed to improving Our practises to combat slavery and human trafficking.
SLAVERY AND HUMAN TRAFF'CK'NG OUR ORGANISATION
Grou$* PSA formalised its commitments to its stakeholders in a detailed and public manner in Signing the PSA Global Framework Agreement on Social Responsibility on 7 March 2017 ("the Framework"). The Framework was made between Groupe PSA and IndustriALL Global Union and IndustriALL Trade Union and has been adopted and applied across all Groupe PSA including those in the UK. It sets out a framework for companies Within Groupe PSA all over the world to apply the ten UN Global Compact Principles ("Global Compact"). It also describes the Groupe's social requirements With respect to and suppliers.
The Framework indudes the following commitment to the elimination of all forms of forced compulsory labour: "Groupe PSA Lndertokes to respect free choice Of employment and condemns forced labour. considering This ro occur every time work is imposed by way of o threat (food deprivation, confiscation Of land, non-payment Of salary, physical violence, sexual abuse, prison labour etc.)".
Groupe PSA is pursuing a process of improvement in its social policv, based on a continuous assessment Of its approach and the involvement Of Trade Unions and employee representatives. Groupe PSA restates its commitment to applying the Framework and to continuously monitor, assess its application and process anv claims. The Framework requires a" Groupe PSA to exercise due With respect to the suppliers making up the supply chain.
Code Of Ethics
At the same time, Groupe PSA'S Code Of Ethics applies to all Groupe PSA emplovees) formallv sets out 16 rules of ethical conduct, including the following —
- AlI employees must comply With the laws and regulations Of the country in which they Work. Employees ore expected to be formliar With laws and reguhtions covering their specific area of operation.
- All employees contribute to the Groupe's commitmentS With regard to fundamental human rights. In particular, they undertoke to prohibit Child labour and forced labour and to respect freedom of association and the right to representation. Employees are expected to respect these rights in their areas Of responsibility and require the same level of respect from their partners and suppliers
- The Groupe prohibits any and 0/1 types Of discrimination on the basis Of age, gender, nationality. marital status, sexual orientation, lifestwe, genetic charaeteristics, real or supposed belonging to an ethnic group, nation or race, physical appearance, pre•existing hea'th conditions or disability, pregnanCy, nome, politicol Opinion. re/igiOuS ConvZtion or union activities.
Employee Awareness Programmes and Training
TO ensure a high level of understanding Of the risks Of modern slavery and human trafficking in the Groupe business and the supply chain, awareness prWamrnes and training are provided to employees. The Framework is translated into 14 languages to ensure that all employees can easity read and understand ns requirements. The principles and good practises linked to ns application are communicated to an employees to rai* awarenesS.
Evolving Approach to the Effectiveness Of Combating gavery Human
The Groupes policies relating to the protection of human rights are clear and wideiy implemented. However, there is always a possibility that some risks cannot be prevented. ln 2019, 28,048 Groupe employees undertook dedicated training in human rights policies and procedures. This included guards and security staff When these activities are Outsourced, specialist contractors are selected and must comply With the Framework on social responsibility requirernents.
SLAVERY ANO HUMAN TRAFFICKING RtSKS WITHIN GROUPE PSA's SUPPLY CHAN
Groupe PSA has direct contractual relationships With more than suppliers (Tier 1) which are required to comply With CSR commitments. These are formalised in the PSA General Purchasing Terms and Conditions" that reinf0rce the Groupe PSA commitments and requirements in CSR matters, as well as in the document "Groupe PSA Responsible Purchasing Polio'" ("Commitments-).
The Document "Groupe PSA General Purchasing Terms and Conditions" includes the staternent -Seller further represents that neither it nor any Of its subcontractors, vendors, agents or "ther associated third parties will utilize Child, slave, prisoner Or ony Otherf0rm Offorced or involuntary labor. engage in abusive employment or corrupt business practices, in the supfly Of goods or provision Of services under the Contract. The Commitments is availab/e on-line on the Groupe PSA website at http://wwv.4 roua.com en documen chane-rse-fournisseur _
This includes the statement - The Supplier recognises the principle of the freedom ofchoice of employment_ The Supplier must not, under any circumstances, resort to forced or compulsory labour. is deemed gorced or compulsory When it is imposed by means Of o threat (Withholding Of f00d, confiscation Of land, non•payment Of salory. physical violence, sexual abuse or non•voluntary prison labour. etc.) (IIO Conventions nos. 29 and _ By signing the Commitments, Our Tier I suppliers commit themselves to selecting their subcontractors (Tier 2 suppliers for Groupe PSA) on the same CSR criteria. These CSR criteria theref0re apply throughout the Groupe PSA supply chain as part Of the direct contractual relationship between Groupe PSA as the purchaser and Our suppliers.
Due Diligence Processes for Slavery and Human Trafficking
In line With its longstanding commitment to the Global Compact and building on the Framework Agreement and the Commitments, Groupe PSA identifies the and areas that are the most Iikely to present risks of human rights violations, particular'y in relation to modern slavery. ln the event that anv supplier fails to respect these rights and principles, the supplier must corrective action plans. Moreover, PSA's Purchasing department reserves the right to penalties leading up to the exclusion Of the supplier from the Groupe's panel of suppliers if it should emerge that it was directly or indirect'y invotved in these types of practises.
Groupe PSA has furthered its commitrnent to identifyine and taking action against modern dav slavery and human trafficking by implementing a whistle•blowing system, Speak4CompIiance, Whereby employees are encouraged to report under certain conditions unethical or illegal conduct which they Observe or become aware of. The whistleblowine system is a voluntary web-based reporting system by an independent service provider for all Groupe PSA entities and is intended to deal With, among Other issues, human rights. Groupe PSA prohibits retaliation in anv form against an employee Who reports a problem or concern in a good faith and is acting in the public interest.
Supplier Adherence to Our Values and Ethics
Groupe PSA has a Zero tolerance approach to slavery and human trafficking. TO ensure all those in our supply chain and contractors comply With our values we have in place a strong supplv chain cornpliance programme. This consists Of a four-step supplier evaluatjon undertaken by the Purchasing department that is responsible for each supplier:
- Signature Of the document "Groupe PSA Responsible Purchasing Policy-: all suppliers are asked to mark their commitment to these principies by sGning this document. which requires elimination Of any forms Of forced Or compulsory labour and a commitment to womoting the same principles to their own suppliers and subcontractors.
- IATF audit certification". all suppliers wishing to take part in a tender process for automotive parts must be compliant With the 'ATF 16 949 standard as well as the Groupe PSA specific requirements. Assessment by a third party service provider EcoVadis: this assessment is mandatory and is to performed for all suppliers. The results Of these assessmentS are taken into account during the tender process before awarding new business to any supplier.
- Audits on site conducted by a third party: for suppliers identified as "at risk" , these audits provide a summary Of how the supplier is performine in terms Of PSA requirements and the local Statutes and regulations.
TO ensure a high level Of understanding Of the risks Of slavery and human trafficking in Our supply chains and our business, we prcwide training to our suppliers through e-learning and information during the supplier meetings, details of which are set out in the Groupes annual CSR report. This statement is made pursuant to section 54(1) Of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for the financial year ending 31 December 2019 for Peugeot Motor Company PIC, Citroën U.K. Limited, Peugeot Citroën Automobiles UK Lirnited and their subsidiaries.
Approved by the Board
Peugeot Citroën Automobiles UK Limited, Motor Company PIC, Citroën U.K Limited
OPENING STATEMENT FROM SENIOR MANAGEMENT
Peugeot S.A. (“Groupe PSA”) merged with Fiat Chrysler Automobiles N.V. (“FCA”) to form Stellantis N.V. on 16 January 2021. As this statement relates to the activities in the year 2020, reference is made only to Groupe PSA and covers only the entities within the Groupe as at 31 December 2020. Peugeot Motor Company PLC, Citroen UK Limited and Peugeot Citroen Automobiles UK Limited are part of the Peugeot SA group of companies (Groupe PSA), a global company, in the automotive sector. Groupe PSA is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain, and impose the same high standards on its suppliers. By signing, at the highest level, the Global Framework Agreement on the PSA Group’s Social Responsibility (March 2017 - https://www.groupe-psa.com/en/document/accord-cadre-mondialresponsabilite-sociale-fr/ ), Groupe PSA has committed itself to stand against the violation of human rights and promotes the elimination of all forms of forced or compulsory labor. In signing the Global Framework Agreement, Groupe PSA undertakes to require the same respect from the value chain and to make it a determining criterion in the selection of its suppliers.
STRUCTURE OF THE ORGANISATION
Groupe PSA employs 110,000 people worldwide and has business operations in 160 countries. Groupe PSA has a global annual turnover of €74,000 million. To find out more about the nature of our business, please go to https://www.groupe-psa.com/en/ . In order to ensure competitiveness and continuous supply to all Groupe PSA operations, we work directly with a wide range of suppliers, currently more than 8,000 for parts and services globally. These are classified into 3 categories (“Key Partner”, “Key Supplier” and “Others”) based on various contributing factors.
As part of our commitment to combating modern slavery, we have implemented the following policies:
• Groupe PSA’s Code of Ethics (which applies to all Groupe PSA employees) - https://www.groupe-psa.com/en/document/code-of-ethics/
• Groupe PSA’s Responsible Purchasing Policy – https://www.groupe-psa.com/en/document/charte-rse-fournisseur/ We also make sure our suppliers are aware of our policies, and adhere to the same high standards. Suppliers must commit to these standards in several ways to evidence their fight against modern slavery, for example, by accepting the Groupe PSA General Terms and Conditions and the signing of the Responsible Purchasing Policy. These documents reference:
• Elimination of all forms of forced and compulsory labour, ILO Convention 29 and 105
• Effectively abolish child labour, ILO Convention 138 and 182
• Eliminate discrimination in respect of employment and occupation, ILO Convention 111
• Remuneration, ILO Convention 100
• Respect for health and safety at work, ILO Convention 155
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted several due diligence procedures. All suppliers have to obtain a CSR Scorecard that is provided by an independent 3rd party provider. Additionally, all suppliers are assessed against an internal risk criteria. Where we identify suppliers from our total supply base that pose a higher risk, we (via an independent 3rd party auditor) conduct an onsite audit. Suppliers with core non-compliant or critical findings are closely monitored. This also includes case-dependent follow-up audits to ensure that supplier performance is increased. Suppliers that do not improve or cooperate with Groupe PSA in specified areas might be ultimately excluded from the Groupe PSA’s supplier panel.
Our procedures are designed to:
• Establish and assess areas of potential risk in our business and supply chains
• Monitor potential risk areas in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains
• Provide adequate protection for whistleblowers
RISK AND COMPLIANCE
Groupe PSA regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain by ensuring that all suppliers renew their CSR assessment regularly. This is achieved by monitoring the mandatory supplier CSR performance scorecards for all suppliers in the panel and again when considering any business award. All suppliers are classified by their risk exposure based on multiple factors. Although we have not identified or been made aware of any significant risk, we believe that our policies effectively prevent this risk and remain vigilant with respect to practices that do not fully respect the rights of individuals in their working environments directly or indirectly with the Group.
EFFECTIVENESS AND KPIS
Groupe PSA uses key performance indicators (KPIs) to measure how successful we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains. These are as follows: • Development of coverage of supply base that has CSR Assessment • Development of average result of Social Score of suppliers CSR performance • Annual number of CSR onsite audits performed at suppliers We use Ecovadis assessments and engage SGS and RCS Global to conduct audits and provide independent reviews of our businesses and supply chains, and to recommend actions we can take to combat slavery and human trafficking from within.
We invest in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes, employees are encouraged to identify and report any potential breaches of our policies. Employees are taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains. Examples of training courses we have administered over the past year include: • Regular internal CSR Trainings to all GPSQ Employees and all new Purchasing employees • Regular external CSR Trainings to supply base globally
FURTHER ACTIONS AND SIGN-OFF
Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking: • HR managers in all countries have been requested to review practices, in order to reinforce the effectiveness of Group requirements within its areas of responsibility. • We will perform control reviews regarding the at-risk points related to temporary workers and recruitment consultancy, in areas such as wages paid to temporary workers in accordance with the law and reference wages agreed, the invoicing for services provided, and the absence of fees or financial burdens imposed on workers or applicants.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement of Peugeot Motor Company PLC, Citroen UK Limited and Peugeot Citroen Automobiles UK Limited for the financial year commencing 1 January 2020 and ending 31 December 2020.
This statement was approved by the Board of Directors for Peugeot Motor Company PLC, Citroen UK Limited and Peugeot Citroen Automobiles UK Limited on 19 March 2021.
Signature: ALISON JONES Director General Peugeot Motor Company PLC, Citroen UK Limited and Peugeot Citroen Automobiles UK Limited Date: 12th April 2021