Modern Slavery Statement
Modern Slavery & Human Trafficking Statement 2022
Our latest available Modern Slavery & Human Trafficking Statement is for 2022. Our historic reports are published as National Express Group. In future they will be published as Mobico Group.
This statement is made pursuant to the Modern Slavery Act 2015. It sets out the steps taken by Mobico Group PLC and its relevant subsidiaries (together, the" Group") during their financial year ending 31 December 2022 to ensure, as far as reasonably possible, that no modern slavery or human trafficking takes place in any part of their business or supply chain.
The Mobico Group is a leading public transport provider with bus, coach and rail services in the UK, Continental Europe, North Africa, North America and the Middle East.
The Group is organised into a number of divisions: UK Coach & Bus (providing coach and bus services in the UK); North America Bus (providing student transportation, transit services and shuttle services in 34 US states and 3 Canadian provinces); ALSA (providing coach and bus services in Spain, Switzerland, Puerto Rico and Morocco); German Rail; and International (the Bahrain bus operation which the Group operates jointly with Ahmed Mansoor Al A'Ali through a joint venture).
The Group's revenue from its continuing businesses for the year ended 31 December 2022 was £2.81 billion and its normalised operating profit from those businesses for the same period was £197m. The Group employed close to 46,200 people, the majority of which are drivers.
The Modern Slavery Act is relevant to all commercial organisations in any sector that supplies goods or services, and conduct business in the UK. It is the Group's policy to conduct its business in an ethical manner and with integrity. Accordingly, the Group has a zero-tolerance approach to slavery and human trafficking and is committed to taking steps to enforce such approach as detailed in this statement.
Our supply chains
The Group procures goods and services from suppliers around the world, which total several thousand in number and operate from multiple countries. Our vendors supply a variety of categories from rolling stock, road vehicles, fuel and utilities to uniforms, catering, cleaning, contract employees (including drivers) and security.
The Group aims to ensure that its suppliers meet high standards with respect to both the conduct of their business and their management of social and ethical issues.
To this end, the Group has in place Ethical Sourcing Standards which we expect our suppliers to comply with. We have a practice of including in our supplier contracts the right to audit such compliance and take other remedial action against suppliers should we find non-compliance.
As reported in our 2018 statement, the Group has adopted a Modern Slavery Policy. The Group also has a number of other policies in place which support ethical behaviour and assist in deterring and detecting unethical behaviour, including modern slavery.
The Group has a Workplace Rights Policy and a Human Rights Policy. The Group also has in place a Whistleblowing Policy and operates a confidential whistleblowing hotline in the UK, North America, Spain, Morocco, Germany Switzerland and Bahrain.
The Group was the first private transport provider to commit to becoming a voluntary Living Wage employer. UK Bus secured Living Wage Foundation accreditation in January 2016, followed by UK Coach obtaining the same accreditation in October 2018. For any other country in which the Group operates, we are committed to pay at least 10% above the national minimum wage in that country. The Group is also committed to providing a workplace that values diversity, champions inclusion and respects the rights of all employees. These are examples of commitment to conducting business in an ethical manner and with integrity.
Steps taken by the Group
During 2022, the Group continued to ensure its Modern Slavery governance and controls across the supply chain were robust. This included specialised training for Procurement; continuing category assessment and supplier audits; updating supplier contracts with additional ethical clauses.
The Group’s dedicated Procurement employees across all divisions attend the Ethical Procurement and Supply course provided by the Charted Institute of Procurement & Supply. This training is a mandatory requirement for all Procurement employees to undertake on an annual basis.
The UK, North America, Bahrain and Alsa divisions continue to work within the Group’s Modern Slavery four-step process: Assess, Analyse, Action and Audit. New suppliers are subject to the assessment stage. If they fall within a high-risk category, the analysis and action stages must be completed before a purchase order is placed. Existing suppliers are reassessed across a 3 to 5 year cycle.
During 2022, the UK, North America and Alsa divisions addressed low scoring suppliers from the responses to the 2021 questionnaire through a variety of measures. These included additional due diligence, the changing of suppliers, sharing knowledge and techniques and supply chain mapping.
The Bahrain division refreshed its risk assessment analysis and published a questionnaire to the suppliers identified in high-risk supply categories. The responses are to be evaluated in 2023.New employees across the Group are offered training to develop employee understanding and individual responsibilities. The Alsa division carried out refresher training for all employees to improve their knowledge regarding the risk of Modern Slavery with a completion rate of almost 70%.
The Group governed its progress through quarterly steering group meetings consisting of representatives from each of the divisions and Procurement, Compliance, HR and Legal. The steering committee will continue to engage in 2023 to ensure each division is focused on robust supply chain assessment utilising questionnaires, supporting audits and expanding our modern slavery training across the organisation.
Approval of this Statement
The Audit Committee of the Board of Directors of Mobico Group PLC has concluded that the policies, together with the steps taken and to be taken, provide reasonable assurance that the Group is acting in a way which reduces the risk of slavery and human trafficking in both its own business and in its supply chains.
This statement has been approved by the Board of Directors of Mobico Group PLC. This statement has also been approved by the Boards of Directors of relevant UK subsidiaries of National Express Group PLC to which it also relates, being National Express Limited and West Midlands Travel Limited.
Signed for and on behalf of Mobico Group PLC and each of its relevant subsidiaries
Group Chief Executive officer
22nd June 2023