1. Introduction and commitment
Mitchell Diesel Limited, trading as Mitchell Powersystems (the Company), is committed to acting ethically and with integrity in all business relationships. We take a zero-tolerance approach to modern slavery and human trafficking and seek to implement proportionate systems and controls to reduce the risk of these practices occurring within our own operations or supply chains. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.
Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. We recognise that no organisation can provide an absolute guarantee that every tier of its supply chain is free from abuse. Our approach is therefore based on identifying risk, applying proportionate due diligence, encouraging early reporting and responding responsibly to concerns.
2. Our business, structure and supply chain
The Company provides power systems products and technical services. Our activities include distribution of engines, transmissions and related parts; workshop repair and overhaul; field service; technical support; and associated maintenance services.
Our direct supply chain includes a range of Franchise Partnered original equipment manufacturers, component and parts suppliers, engineering subcontractors, logistics and freight providers, recruitment agencies, facilities management providers, IT suppliers and professional advisers. Direct suppliers are principally located in the United States, Germany, Holland, United Kingdom, Italy and Austria.
3. Governance and accountability
The Board of Directors has overall responsibility for the Company’s approach to modern slavery and for approving this annual statement. Day-to-day implementation is delegated to relevant heads of department with support from managers who recruit people, engage contractors or appoint and manage suppliers.
Managers are responsible for ensuring that relevant colleagues understand this statement, complete training when assigned and escalate concerns promptly. Procurement and supply chain functions are responsible for applying the due diligence controls described below and retaining appropriate records.
4. Policies and employment controls
The Company’s controls are supported by the following policies and procedures, where applicable:
- Anti-Slavery and Human Trafficking Policy;
- Whistleblowing Policy and confidential reporting arrangements;
- Recruitment and right-to-work checking procedures;
- Disciplinary and grievance procedures;
- Health, safety and wellbeing arrangements;
- Supplier approval and purchasing procedures; and
- Employee contract obligations
All employees are employed on terms intended to comply with applicable UK employment legislation. Right-to-work checks are completed before employment begins in accordance with current Home Office guidance. These checks form part of the Company’s recruitment controls but are not treated as a substitute for wider modern slavery risk awareness. Employee records are retained in accordance with the Company’s data retention requirements and applicable data protection law.
5. Risk assessment
During the reporting year, the Company has introduced a more comprehensive assessment of its operations and supply chain. The assessment considers the nature of the goods or services, supplier location, labour model, use of subcontracting, level of supply-chain visibility and any known adverse information. Potential areas requiring closer attention may include:
- Labour-intensive manufacturing or services;
- temporary, agency or subcontracted labour;
- logistics, cleaning, facilities management and security services;
- suppliers operating in higher-risk locations or sectors;
- suppliers with limited transparency or weak policies and controls.
6. Supplier due diligence and contractual controls
The Company expects suppliers, contractors and business partners to act lawfully and ethically and to support our zero-tolerance approach to modern slavery. Expectations are communicated at the outset of relevant business relationships and reinforced where appropriate. Depending on the assessed level of risk, controls may include:
- supplier pre-qualification or self-assessment questionnaires;
- review of a supplier’s published modern slavery statement and relevant policies;
- screening for sanctions, enforcement action or credible adverse information;
- enhanced review, evidence requests, audit or site visit for higher-risk suppliers; and
- corrective-action plans, follow-up reviews and escalation of unresolved non-conformance.
Where a concern or non-conformance is identified, the Company will assess the circumstances, prioritise the safety and welfare of potentially affected individuals and require appropriate corrective action. The Company reserves the right to suspend or terminate a relationship where a supplier does not cooperate, fails to implement required improvements, or the seriousness of the matter makes continued engagement inappropriate.
7. Reporting, investigation and remediation
All employees and people working on the Company’s behalf are encouraged to report any concern or suspicion of modern slavery at the earliest opportunity. Concerns may be raised with a line manager, or through the Company’s whistleblowing arrangements. Reports will be handled as sensitively and confidentially as reasonably possible. No person should suffer detrimental treatment for raising a genuine concern in good faith, even if the concern is not substantiated. Any allegation will be assessed promptly and escalated to the appropriate senior manager. Where there may be immediate danger or a suspected criminal offence, the Company will consider referral to the relevant authorities and specialist support organisations. The Company’s response will focus on protecting potentially affected people, preserving relevant information, investigating proportionately and addressing control weaknesses. Commercial action against a supplier will be considered alongside the potential impact on workers.
8. Measuring effectiveness and reporting-year outcomes
The Company will use proportionate measures to monitor whether its controls are being implemented and improved.
9. Breaches
Any employee who breaches the Company’s Anti-Slavery and Human Trafficking Policy may be subject to disciplinary action, which could include dismissal in accordance with the Company’s disciplinary procedure. The Company may also take appropriate action in relation to contractors, suppliers and other business partners, subject to investigation, contractual rights and consideration of worker welfare.