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We oppose modern slavery and human trafficking

Subaru and its parent company, IM Group, work hard to ensure the integrity of our business and supply chains.

IM Group Modern slavery statement for January - December 2022

IM Group recognises that the potential for modern slavery exists in many sectors, and we must do everything we can to prevent any form of slavery, human trafficking or any other unethical behaviour.

We are dedicated to developing, implementing, and enforcing effective systems and controls to ensure that we address the threat of modern slavery within our business and in our supply chains.

We have zero-tolerance for slavery and human trafficking, and we expect our supply chains to take the same stance. To date we have not identified any actual or suspected cases of modern slavery in our operations or direct supply chain.

This statement is IM Group's sixth modern slavery statement. It sets out the steps that IM Group and its subsidiary companies have taken during the financial year ending December 2022 to combat slavery and human trafficking in our business and supply chains.

Click here to view our policy.

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  • This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for IM Group.
  • This statement covers the IM Group and all its entities as set out list-of-active-dormant-companies/
  • This statement has the support of the IM Group Board of Directors and was approved by the Board on 28th June 2023

Gary Hutton, Executive Director

Our Supply Chain

IM Group, directly and indirectly, purchase products, materials, services, and labour from a diverse portfolio of suppliers, distributors, labour agencies and professional service suppliers. Our supply chain is complex, with multiple tiers stretching across the globe.

For supplier management and relationship building purposes, we have a contract management system facilitated by the risk and compliance department and within the property division of the business, IM Group fosters long-term working relationships with its supply chain members. Our procurement and commercial teams regularly engage with their supply chain partners.

Key Strategical Focus for 2021

A key strategical focus is a collaboration and partnership with other stakeholders and external parties, including Slave Free Alliance aligned to Hope for Justice.

  • Our modern slavery contract administrators are tasked with managing and mitigating modern slavery risks, including evaluating the risks of modern slavery occurring in our supply chains and implementing proportionate and effective systems and controls.
  • This is further supported by the training and governance structure provided by the Director of CSR and reported to the CSR board.
  • We have made a number of commitments in our policies to help us address the risk of slavery and human trafficking occurring in our operations or supply chains
  • Our key modern slavery policies are the following:
    • Our Code of Conduct
    • Our Modern slavery and Human Trafficking policy statement
    • Our Anti-slavery and Human Trafficking questionnaire and our accompanying pack

The purpose, goals and behaviours set out in our guiding framework are underpinned by our Code of Conduct. Our Code of Conduct applies to all members of IM Group, including temporary staff. We also expect our suppliers to uphold similar values to our own.

Modern Slavery and Human Tracking Policy

The IM Modern Slavery and Human Trafficking policy reflect our zero-tolerance approach to modern slavery in our business and our supply chains and our long-standing commitment to:

  • Acting ethically and with integrity in all our business dealings and relationships
  • Implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere within our own business or any of the business’ of our supply chains
  • Ensuring that there is transparency in our business and in our approach to tackling modern slavery that is consistent with our disclosure obligations under the Modern Slavery Act 2015
  • Encouraging openness and providing support to anyone who raises concerns relating to Modern Slavery, even if they turn out to be mistaken
  • Modern slavery and Human Trafficking procedure and due diligence

Upon a business relationship being formed, and terms sent out we ensure that appropriate clauses are inserted, and this is implemented with further information gathered by way of questionnaires to ensure compliance.

In conjunction with our Code of Conduct procedure and due diligence, we have implemented a modern slavery and human trafficking process setting out the minimum labour standards that we require from all members of our supply chain. The standards align to the principles of the Ethical Trading Initiative:

  • Employment is freely chosen
  • Freedom of association & the right to collective bargaining are respected
  • Working conditions are safe & hygienic
  • Child labour shall not be used
  • Living wages are paid
  • Working hours are not excessive
  • No discrimination is practiced
  • Regular employment is provided
  • No harsh or inhumane treatment is allowed
Reporting suspicions of Modern Slavery

All employees are encouraged to be vigilant to unethical practices and report concerns. Appropriate action is taken to investigate any breaches of our policies. Our Modern Slavery and Human Trafficking Policy confirms that our employees and supply chain partners have a personal responsibility to report any actual or suspected instances of modern slavery within our business or in our supply chain

  • Suspected instances of modern slavery may be reported to an individual’s line manager (in the case of employees) and a member of the IMG HR team at the Gate, HQ
  • Our policies are communicated internally via our cascade system and externally via our website
  • IM policies are reviewed and signed off by the Chief Executive on behalf of the Board
Risk assessment due diligence

We consider that our most significant modern slavery risks are in our supply chains where we undertake procurement activities and where operations and managerial oversight of our direct control. Some examples of the key supply chain risks that we have identified are as follows:

Due Dilligence
  • Within the Automobile aspect of the group and Spitfire Homes we request our suppliers to complete our questionnaire, drafted in conjunction with the Slave-free Alliance so that we may support them in the supply chain, where operations and managerial oversight are within their control. For IM Properties this aspect is included as part of employer requirements. This includes validating all sub-contractors and recruitment agencies with whom we engage. Questionnaires include questions to assess Modern Slavery risks. All adverse responses to these questions are required to be escalated to the appropriate senior leader.

We also conduct enhanced due diligence, targeted at our specific supply chain risks identified as part of our risk assessment process including:

  • Where we identify instances where we are procuring materials directly from high-risk countries, we will engage with one of our internal or external auditors to carry out a satisfactory ethical audit review prior to making an order. If issues are identified, appropriate investigative and remedial action is taken; and
  • Conducting modern slavery workshops and compliance audits with our key labour partners

Our standard form contracts include a contractual obligation to comply with our clauses relating to the Modern Slavery and Human trafficking policy.

In addition to our supply chain mapping, we regularly evaluate the nature and extent of our exposure to the risk of modern slavery occurring in our supply chain by conducting an annual slavery and human trafficking risk assessment. Plus, training for staff specific to their areas of work.

In 2021 a key focus of our annual modern slavery risk assessment was to assess the potential impact of the global pandemic and Brexit on the risk of Modern Slavery in our business and supply chains. We are aware of warnings of the potential for the new points-based immigration system to increase the risk of modern slavery through resulting labour shortages, with the potential for companies to cut corners in their recruitment processes, and for migrant workers to become increasingly vulnerable to deportation, and gangmasters taking advantage of such opportunities.

2022 Strategic Focus

This section confirms our next steps and our strategic priorities for 2022

We have developed the Group Sustainable Futures plan for different parts of the business focusing on People, Place, Planet that is underpinned by our partnerships and practices. It is therefore important to us that we are effective in ensuring that slavery and human trafficking are not taking place in our business or supply chains, and measured against appropriate KPIs.

We will review our performance against these objectives and outcomes as part of our modern slavery statement for the year ending 2022.

Training and Compacity building in relation to slavery and Human Trafficking

Training and raising awareness remain key focuses in 2022. To date our modern slavery training and compacity activities have included:

E-Learning: We will continue to invest in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains, Our modern slavery E-Learning module, which will be reinforced by face-to-face-training where appropriate, covers topics such as how to spot the signs of modern slavery and who to contact in the event of a potential instance of modern slavery and is required to be repeated by our staff every four years upon induction

Anti-slavery day awareness campaigns: Each year we share key modern slavery communication campaigns to co-inside with the anti-slavery day.

To read our previous modern slavery report Click here ( which is also uploaded to the Government Modern Slavery Registry