Modern Slavery: Our Slavery and Human Trafficking Statement FY2020/21
This statement, published in accordance with provisions of the Modern Slavery Act
2015, sets out the policies, processes and actions we have taken during thefinancial year ended 30 September 2021 to prevent modern slavery in ourbusinesses and supply chains. It is intended to cover all the business andundertakings of National Car Parks Limited (“NCP”).
At NCP, we are committed to conducting business responsibly and have a zerotolerance approach to all forms of modern slavery across our operations. We arecommitted to ensuring everyone who works for NCP does so in an environment
where fundamental human rights are upheld, and we expect anyone that we dobusiness with also upholds these principles as well. We are continuously working toimprove our operations in practice reflect that expectation.
1. Our Business
NCP is the UK’s largest and longest-standing private car park operator. We operate
more than 500 car parks servicing towns, cities, airports, and railway stations
throughout the United Kingdom. To deliver parking services to our customers andclients, we employee over 900 people within the United Kingdom and have morethan 750 active suppliers.
2. Our Supply Chain
With over 750 active suppliers, it’s crucial that NCP understands the level of risk
posed by its suppliers in a modern slavery context. The majority of suppliers are
based the United Kingdom (over 98%). The countries in which they are based areshown in the table below:
Number ofCountry

Suppliers
776

U.K.

3

Netherlands

2

Australia

2

Luxemburg

1

Ireland1

Philippines

3. Our Values
NCP has introduced a focus on Kaizen. This is a concept that refers to ongoing andcontinuous improvement working culture. The idea is that every small improvement
adds up and supports a safer and more successful business in all respects. This has
been visible within the approach taken by NCP this year to improve how we identify
and address risks within our supply chain and within our work force.
4. Focus on Wellbeing
As with many businesses and people around the world, the past two years havepresented unique challenges for NCP and its staff. During this challenging period, NCP
recognised the mental strain and vulnerability people have faced during the uncertainty
presented by Covid-19. We prioritised the welfare and safety of our colleagues by
supporting flexible working arrangements and encouraging working from homewherever appropriate. This was accompanied with mental health awareness andresilience training, as well as presenting creative suggestions as to how to stayconnected with colleagues while working from home and the roll out of a quarterly
anonymous staff engagement surveys have been distributed to all staff members. Thisyear
NCP
also
partneredwithChasing
theStigma
as ourchosen charity, to recognise the significance of mental health awareness both forcolleagues here and overseas.
5. Our Governance & Policies
NCP’s commitment to human rights and the eradication of modern slavery is sharedthroughout the business. Our policies support NCP in mitigating risks, both within ourbusiness and our supply chain. Responsibility for managing these policies varies policy
to policy. However, our annual modern slavery statement is ultimately approved by ourboard of directors and signed off by our Chief Executive Officer, following a crossdepartmental review.
a. Anti-Modern Slavery and Human Trafficking Policy
This statement is reviewed and updated each year, with an updated policy lastissued during May 2021. The policy is an internal document that sets out theexpectations we, as a business, have in relation to our zero-tolerance approach
to modern slavery and human trafficking. It applies to all individuals working in
NCP at all levels and grades (whether they are permanent, fixed term, ortemporary) and all of NCP’s subsidiaries.

b. Whistleblowing Policy
This sets out how NCP is committed to prompting high standards of openness,probity and accountability. Our whistleblowing policy is available for all staff toview on our intranet and is communicated annually. It sets out how complaints
can be made, including the ability for these to be made anonymously.
c. NCP Code of Ethics Policy
This sets out NCP’s expectations on how all colleagues are expected to behave.
Colleagues receive a copy of it when joining our business, and an up to dateversion is maintained on our intranet. This is maintained by our HR department.
Amongst other things, it requires colleagues to treat each other fairly and notto discriminate on any grounds, to always treat those who raise concerns of
misconduct or malpractice in accordance with NCP’s whistleblowing proceduresand prohibits doing business with countries subject to trade restrictions,embargoes or sanctions. Failure to comply with this may result in disciplinary
action.
d. HR Recruitment and Selection Policy
This policy is managed by HR and sets out NCP’s commitment to equality ofopportunity in recruitment, selection, promotion and all areas of employment.
NCP aims to attract high calibre colleagues by ensuring that our recruitment andselection processes are effective, systematic and equitable. We recognise thatcolleagues are critical to our success, and the utmost importance is placed on
ensuring that a consistent, fair and professional approach is applied throughout
the recruitment and selection process. This enables us to employ the best
people who possess the necessary skills and attributes, and who demonstrate
the behaviours essential to fulfil our strategic ambitions.
NCP will avoid unlawful discrimination in all aspects of employment including
recruitment, promotion, opportunities for training, pay and benefits, disciplineand selection for redundancy.
6. Risk Management & Due Diligence
NCP’s commitment to human rights and the eradication of modern slavery is sharedthroughout the business. Our policies support NCP in mitigating risks, both within ourbusiness and our supply chain. Responsibility for managing these policies varies policyto policy. However, our annual modern slavery statement is ultimately approved by ourboard of directors and signed off by our Chief Executive Officer, following a crossdepartmental review.

Part A: Our People
a. Recruitment and Fair Pay
To manage potential risks in relation to onboarding our employees, we ensure
all our direct hires are subject to standard “right to work” checks, DBS checks
and depending on the nature of the working permits, we may audit these fromtime to time. We have focused on staff wellbeing and taken steps to ensure all
our staff are paid fairly.
b. Changes to our recruitment processes
During the past year, our HR department has been working to develop a direct
hire talent acquisition model to offer in house end to end recruitment services
for our business, and the use of external recruitment agencies will be centralisedand managed by a specific Talent Acquisition Term. It is anticipated that thiswill have many benefits for NCP, including enabling more control and procedures
around how staff members will join our business. This will also give more
centralised control of ensuring all external suppliers of workers to NCP haveappropriate terms in place to protect NCP, and any temporary or contract hire
relationships.
c. Training and awarenessOur staff play a key role in mitigating risk(s) both within our business and supply
chain, and we recognise that appropriate training and communication isessential. Our Learning and Development Team have been working throughout
2021 to build on our existing training and to launch a new modern slavery
training module to all staff to ensure year-on-year improvement in terms of ourcommitment to identify the risks of, and remove all instances of, modern
slavery, human trafficking and exploitation.
d. Communication
NCP recognises communication is an essential part of raising modern slavery
awareness within our business. All of NCP’s policies documents are madeavailable either via internal communication channels as well as on our intranet.
This statement will be distributed to all staff via internal communication
channels following board approval and will be published on NCP’s website.
We recognise communication must be both ways, which is why during the pastfinancial year, quarterly anonymous staff engagement surveys have been
distributed to all staff members. We believe anonymous, company-wide surveys
are a useful tool for understanding the wellbeing needs of all colleagues and tobetter recognised gaps in support they feel is needed.

e. Whistleblowing Hotline
In April 2019, NCP introduced a whistleblowing hotline to help create a culture
where staff feel confident in raising concerns safely. A company-wide
memorandum was emailed to all staff in at the beginning of FY2020/21 together
with NCP’s whistleblowing policy and information on the hotline, so that all staff
are clear that there is a hotline service provided by an independent, external
whistleblowing service provider that can be contacted. Once reports are made,responsible colleagues allocated to this are notified, so that if a report is received
an investigation can be conducted and a response given to colleagues who haveraised concerns within a specified timeframe.
Part B: Our Suppliers
Our standard supplier terms and conditions require compliance with all applicable law,and reference compliance with NCP’s requirements with regard to modern slavery. We
reserve the right to terminate immediately for breaches of these clauses. While ourterms may vary between suppliers, our Legal department maintains a guidance noteon changes we are able to accept to ensure essential clauses are not removed fromour standard terms unless appropriate in that particular instance.
During the past year, NCP has been investigating ways it can improve its supplieronboarding and supply chain risk management processes to ensure our Procurement
team have access to support and are able to access up to date supplier informationand ensuring compliance with NCP’s onboarding requirements across the board. This
review is ongoing, but we recognise NCP needs to focus on:
••
•
•
•

implementing more robust risk-profiling by suppliers when onboarding newsuppliers;
re-thinking what we require of suppliers based on the risk profile;improving NCP’s supplier vetting processes;
improving the way we monitor supplier risk throughout the duration of therelationship; andconducting more audits of suppliers.

7. Measuring and Monitoring Progress
Our modern slavery statement will be reviewed annually by colleagues from Legal,HR, Risk and/or Procurement prior to it receiving board approval. This is done toensure we are meeting our ethical and legal obligations and providing up to date
information within NCP’s statement. This annual review is a great opportunity for us
to see how we have performed over preceding financial year, and how we can look
to improve in the current year.
Our performance during the financial year ended September 2021 was assessed byexamining the following key performance indicators:
 Number of NCP staff that have undertaken awareness training.
 Number of modern slavery complaints made to our whistleblowing hotline.
 Evidence or suggestion of any material breaches or reasons for concern.
Our goals for the financial year ending 30 September 2022:
 Communication: Ensure the Modern Slavery statement is communicated toall staff members as well as being uploaded to NCP’s website.
 Training: Ensure new training is delivered to all NCP staff and ensure this iscommunicated and pushed to maximise staff engagement and increase thenumber of NCP staff who undertake this training in the next financial year.
 Whistleblowing: Maintain our high level of performance in relation toinvestigating all reports made to our external, independent, whistleblowing
service provider within the target timeframes.
 KPIs: Improve on our KPIs/performance year on year and develop new KPIs.
8. Board approvals
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015and has been approved by our Board of Directors on 7 December 2021.

Hiroyasu MatsuiChairman and DirectorDecember 2021