INTRODUCTION
The Company is committed to constantly reviewing its employment practices, the activities of its supply chain and ensuring compliance with the obligations under the Modern Slavery Act 2015. This statement sets out the policies and practices within the Company’s business that provide a framework aimed at ensuring the Company’s compliance with the requirements of the Act.
This statement refers to the Company’s primary review of the implementation of the Act and sets out certain actions that took place during the current financial year (2024/25). This statement also sets out actions that the Company intend to take in the next financial year to improve our position.
The Company and its principal activities
Established in the United Kingdom by the initial acquisition of Universal Salvage Limited in 2007, the principal activity of Copart UK Limited is the provision of vehicle remarketing services to the UK insurance and automotive industries. The Company provides sellers access, through its daily online auctions, to an active and geographically diverse buyer base. This ensures market value is achieved for vehicles sold. The Company only operates in the UK and ROI.
Responsibilities
The HR Director has responsibility for ensuring that all the Company’s policies and procedures are up to date and properly meet the requirements that the policy is designed for. Such reviews are conducted annually as a minimum.
The Senior Leadership Team review the Company’s approach to human rights and modern slavery annually to ensure that no changes have taken place that may have impacted upon its initial risk assessment.
Risk Assessment
The Senior Leadership Team carries out an annual risk assessment of the Company’s activities. The assessment conducted for this financial year (2024/2025) has concluded that the Company does not have any areas subject to high risk within the definition of the Act. The Company believes that its risk assessment and this statement are proportionate to the identified risks to modern slavery as described within the Act.
The Company’s Values are an integral part of the way the Company operates and provides a framework that ensures that the behaviour of its employees meets or exceeds the minimum requirements set out in active employee related legislation. When necessary, the Company will invoke its Disciplinary Policy & Procedure to ensure that its Values remain an integral part of its culture.
Due Diligence
Given the Company’s business operations and that it has assessed itself as low risk, the Company believes that its existing commercial due diligence practices are sufficient to ensure continual compliance to the requirements of the Act.
Policies & Procedures
The Company has a number of relevant policies that supports its efforts to ensure compliance with the Act:
- Whistleblowing policy. The Company encourages all its teammates, customers, and other business partners to report any concerns related to its direct activities, or its supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for teammates to make disclosures, without fear of retaliation, by using the Company’s anonymous hotline. The hotline is well publicised to teammates through the Company’s Teammate Handbook, notice board posters and flyers.
- Teammate Handbook. The Company’s Teammate Handbook makes it clear to all teammates the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of teammate conduct and ethical behaviour.
- Pay & Benefits. The Company is committed to ensuring all teammates receive pay and benefits that meet national standards. The Company prides itself on being an accredited Real Living Wage employer and reviews salaries regularly, at least once a year. All teammates have ready access to information on their pay and benefits. The Company is committed to equal pay and benefits for men and women for work of equal value.
- Recruitment activity. The Company primarily sources potential candidates for employment through an online portal, as well as, when necessary, reputable employment agencies. The Company will always verify the practices of any new agency it is using before accepting workers from that agency. When entering into a contract with any new agency the Company applies its Contract Approval Policy.
- Contract Approval Policy. The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. The Company will only work with reputable suppliers to ensure they meet the standards required. When a new supplier is identified, the Company has a Contract Approval Policy where all contracts are verified by the Company’s legal team and assurances received with such contracts that the supplier meets the requirements of the legislation. Any identified violations of the legislation could lead to the termination of the suppliers’ relationship with the company.
- Corporate Social Responsibility Policy. The Company has a Corporate Social Responsibility Policy that sets out its approach to continually improve upon the Company’s responsibilities to its business partners and teammates, and reaffirms the Company’s desire to act in a responsible way and improve its performance in meeting legislative requirements and more. The policies listed above, and any other relevant policies will be reviewed and updated annually to ensure they include reference to and adequately ensure compliance with the requirements of all relevant legislation. These are available to all colleagues through the Company’s shared drive.
Employee Awareness & Management
New teammates are made aware of the key aspects of the legislation upon joining the Company, as well as understanding what they should do if they believe a supplier is working in a way that could be considered as being contrary to the provisions of the Act.
The Company’s management team have been made aware of the obligations within the Act, the due diligence process the Senior Leadership Team have conducted and the actions required of the Company’s managers to ensure that the Company complies with the requirements of the Act. They have also been made aware that any suppliers who work with or for any manager is properly reviewed to ensure that Supplier’s compliance with the Act.
This Policy Statement will be reviewed annually and updated, as necessary.
On behalf of the board
Jane Pocock
CEO UK & Ireland
Date reviewed: Nov 2025
Due for review: Nov 2026
Version: 4
Department: People Team