SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR JAGUAR LAND ROVER AUTOMOTIVE PLC
AND ITS SUBSIDIARIES (JLR) FOR THE FISCAL YEAR ENDED 31 MARCH 2023
JLR’s Slavery and Human Trafficking Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 “Transparency in Supply
Chains”. This Statement sets out the steps JLR has taken to address the risk of slavery and human trafficking taking place within its own
operations and supply chains.
Please note for the purposes of this Statement JLR’s joint venture arrangements are treated as being part of our supply chain.
OUR ORGANISATION
Business Sector
JLR’s primary business is the manufacture of premium automobiles. JLR has a House of Brands, comprising Jaguar, Discovery, Defender,
Range Rover. JLR also supplies automotive parts, services and branded merchandise; offers a range of driving experiences and provides
mobility and smart transportation services.
Organisational Structure
The average number of staff working for JLR was approximately:
Average Staff Numbers (’000)
Year Ended 31 March 2023
Year Ended 31 March 2022
UK
Overseas
Total
UK
Overseas
Total
Direct Employees (Salaried)
14.8
3.8
18.6
14.2
3.6
17.8
Direct Employees (Hourly Paid)
11.2
3.9
15.1
12.7
3.6
16.3
Agency Staff
3.0
0.2
3.2
1.6
0.1
1.7
Total
29.0
7.9
36.9
28.5
7.3
35.8
JLR has a global sales network across 122 countries and approximately 1,424 franchised dealer sites worldwide. We have 19 JLR
owned National Sales Companies (NSCs) servicing 22 key international markets. During the year ended 31 March 2023, sales and certain
service support to the Russian market remained paused in line with our adherence to imposed global sanctions.
Other markets are serviced through export and import partners.
JLR’s traditional manufacturing base is in the UK. JLR also operates wholly-owned factories in Brazil and Slovakia. Other
manufacturing operations include a vehicle assembly site at Pune in India, and contract manufacturing by Magna Steyr at Graz in
Austria.
Responding to the Modern Slavery Act
JLR has a cross-functional working group to respond to the requirements of the Modern Slavery Act 2015. The working group has
representation from Group Compliance, Industrial Operations, and Human Resources. We have an ongoing programme to improve our
response to slavery and human trafficking risk. Existing policies and practices are regularly reviewed and updated as required.
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Global Headquarters, Research, Design,
Engineering and Manufacturing.
Manufacturing site
Vehicle assembly site
Manufacturing site.
SLAVERY AND HUMAN TRAFFICKING RISKS WITHIN JLR’S OPERATIONS
POLICIES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING
In light of the Modern Slavery Act 2015, during the year end 31 March 2016 we updated JLR’s Corporate Policies to be more explicit about
slavery and human trafficking. A new JLR Code of Conduct was issued during the year ended 31 March 2017. During the year ended 31
March 2023 the Human Rights Policy and JLR Code of Conduct were reviewed but not changed.
Code of Conduct
The JLR Code of Conduct (the Code) is applicable to all personnel working for and on behalf of JLR globally (JLR Personnel), including
direct employees and agency and contract staff. The Code states that:
We shall respect the human rights and dignity of all our stakeholders.
We do not employ anyone under the age of 15 at our workplaces.
We do not use forced labour in any form. We do not confiscate personal documents of JLR Personnel or force them to make
any payment to us or to anyone else in order to secure employment with us or to work with us.
All JLR direct employees are required to sign up to the Code on joining the business. The Code is available to JLR Personnel on the JLR
intranet and to external parties via the JLR Corporate website. The JLR Annual Compliance Declaration process requires all JLR salaried
staff globally and selected other personnel to confirm that they are aware of the Code and acknowledge that they are bound by it. For the
January 2023 declaration process, 100% of this population of approximately 19,760 people have completed their declaration.
Human Rights Policy
JLR’s Human Rights Policy articulates JLR’s requirements with regards to the protection of human rights. The Policy applies to all JLR
Personnel and has been distributed company-wide and is available for external parties via the JLR Corporate website. It sets out our
commitment to respecting human rights and complying with laws, rules and regulations governing human rights in the territories in
which we operate. This includes specific provisions addressing slavery, human trafficking, forced labour, child labour and upholding
each employee’s right to freedom of association.
Recruitment Practices
JLR undertakes “right to work” checks on all potential direct employees prior to interview by the Company. This includes checking
whether the candidate is of an appropriate age to work and, where applicable, that they have a valid work visa.
Trade Unions and Other Bodies Representing Workers
Through the Code, Human Rights Policy and employment practices, JLR recognises and respects each employee’s right to freedom of
association, including the right to join trade unions.
Access to Remedy for Victims
If JLR Personnel identify any potential signs of slavery, human trafficking or other human rights abuses, they are encouraged to report
this to JLR management directly or through our externally run “Speak Up” confidential reporting facility. The guidance in our
Confidential Reporting Policy includes examples around reporting concerns regarding slavery and human trafficking.
To date, JLR has received no reports of concerns regarding slavery or human trafficking in our operations. In the event that such issues
were reported to us, we would undertake an urgent thorough investigation into the concerns raised under the supervision of members of
the JLR Limited Board of Directors. If the investigation confirmed the concerns, we would put in place robust action plans to address the
issue and protect the victims.
TRAINING ON SLAVERY AND HUMAN TRAFFICKING
Training has been delivered to those individuals in roles most likely to be in a position to identify and address potential modern slavery
risks. At the date of this report, 91% of the target population have completed this training.
In the year ending March 2023, JLR launched a refreshed e-learning course on the JLR Code of Conduct, reiterating JLR’s commitment to
respecting human rights. This training includes a scenario addressing human rights concerns. As at March 2023, 97.4% of the target
population had completed this training.
RISKS OF SLAVERY AND HUMAN TRAFFICKING IN JLR’S OWN OPERATIONS
We have refreshed our assessment of slavery and human trafficking risks within JLR’s own operations. We considered: the location of
our operations; roles being performed; recruitment processes; and absence to date of reports of concerns regarding slavery and
human trafficking.
As well as direct employees, JLR has agency and contract staff working at our sites. Contractual terms and conditions are in place
with the companies that provide JLR with agency staff, requiring them to have policies and processes in place to protect human rights.
We have obtained assurances from all key providers of agency staff with regards to their commitment to respecting human rights,
including supplying us with a copy of their Slavery and Human Trafficking Statement, where applicable.
Based on our risk assessments, we continue to deem the risk of slavery or human trafficking occurring within JLR’s direct employee
population, or our agency and contract staff population under our direct supervision, to be low.
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SLAVERY AND HUMAN TRAFFICKING RISKS WITHIN JLR’S SUPPLY CHAINS
JLR sources goods and services directly from a global network of approximately 7,175 suppliers, based in 72 countries. These
suppliers can be analysed by the area of the JLR business that they primarily supply goods and services to, as follows:
Area of JLR Business
Approximate Number of Suppliers
Year Ended 31 March 2023
Year Ended 31 March 2022
Production and Special Operations
500
Indirect Procurement and NSCs
4,900
Aftermarket
1,000
Branded Goods
50
Total
6,450
Like other automobile manufacturers, JLR’s supply chain is highly complex. This complexity and limitations on the visibility beyond the
first tier of the supply chain mean there are inherent challenges in efficiently and effectively assessing and addressing supply chain
issues, such as human rights risks. Therefore, our work to address slavery and human trafficking risks within our supply chains has been
focused primarily on our Tier 1 suppliers.
RELATIONSHIPS WITH SUPPLIERS
JLR actively manages its relationships with its Tier 1 suppliers. There are clear contractual arrangements in place with all direct and
indirect suppliers, who are required to sign up to JLR’s Global Terms & Conditions (Global T&Cs). JLR communicates the standards
expected of its suppliers through a variety of mechanisms, including: supplier conferences; Supplier Sourcing system, Covisint (a global
supplier portal); direct buyer interactions; emails to suppliers; and via the JLR Corporate website.
EXPECTATIONS OF SUPPLIERS
The standards JLR expects its suppliers to meet, including standards equivalent to those articulated in the Code, are set out in the Global
T&Cs, which also detail human rights requirements, including basic working conditions. The Global T&Cs are supported by JLR’s Global
Sustainability Web Guide – Supplier Environmental & Social Requirements document which articulates the minimum environmental and
social standards JLR expects all its suppliers and business partners to adhere to.
These address working conditions (including specific reference to the Modern Slavery Act), with expectations of processes and safeguards
to demonstrate compliance. There is an accompanying Minimum Standard of Working Conditions Self-Assessment Checklist.
There are several processes in operation that address human rights risks within JLR’s supply chains. These include:
The requirement to complete automotive industry supplier sustainability assessments applies to all of our Production Purchasing
and Special Vehicle Operations suppliers, as well as those Indirect Procurement, Aftermarket and Branded Goods suppliers with an
annual spend of more than at least £100,000. To date 1,288 suppliers (at individual statutory entity level) have completed the
assessment, which includes questions regarding forced / bonded and child labour. The assessment has been developed to address
the Modern Slavery Act, as well as other sustainability related regulations. No slavery or human trafficking issues have been
reported to us through these assessments.
The Supplier Technical Assistance diagnostic tool assesses all potential new suppliers for Production and Special Vehicle Operations.
It includes six questions on human rights. Suppliers are asked to confirm that they do not employ any form of forced or child labour.
No slavery or human trafficking issues have yet been identified by this process.
Branded Goods Manufacturing Site Self-Assessment (MSSA) is required to be completed by all new suppliers of branded goods. The
MSSA asks for information on labour standards, whistleblowing facilities and ethical/ social audits completed. Responses have been
received from all current branded goods suppliers. No slavery or human trafficking issues have been reported to us through these
self-assessments.
JLR China Supplier Self-Assessments, which new suppliers to JLR China are asked to complete, addressing legal and regulatory
obligations. We also undertake searches of publicly available sources to see whether concerns are highlighted. No slavery or human
trafficking issues have been identified through these assessments.
During the year ended 31 March 2023 we received a report of human rights concerns at one supplier to JLR. Our investigations to date,
which included a detailed audit of working conditions at the supplier’s facilities and confidential interviews with employees, have
determined that the concerns were not founded.
If we became aware of slavery or human trafficking concerns within our supply chains, we would seek to work with the relevant
suppliers to improve conditions for their workforce. We reserve the right to deselect suppliers, if they were to fail to make required
improvements within a reasonable timeframe.
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ASSESSMENT OF RISKS OF SLAVERY AND HUMAN TRAFFICKING IN JLR’S SUPPLY CHAINS
JLR maintains a register of suppliers that have published Slavery and Human Trafficking statements, which we monitor as part of our
assessment of suppliers’ approaches to addressing modern slavery risks. To date, we have identified approximatively 710 of our
suppliers that have published a Statement setting out the actions they are taking to address slavery and human trafficking in their
operations and supply chains.
In our Slavery and Human Trafficking Statement for the year ended 31 March 2022, we reported that we had identified 65 suppliers who
were deemed to present an elevated risk of slavery and human trafficking. We distributed a Slavery and Human Trafficking Questionnaire
to these suppliers, in order to seek additional assurance. Of these 65 suppliers:
27 provided a satisfactory initial response to the questionnaire;
34 required further follow-up and we are working with these suppliers to obtain relevant assurances;
3 are no longer JLR suppliers; and
In 1 case, no response has been received to date.
For the year ended 31 March 2023, we have undertaken our annual exercise to assess slavery and human trafficking risk within JLR’s
supply chains. We have evaluated our Tier 1 suppliers by considering the countries where our suppliers are based, products and services
being supplied and the volume of spend. The data was evaluated against recognised external indices of perceived slavery risk within
sectors and geographic areas, to assess whether suppliers may represent an elevated modern slavery risk.
For the year ended 31 March 2023, our supply chain risk has identified an additional 43 suppliers which may represent an elevated slavery
or human trafficking risk. These suppliers span 12 countries: Brazil, Bulgaria, China, India, Malaysia, Mexico, Morocco, Romania, South Africa,
Thailand, UAE and Ukraine. We are currently seeking further information to understand how these suppliers protect human rights within
their operations.
We have performed several social audits in the year ended 31 March 2023 of suppliers which may represent an elevated slavery or
human trafficking risk. These audits have not identified significant risks or issues with those suppliers.
Also for the year ended 31 March 2023, a JLR Modern Slavery Act Compliance Programme questionnaire has been completed to our
satisfaction by each of JLR’s joint ventures.
There are also a number of people working on our sites as employees of companies providing outsourced services, such as cleaning,
logistics and catering. The nature of these services may mean there is an increased inherent risk of slavery and human trafficking. The
companies that provide these services are subject to the Global T&Cs.
EVOLVING APPROACH TO SLAVERY AND HUMAN TRAFFICKING RISK IN SUPPLY CHAINS
The Code, our Policies and contractual terms are clear on the need to protect human rights. However, we recognise that these measures
only give a limited degree of comfort that slavery and human trafficking are not occurring within our supply chains. We will continue to
assess how we might obtain further comfort over the effectiveness of anti-slavery and human trafficking measures beyond the first tier of
our supply chain.
As our programme progresses, we have prioritised potentially higher risk suppliers for the risk mitigation measures we implement.
During the year ended 31 March 2023, we have obtained more granular data from suppliers, undertaken more detailed reviews of
supplier information (particularly with regard to commodity level information), rolled-out self-assessment questionnaires to additional
higher risk suppliers, and commissioned a programme of social audits at higher risk suppliers.
We have implemented supply chain traceability and risk scanning tools to continue to seek further transparency within our supply chain
to identify potential risks relating to forced and child labour.
APPROVAL
This statement has been reviewed by the Board of Directors of Jaguar Land Rover Automotive plc and is approved on the Board’s behalf by
the Chief Executive Officer.
Adrian Mardell
Chief Executive Officer of Jaguar Land Rover
21 July 2023