ANTI SLAVERY & HUMAN TRAFFICKING STATEMENT

Slavery and Human Trafficking Statement for Barnetts Motor Group Limited and its subsidiaries for the year ending 31 December 2018. Introduction from the Group Chairman:

Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.

We ensure:

• our values, which are embedded throughout our business, set the perimeters for how we expect our people to behave with colleagues, customers and all other organisations we deal with.

• we seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted

• our policies and procedures relating to the Modern Slavery Act are in line with our culture and values.

Organisation Structure

We are primarily an automotive retailer and a provider of servicing and parts. The group has its head office in Dundee, Scotland and all trading outlets are in Scotland.

Our Business

Our business is organised across the three different brands we represent – Volkswagen, Mazda and Volvo in 4 retail facilities.

Our Supply Chain

Our supply chains principally include the supply of vehicles and parts from the manufacturers we represent and certain key local suppliers.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due Diligence Process for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk –

* We ensure all staff are paid at least the current minimum wage.

* We also ensure that all staff have the right to work in the UK before employment begins.

* We manage retail dealerships in-line with best practice UK automotive standards;

* The geographical scope of our premises are limited to Scotland allowing us to have firm control on our activities and being able to adequately oversee them;

* Where possible we build long standing relationships with local suppliers and, make clear our expectations of business behaviour;

* With regards to national or international supply chains, our main point of contact is the represented personnel of our UK-based manufacturer partners and we expect these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity in the chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the chain.

* We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.

Supplier Adherence to Our Values

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors comply with our values.

Responsibility for monitoring

The Franchise Managers are responsible for compliance in their respective dealerships and for their supplier relationships. Our HR department carry out an overall watching brief on our staff.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group's slavery and human trafficking statement for the financial year detailed above and is valid until amended.

Paul Barnett, Group Chairman