Belron® International Limited 

Modern Slavery: Our approach to making a difference

This Modern Slavery Statement was formally approved by the Belron® International Limited Board on 28 June 2023

Our business structure

Belron® International Limited acts as the central support and procurement hub of all operations on behalf of the Belron family of businesses (referred to as ‘Belron’ throughout this statement). Belron is the worldwide leader in vehicle glass repair, replacement and recalibration (VGRRR) operating in 37 countries, through wholly owned businesses and franchises, with market leading brands – including Autoglass® and Laddaw® in the UK, Carglass® across Europe, Lebeau Vitres d’autos®, Speedy Glass®, Apple Auto Glass®, Duro® vitres d’autos and Vanfax® in Canada, Safelite® Autoglass in USA, O’Brien® in Australia and Smith&Smith® in New Zealand.

Aside from dealing directly with customers, Belron manages vehicle glass and other insurance claims on behalf of insurance companies. Each of the Belron family of businesses is led and operated by a separate executive team who has direct engagement with the global leadership team at Belron® International.

For clarity, the Belron family of businesses including Belron® UK have their own supply chains for products and services procured locally and are responsible for conducting their own due diligence and for complying with any local modern slavery legislation.

Our Responsible Business Framework

Belron’s approach to responsible business is driven by its purpose of “making a difference with real care”.

From a cultural perspective, Belron  has a long tradition of serving society, and throughout our entire history we have encouraged our people to give back and we have supported hundreds of charities, NGOs and community groups, most recently establishing the Belron Ronnie Lubner Charitable Foundation. We were an early adopter of EcoVadis sustainability ratings and we have also been a signatory to the United Nations Global Compact since 2010.

The Belron Responsible Business Framework (the ‘Framework’) brings together all aspects of how we view “Doing Business Responsibly”, which is derived from Belron’s purpose and values. We want to be “a trusted and respected company in the eyes of our people, customers, partners and society, by doing the right thing every day and behaving with integrity in everything we do”.

The Framework has two strategic pillars – Sustainable Products & Services and Investing in People and Society. Our priorities under these pillars are to:

• Reduce our waste and work towards a circular economy
• Drive down emissions
• Integrate environmental and social considerations into all our procurement decisions
• Promote diversity, equity, inclusion and well-being
• Continue giving back to drive positive change
• Prioritise the safety of our people

In addition and underpinning the Framework, are core foundations including strong governance and inspiring leadership, a continued focus on our values and ethics, and a commitment to developing robust reporting and measurement around our responsible business activities.

Our values & ethics

The Belron Code of Conduct (the ‘Code’), which includes core guiding principles of integrity, respect and trust, details the company’s set of values and ethics that provide clarity on what is acceptable behaviour across the organisation.  The Code, which has been in place since 2010, remains an important part of Belron’s way of working today. Each Belron business is responsible for the development of its localised code of ethics based on a centralised framework. Training and communications around ethical behaviour are also conducted at local level.

The business adheres to and promotes clear ethical standards for itself and expects similar standards from all third parties who work with Belron or on its behalf. Human rights are a fundamental pillar of Belron’s ethics and are addressed in the Code.

Our Code commits us to:

• Always respect the human rights of everyone who works for us and on our behalf
• Encourage partners, suppliers and others third parties t o adopt similar standards of respect
• Understand that we will not work with any organisation that fails to uphold basic human rights or one that might cause the company embarrassment by their links to inappropriate organisations or regimes
• Report any concerns about human rights abuse immediately
• Respect the rights of our colleagues to be involved in trade unions or collective bargaining arrangements
• Avoid working with suppliers who fail to meet our standards and carry out checks to ensure compliance
• Understand that in certain circumstances we may work with a supplier to improve standards first before terminating an agreement

Belron people are expected to always treat each other with respect and ensure that their activities do not contribute directly or indirectly to human rights abuses. In no instances will inhumane treatment of its people or those in its supply chain be acceptable including any form of forced or bonded labour, child labour, physical punishment or any other abuse.

The Code which incorporates “Our Way of Working” is a public document available through the Belron website. Awareness of the Code is included in the induction process for all new people joining Belron International.

As reported in our 2022 statement, we worked with an external partner to review and evaluate our current Code. In the past reporting year, this work has moved to the next phase of collaborating with our family of businesses for their input in developing an updated Code and a global training programme for all Belron people, to be rolled out in 2023. This will incorporate best practice training delivery and annual certification and will provide additional training to individuals who have distinct obligations such as leaders, procurement managers and sales teams.

Belron maintains a Speak Up facility through NAVEX Global that provides a channel to all colleagues to raise concerns in confidence, in local language and anonymously, about behaviours or activities not aligned to the Code. Every issued raised through the Speak Up facility is investigated by the Belron International legal team with support from the local businesses, and appropriate action taken where necessary. No instances of modern slavery were reported to the Speak Up facility in last 12-months (since our previous Modern Slavery statement).

The People team at Belron® International follow a rigorous recruitment process carrying out appropriate checks regarding each individual’s eligibility and right to work.  We also complete employment referencing for all candidates who are offered roles.  Employees are provided with a clear contract of employment, which complies with applicable local country legislation.   We are committed to promoting a workforce free of discrimination and harassment and everyone must be treated in a fair and equal manner and with dignity and respect.   We provide fair and equitable pay, benefits and additional conditions of employment in accordance with local country laws.

Diversity, Equity and Inclusion (‘DE&I’) is a global priority for the business and is a key component of the Belron Responsible Business Framework. Our ambition is to continue to have an organisation that protects its people and values difference in all its forms, creating an environment which enables everyone to participate and reach their full potential.  We are committed to hiring and promoting people on the basis of their ability for a role and their appreciation of and respect and alignment with the company’s culture. By 2025 our ambitions are to improve our gender mix across the business and improve the overall diversity of the Belron Leadership Group.

Having established a philosophy, approach and goals on DE&I in the past reporting year we have focused on sharing this Group wide framework through engagement and storytelling with senior leaders across the Belron family of businesses. The Annual Engagement Survey once again included DE&I questions to help track progress. We also recognised key global events to help celebrate and recognise our differences and create awareness.

Robust reporting & measurement

A majority of the Belron businesses continue to use the EcoVadis sustainability ratings to measure performance and benchmark themselves with other businesses in the areas of labour practices and human rights, environment, sustainable procurement and business ethics.  In 2022, the Belron businesses in France, Germany, Italy, Netherlands, Finland, New Zealand and Sweden all retained their gold medal rating with high scores in all areas of the assessment, and the businesses in Spain and Canada retained their silver medal rating.

As well as fulfilling mandatory requirements regarding ESG reporting, we are developing our reporting to meet the needs of our different stakeholders and to ensure robust and transparent reporting of all our responsible business activities.  This currently includes the Non-Financial Reporting Disclosure within the D’Ieteren Group annual report as well as preparing to meet requirements of the UK’s Climate-Related Financial Disclosure (CRFD) and the EU’s Corporate Sustainability Directive (CSRD); and the publication of the UN Global Compact Communication on Progress in which 2022 was the 12^th consecutive year of reporting to this framework.

Our supply chain

Belron International sources and manages the procurement of certain core products and services required by the Belron family of businesses globally. Centrally procured products and services include:

Other products and services required by the Belron businesses locally are sourced and managed through their own local supplier network.

Suppliers that have a direct contractual relationship with Belron International are classed as Tier 1 suppliers. Our Tier 1 supply base now incorporates 140 production sites globally, which is an increase of nine sites in the past reporting year. This Tier 1 supply base is based primarily on relationships with a small number of long-term commercial partners. In general, these are leading, multinational companies with global footprints, together with some smaller specialist suppliers. Upstream suppliers of raw materials (and parts or components thereof) as well as other goods and services procured without a direct relationship, for example, via an agent or other commercial partners, are classed as suppliers in Tier 2 or beyond.

Our Sustainable Procurement programme

Belron International operates a formal Sustainable Procurement programme run by a specialist team, led by the Head of Sustainable Procurement. The purpose of the programme is to embed sustainability at the forefront of all our supplier interactions including purchasing strategies and buying decisions and is structured around three key pillars of transparency, assurance, and reward:

Belron International has a Supplier Code of Conduct (the ‘Supplier Code’) which applies to all suppliers of Belron International and includes the high standards and expectations that they must all meet to both become and remain an approved supplier. The Supplier Code is available via the Belron website and has been communicated to all Belron International Tier 1 suppliers. Suppliers’ compliance with the expectations set out in the Supplier Code and their performance against sustainability targets, are all critical requirements of conducting business with us.

Our supplier due diligence

The Sustainable Procurement team maintains a complete and up to date map of the Belron International Tier 1 supply chain, covering all production and distribution sites of centrally procured goods and services. In 2022 we mapped our Tier 2 and Tier 3 supply chain from our most critical suppliers with a specific focus on modern slavery risk areas.

Identification of social and environmental risks in our supply chain including those around modern slavery, is one of the top priorities of the Sustainable Procurement programme. Using both internal expertise and external resource, this risk assessment is updated regularly and used to prioritise and schedule both remote and on-site audits.

In conjunction with two leading audit providers, TÜV and Elevate, we run a bespoke social and environmental on-site supplier audit programme, aligned with our Supplier Code and incorporating modern slavery, health and safety, environment, labour and values.  Our independent audit partners are responsible for undertaking site audits and assisting us in further developing our Sustainable Procurement programme.  A key aspect of the on-site audit is direct dialogue with workers at the production sites which is done in local languages by the independent expert audit providers we use. Answers are anonymised and the results of the dialogue, as well as the on-site audit results are communicated to Belron International. This is followed up by the team to address any gaps and share opportunities for improvements.

In 2022 we completed 37 supplier site audits in addition to the 31 completed in 2021. This means that all high risk and critical Tier 1 supplier sites have been audited at least once since the start of the programme which meets our target as set out in our 2022 statement. Tier 1 suppliers are now monitored and re-audited on a rolling basis based on risk, criticality, and the results of the previous audits. In addition, we perform full supply chain assessments of our most critical suppliers. This involves performing ESG audits of the full supply chain of our suppliers back to the raw materials. The audits focus on modern slavery, health and safety, environment, labour and values.

We continue to monitor suppliers whose country of operation brings potentially high risk of modern slavery issues and use this to focus our assessments and audits accordingly.

As outlined in our previous Modern Slavery statements, any non-compliances found in supplier audits are addressed in a timely manner and with vigour. If any instances of modern slavery are found at site level these will be reported to the Belron International Board of Directors by the Head of Sustainable Procurement, with an appropriate action plan and timescales for improvements.

Following any non-compliance, the initial focus will be working with the supplier to resolve any issues, however we are committed to responsibly disengage with any suppliers who may demonstrate an unwillingness or inability to comply or to address any issues. We will report on non-compliances as part of our annual Modern Slavery Statement.  In this past reporting year, no instances of modern slavery were found.

Training and awareness

Building Relationships with Suppliers and Partners and Human Rights are two key sections within the new Belron Code of Conduct, providing an overview of our approach as well as our employees’ responsibilities, and are incorporated in the training module due to be rolled out in 2023.

With a focus on the Sustainable Procurement programme, we are committed to providing refresher training to all Belron International employees and training to new employees as part of on-boarding. The purpose of the training is to enable colleagues to recognise modern slavery and help mitigate the risk of incidents. This training will be conducted in partnership with external providers that specialise in modern slavery and human trafficking awareness.

Susan Ormiston, Chief People Officer

Belron® International Limited Board

Date: 28 June 2023

This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Belron® International Limited during the financial year ending 31 December 2022 and was approved by the Board on 28 June 2023.