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Trenton (Hull) Limited Modern Slavery and Human Trafficking Statement March 2019


This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1 January to 31 December 2018.

The statement sets down Trenton (Hull) Limited’s commitment to preventing slavery and human trafficking in our business activities and supply chains.This statement affirms our intention to act ethically in our business relationships.

We acknowledge our responsibility to the Modern Slavery Act 2015 to ensure transparency within our Company. We all have a duty to be alert to risks, however small. Employees are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

Trenton (Hull) Ltd has been established over thirty years as a motor vehicle retailer. This statement covers the business activities of Trenton (Hull) Limited which are as follows:

  • The sale of new and used vehicles, including commercial vehicles
  • Arrangement of finance to enable customers to buy vehicles
  • Providing vehicle aftercare including the servicing and repair of vehicles for both businesses and the general public
  • The sale and distribution of parts across the Hull and Humber region
  • Conducts MOT testing

Our business is based across four locations and one office base situated across the Hull and Humber region. The four sales location retail the following brands: - Nissan, Peugeot and Citroen.

The Company has circa 100 employees all based in England and operates exclusively in the United Kingdom.

Supply Chains

Most of our supply chains are through the supply of vehicles and parts from the international vehicle manufacturers we represent as detailed above.

We also identify the following non-manufacturer suppliers within our supply chains:

  1. Out-sourced vehicle bodyshop contractors
  2. Waste management services
  3. Cleaning Services
  4. Maintenance Contractors

Risk Assessment

Although the non-manufacturer suppliers listed above comprise a very small proportion of our supply chains, we consider them to be at higher risk of potential breaches of the modern slavery obligations.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

  • Recruitment policy - we operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
  • Whistleblowing policy - the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
  • Modern Slavery and Human Trafficking Policy - This states our commitment to ensure that modern slavery is not taking place in our business or supply chains.


To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, with effect from April 2019, the Company will ensure that all existing staff is aware of the existence of modern slavery and the company’s policy in relation to it. In addition, we will require current employees to undertake online training.

New employees joining the Company from 1 April 2019 will be provided with the Company’s policy on modern slavery and undertake on-line training as part of their induction.

Responsibility for the Company’s anti-slavery initiatives is as follows:

    1.1  Policies: The HR Manager is responsible for creating and reviewing policies. The process by which policies are developed is to look at best practice ensuring that legal compliance is met and adapt to the needs of the Company.
    1.2  Risk assessments: the HR Manager is responsible for risk assessments in respect of human rights and modern slavery and human trafficking.
    1.3  Due diligence: The HR Manager is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.

Due Diligence Processes for Slavery and Human Trafficking

The Company will undertake due diligence when considering taking on new suppliers, and will review its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners. We will also be evaluating the modern slavery and human trafficking risks of each new supplier and invoke sanctions against suppliers that fail to improve their performance in line with our Modern Slavery and Human Trafficking Policy, including the termination of the business relationship where necessary.

Key Performance Indicators

The Company will use the following key performance indicators (KPIs) over the next twelve months to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains. This will include:

  • The set-up of a record of supplier agreements entered into, including the requirement to comply with our values;
  • A review of suppliers we have identified as high-risk, ensuring they have agreed to adhere to our anti-slavery policy;
  • Carrying out an annual reviews of all suppliers;
  • Requiring all current employees to have completed training on Modern Slavery and Human Trafficking by 31 October 2019;
  • The set-up of a staff training record of Modern Slavery and Human Trafficking training undertaken by staff;
  • The use of our HR and payroll system to ensure compliance with the Home Office eligibility to Work in the UK, the National Minimum Wage and Working Time Regulations are met.

This Modern Slavery and Human Trafficking Statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and will be regularly reviewed and updated as necessary.

The Board of Directors endorse this policy statement and is fully committed to its implementation.

This Modern Slavery and Human Trafficking Statement has been approved and signed by Peter Staveley, Managing Director, on 21 March 2019.

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