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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