Modern Slavery and Human Trafficking Statement


This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It constitutes Arctos Groups slavery and human trafficking statement for the financial year ended 31 March 2021. It covers the activities of Arctos Group and its wholly-owned subsidiaries: SMH Fleet Solutions, Hudson Kapel and CD Auction Group.

This is the second year Arctos Group has produced a statement and it details the steps in place to ensure that neither slavery nor human trafficking is taking place in our supply chains or any part of our business and the action we intend to take in pursuit of our ongoing commitment to maintaining high ethical standards.

Our organisation

Arctos group is one of the UK’s largest providers of services for vehicle manufacturers, franchise vehicle dealerships, leasing and rental companies and vehicle fleet providers of all sizes. The group offers a range of services including vehicle management, logistics, refurbishment, salvage sales, storage, licence checking and securities.

We operate exclusively in the UK and employ over 400 employees.

Our supply chain

The majority of our suppliers are UK-based and supply standard goods or services. We recognise there are areas of potentially higher risk and some services involving relatively high levels of contracted labour.

Arctos Group considers its tier-1 suppliers to be those with whom we have a direct contractual relationship. This will therefore include, but not be limited to: parts suppliers, cleaning contractors and IT contractors. As a result of the potential number and variety of non-tier 1 suppliers in Arctos Groups supply chain, it is difficult for us to effectively monitor and manage the modern slavery activities of those suppliers.

Arctos Group is, however, committed to ensuring that its tier-1 suppliers are aware of and comply with the Act and will seek to encourage tier-1 suppliers to monitor compliance with the Act within their own supply chains.

Due diligence

There are a number of internal policies which support and foster continuing compliance with the Act. All internal policies are reviewed on an annual basis.

  • Modern Slavery Policy: Details of the Company’s approach to fulfilling its commitment to support the elimination of Modern Slavery and the actions for reporting concerns.
  • Whistleblowing Policy: This policy sets out the way in which individuals may raise any concerns that they have and how those concerns will be dealt with.
  • Corporate Social Responsibility Policy: This policy outlines our Corporate Social Responsibility (CSR) into all aspects of operations relating to our employees, customers, other stakeholders and the wider community.
  • Ethical Trading Policy: The company bases its operations on lawful, efficient and fair practices, and expects its suppliers to adhere to applicable legal and regulatory requirements in their business relationships
  • Equal Pay Policy: Our commitment to ensuring the pay and conditions of employment for all employees does not discriminate unlawfully and are free from bias.
  • Recruitment and Selection Policy: Outlines our robust recruitment and selection process.


When employing anyone to work at Arctos Group, a robust recruitment selection process takes place which is managed centrally by a trained recruitment team. It is important to us that any of our applicants apply for opportunities at their own free will or give full permission to be represented by a third party (which is agreed in our terms and conditions with our recruitment agencies and workforce suppliers).

This has also been achieved through strengthening our direct hiring; over 90% of our employees are hired directly without the assistance of recruitment agencies.

Where we do require any support in the hiring process, we are committed to reviewing our agency agreements to ensure that we only work with employment agencies that have the same ethical standards as our own.


Arctos Group commit to the following actions:

  • Undertake an audit of tier-1 suppliers. Review the nature of their business as well as their country of operation, product and industry characteristics and level of contracted labour.
  • Suppliers categorised as high-risk will be subject to additional due diligence. Primarily based on public sources of information including checks of their own modern slavery and human trafficking statements where applicable, and any other published policies and procedures.
  • High-risk suppliers will be required to sign a Modern Slavery Supplier Agreement to confirm their commitment and compliance with the act.
  • We reserve the right to audit all or any suppliers for compliance.

Continued Commitment

Arctos Group is committed to not knowingly supporting or doing business with any supplier involved in slavery or human trafficking and expects all of its tier-1 suppliers to impose obligations on their own suppliers, in order to ensure compliance with the Act. With this in mind, we will continue to work closely with tier-1 suppliers to reduce and/or eliminate the risk of modern slavery.


This statement has been approved by the Directors of Arctos Group and its subsidiary companies and signed on their behalf.

Andy Baxter - Chief Financial Officer

May 2021