Modern Slavery Statement

MODERN SLAVERY STATEMENT UNDER SECTION 54 OF THE MODERN SLAVERY ACT 2015

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.

At Tom Hartley Jnr Ltd, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the coming financial years.

Our business

Without a doubt, cars instil a passion in many of us that simply can’t be replicated in other walks of life. Wonderful cars are a perfectly distilled blend of design, engineering, performance and aesthetics; a great car is quite simply a thing of beauty. At Tom Hartley Jnr we operate at the highest end of the market – supplying only the finest cars and providing total peace of mind to our clients.

Part of our obligation to our clients is to help them navigate through a world that is rife with potential difficulties; an environment often dominated by confusing advice and misinformation which can naturally create costly mistakes for anyone not in receipt of the right knowledge and guidance. The sale and purchase of any exotic car, be it a 1955 Mercedes-Benz 300SL ‘Gullwing’ or a 2014 Ferrari F12 Berlinetta, can only be made with sophisticated, professional knowledge and understanding – advice that will ensure that your purchase provides a total, trouble-free experience and which delivers the excitement and satisfaction you deserve from a such a significant and emotional purchase.

With nearly 20 years of personal experience dealing at the very top of the market, Tom Hartley Jnr has built enviable client loyalty and a world-wide reputation upon his exceptional knowledge, impartial advice and commitment to quality in every aspect of his business. Operating from a private showroom in Derbyshire, Tom has a truly global reach and has been responsible for three of the world’s biggest private treaty sales of recent times, including the sale of an ultra-desirable 1957 Ferrari 250 Testa Rossa sports racing car; the only right hand drive Ferrari California SWB in existence; and the sale of a fabulous 1937 Mercedes-Benz W125 Grand Prix car, one the rarest and most valuable racing cars in the world.

But of most importance to Tom Hartley Jnr, is that buying fine automobiles should be a fun and passionate process. Cars are for driving; they open up a new world of exhilaration, pride and even friendship within a community of likeminded people who own and enjoy their cars all over the world. If you have a car to sell or wish to acquire the car of your dreams, please talk to us first – it may well prove to be the best decision you’ve ever made.

Our Suppliers

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.

We haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.

Due diligence and Risk

Tom Hartley Jnr Ltd operates the following for identifying and preventing slavery and human trafficking in our operation:

· We encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation.

· We encourage employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour.

Awareness

Tom Hartley Jnr Ltd has raised awareness of modern slavery issues by discussing this policy with all staff, which explains:

· Our commitment in the fight against modern slavery

· Red flags for potential cases of slavery or human trafficking

· How employees should report suspicions of modern slavery

This statement was produced on 31stMarch 2019 in accordance with the Home Office Audit requirement, this statement can be updated at any time without prior notice.

2019/20