Modern Slavery and Human Trafficking Statement

For the financial year ending 31 December 2025

This statement sets out the steps taken by Foray Motor Group to prevent modern slavery and human trafficking in our business operations and supply chains, in accordance with section 54(1) of the Modern Slavery Act 2015.

Foray Motor Group is committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our business or supply chains.

1. Our organisation and supply chains

Foray Motor Group is a UK-based motor retail business operating from multiple locations across the United Kingdom. We have been trading since May 2000 and employ approximately 400 employees.

Our core activities include the sale of new and used passenger and commercial vehicles, servicing and repair, parts supply, accident repair services, and associated support functions.

Our supply chain is predominantly UK-based. A significant proportion of our vehicle supply is through Ford Motor Company, alongside a network of UK suppliers providing parts, services, facilities, professional support, and consumables. While we do not source raw materials directly, we recognise that the wider automotive supply chain is complex and may involve multiple tiers of suppliers beyond our immediate contractual relationships.

2. Policies relating to modern slavery

We operate a range of policies that support our commitment to preventing modern slavery and human trafficking, including but not limited to:

• Recruitment and selection policies

• Disciplinary policy

• Equality, diversity and inclusion policy

• Whistleblowing policy

• Health and safety policy

These policies are available to all employees and may be made available to third parties upon request via the HR department. Policies are reviewed regularly to ensure they remain compliant with employment legislation and reflect good practice. Our approach is underpinned by a zero-tolerance stance towards forced labour, human trafficking, and any form of exploitation.

3. Due diligence processes

As part of our commitment to responsible business practices, we take proportionate steps to assess and manage the risk of modern slavery within our operations and supply chains.

This includes:

• Conducting right-to-work checks for all employees in line with UK legal requirements

• Ensuring recruitment practices are transparent, lawful, and free from coercion

• Engaging with key suppliers and business partners who are expected to uphold comparable ethical standards

• Relying, where appropriate, on supplier assurances and contractual obligations that prohibit forced or involuntary labour

Given the nature and scale of our business, our due diligence processes are risk-based and focused on areas where we believe there is a higher likelihood of potential exposure.

4. Risk assessment and management

We recognise that modern slavery risks exist across the wider automotive sector, particularly within complex, global manufacturing supply chains. While our direct operations are UK-based and subject to robust employment regulation, we remain mindful of indirect risks further upstream.

We assess modern slavery risk by considering factors such as:

• The type and location of suppliers

• The nature of goods and services procured

• Reliance on agency or temporary labour

• Industry-wide risk indicators

To date, we have not identified any known instances of modern slavery within our business or immediate supply chain. However, we acknowledge that risk can evolve and commit to maintaining appropriate oversight and review.

5. Measuring effectiveness

We monitor the effectiveness of our approach to preventing modern slavery through a number of measures, including:

• Ongoing management oversight of employment practices

• Completion of training and induction programmes

• Monitoring of concerns raised through internal reporting or whistleblowing channels

• Periodic review of policies and procedures

Where issues are identified, we take appropriate action to investigate and address them.

6. Training and awareness

All employees receive training as part of their induction to ensure they understand expected standards of behaviour, employment rights, and the importance of treating others with dignity and respect.

Managers receive additional guidance to help them identify potential indicators of modern slavery and to ensure concerns raised by employees or suppliers are handled appropriately.

Training and awareness form part of our ongoing commitment to maintaining a respectful, lawful, and ethical working environment.

7. Future commitments

During the next financial year, we aim to:

• Keep this statement under review and update it annually

• Review supplier arrangements where proportionate and appropriate

• Monitor developments in legislation and guidance to ensure continued compliance

Approval

This statement was approved by the Board of Directors of Foray Motor Group on 09 January 2026.

Simon Moulton - Managing Director
Sara Glasby - HR Director

For and on behalf of Foray Motor Group