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ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT
Modern Slavery refers to the exploitation of individuals through coercion, deception, or force, encompassing various forms such as forced labour, servitude, and human trafficking through involuntary recruitment, transportation, harbouring, or receipt of people against their will. A person is considered to be trafficked if they are brought to a country or location by others who threaten, frighten, hurt or force them to work against their will.
This statement is made on behalf of Ingram Motoring Group Limited pursuant to Section 54(1) of the Modern Slavery Act 2015 (the 'Act'), and constitutes the Group's slavery and human trafficking declaration. It sets out the Group’s actions to understand all potential modern slavery risks, to tackle and eliminate modern slavery within the business and supply chain, and applies to all persons working for us or on our behalf in any capacity, including but not limited to employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and any business affiliated with the supply chain.
Ingram Motoring Group Limited is a well established, family owned and operated motoring group that has taken great pride in serving new and returning customers throughout Ayrshire, Scotland and beyond for over 50 years. Our aim is to continually strive for excellence by exceeding customer expectations and delivering unparalleled levels of service and satisfaction.
We are committed to partnering with one of the most trusted brands in the world – The Volkswagen Group. Ensuring our ethical values and moral standards align extensively with one another is of the utmost importance to Ingram Motoring Group Limited.
Maintaining a zero tolerance approach to any form of modern slavery and human trafficking in any of the business operations, the Group has, and will continue to be, committed to implementing systems and controls aimed at ensuring that modern slavery and human trafficking is not taking place anywhere within our organisation.
We expect that our brand partners will hold their own employees, business partners and other third parties to the same high standards.
Ingram Motoring Group Limited is concerned to have a clear and unambiguous Code of Conduct which is understood and adhered to by every employee, regardless of position and length of service.
Detailing the expected behaviours and actions, The Ingram Motoring Group Code of Conduct focuses on honesty, integrity and ethical behaviour, as well as responsibility. It helps employees to observe existing company rules in the workplace and act in a corporate and socially responsible manner by setting out the context within which Ingram Motoring Group Limited can operate effectively to meet the expectations of internal and external stakeholders. The Code of Conduct is introduced at the induction process when onboarding new employees and is available at all times, along with the policies and procedures in relation to The Modern Slavery Act 2015 noted below.
As a Volkswagen Group (VWG) business partner, Ingram Motoring Group Limited aligns with the ethical requirements as set out in The VWG Code of Conduct. All employees are required to complete regular mandatory training as set out by VWG, regardless of hierarchical level. Including observance of human rights, such as the probation of child labour, human trafficking and slavery, as well as ensuring environmental protection and preventing corruption. The requirement to comply with VWG Code of Conduct is regarded as the basis for shaping the business relationship and ensuring all parties align in a shared vision to eradicate anti-slavery and human trafficking within the supply chain.
We have created awareness of modern slavery and human trafficking through communication with all employees.
The following policies are available at all times:
Anti-Slavery and Human Trafficking Policy
Anti-Bribery Policy
Bullying and Harassment Policy
Code of Conduct and Business Behaviour
Equality, Diversity and Inclusion Policy
We will continue throughout 2026/2027 to prevent modern slavery and human trafficking within the organisation by embedding these principles and combining the following steps:
Continued communication regarding our whistleblowing system, responsible for receiving and processing reports of serious regulatory violations. Our employees, business partners and other third parties may use our whistleblowing system to report modern slavery concerns or incidents.
Complying with applicable labour laws relating to working terms, conditions, and pay such as Working Time Regulations 1998, Health and Safety at Work Act 1974 and applicable legislation, and the National Minimum Wage Act 1998. We place great emphasis on the fair and equal treatment of all employees, who are paid, at the very least, the applicable financial year rate of National Minimum Wage.
Ongoing regular risk assessments and background checks, ensuring compliance with Right to Work in the UK documentation for new employees to prevent employees working illegally.
Due diligence to guarantee suppliers are taking the necessary steps to mitigate any risks on the use of child labour, slavery and human trafficking.
Ingram Motoring Group is dedicated to the prevention, detection and reporting of modern slavery in any part of our organisation. Employees, Directors and all stakeholders must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this statement.
As an equal opportunities employer, we are committed to creating and ensuring a non-discriminatory and respectful working environment for all. We cultivate a culture wherein every individual feels confident in exposing any wrongdoing without risk to themselves.
The Group acknowledges that modern slavery exists and everyone has a vital role to play in tackling the issue of exploitation. In the event that any of our business partners are found to be engaging in slavery or other unethical working practices, we will take steps to address those issues with this business partner, seek to drive improved standards and, if necessary, terminate relationships with any such business partners.
This statement has been approved by the Ingram Motoring Group Board of Directors on 3rd December 2025.
Managing Director: Malcolm Ingram
Finance Director: Andrew Fyfe
Sales Director: Kenneth Monaghan
This 2026 statement will be reviewed and updated annually.