Modern Slavery Statement
Tackling Modern Slavery
This statement is made pursuant to the United Kingdom’s Modern Slavery Act 2015, section 54. It constitutes Keyloop’s modern slavery & human trafficking statement for the 2022 financial year which ended up 31 December 2022. It is intended to cover all entities within the Keyloop group.
Forced, bonded or compulsory labour, human trafficking and other kinds of slavery and servitude represent some of the gravest forms of human rights abuse in any society.
Keyloop will not tolerate any such activities within our own operations or within our supply chain and are committed to taking appropriate steps to ensure that everyone who works for Keyloop – in any capacity, anywhere in the world – benefits from a working environment in which their fundamental rights and freedoms are respected.
Within this statement we report on our efforts to prevent modern slavery in line with the requirements of the UK Modern Slavery Act (2015). We remain focused on the rights and wellbeing of the people who work for Keyloop and for our suppliers.
Our Statement provides details of our policies, our approach and the actions we have taken in the 2022 financial year to further strengthen our programme and commitment to respect and uphold people’s fundamental rights and freedoms.
Keyloop’s mission is to create and connect technology that advances the car buying and ownership experience in partnership with dealers and OEMs. It is a leading global provider of software solutions to the auto retail industry, serving approximately 18,000 dealer sites and most automotive manufacturers, in 100 countries. Keyloop employes circa 2,400 people worldwide and is headquartered in the UK, with operations across EMEA, Asia and more recently North America.
The ultimate parent company for Keyloop is Concorde Topco Limited. This statement has been prepared by Concorde Topco Limited on behalf of itself and the Keyloop group.
Our Supply Chain
We will not strike up a relationship with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in any form of slavery, servitude and forced or compulsory labour. In turn we expect our supply chain to only employ people who choose to work freely and respect their rights to equal opportunities and freedom of association.
When suppliers wish to work with Keyloop, we focus their attention on our Supplier Code of Conduct. This Code reflects our expectation of our business relationships and outlines the high standards Keyloop hold regarding implementing effective systems and controls to ensure slavery and human trafficking is not taking place in the supply chains.
Keyloop requires all suppliers to adhere to our Supplier Code of Conduct, only by exception and revision by our Legal & Compliance team we will consider a suppliers own code of conduct.
Our contract terms contain statements to ensure our suppliers will comply with all applicable laws in countries of operation.
Where it is appropriate we conduct due diligence (on a risk-based approach given the products and services being supplied) and do so following standard procurement practices, starting with a supplier creation form.
Where necessary for new suppliers we will request further information from the supplier such as copies of policies and where applicable, we will perfom checks against Sanctions lists, PEPs and Adverse Media to ascertain suitability as a supplier to Keyloop. These checks are then monitored via a system for any changes in status of the supplier.
We expect all suppliers to have a Modern Slavery Policy and plans in place to address their own compliance risks within their organisations and supply chains and to conduct appropriate due diligence on their supply chain.
Our Principles, Codes & Policies
To support our trusted and principled business we commit to making sure that we have appropriate policies in place and that these are used internally and externally to conduct our business in a lawful and ethical manner.
Keyloop employees are expected at all times to act lawfully, ethically, and in the best interests of Keyloop.
A Modern Slavery Policy and an Anti-Bribery & Corruption Policy are both in place and regularly reviewed to ensure they are accurate and abide with any laws and uphold the company’s values. These policies are available internally and can be requested externally at any time.
We maintain a Whistleblowing Policy and process where employees and interested third parties can confidentially and anonymously report concerns which may include modern slavery and human trafficking issues, any information brought to Keyloop’s attention will be followed up and as deemed necessary a thorough investigation and outcome decided.
At Keyloop we believe the prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our contract with us. Keyloop expects any persons working for the organisation to avoid any activity that might lead to, or suggest a breach of this policy and others.
All employees complete mandatory online compliance training courses annually. These include Modern Slavery, Whistleblowing and other topics such as Anti-Bribery & Corruption.
This programme of modules has proven successful in increasing employee awareness for key topics and we see rates of completion at over 90% across all courses.
For us this is a key indicator of our employee’s emgagement and commitment to learn and embrace the Keyloop culture and values and to ensure that we remain a compliant and safe employer.
Keyloop periodically reviews the effectiveness or our processes and systems; any changes will be reflected in future annual statements.
This statement was approved by the Concorde Topco Limited Board of Directors and is signed on their behalf by the CEO.