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Modern Slavery Act Statement

Stephen James (Automotive) Ltd is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain, and imposes the same high standards on its suppliers. Stephen James (Automotive) Ltd believes it is our responsibility to uphold the highest standards of ethical behaviour and personal integrity within our business operations. Wherever we do business, our colleagues are required to comply with all applicable laws, rules, and regulations.

Modern slavery is a crime and a morally reprehensible act that deprives a person’s liberty and
dignity for another person’s gain. Stephen James (Automotive) Ltd has a zero-tolerance approach to
Modern Slavery, and is fully committed to preventing slavery and human trafficking in our
operations and supply chain. As a company we are committed to protecting our organisation and
those people at risk from exposure to slavery or human trafficking in our supply chain, both via our
direct employees and those working on our behalf via third party suppliers.

Organisational Structure and Background

Stephen James Alliance Limited is the parent company of DC Management Services Limited which in
turn is the parent company of Stephen James (Automotive) Limited. Stephen James (Automotive)
Limited operates franchised motor dealerships from multiple sites around the M25 and the latter
holds the property assets from which these activities operate. The Company employs c. 440 people
and has an annual turnover in excess of £200m.

Stephen James (Automotive) Ltd retails both the BMW and MINI brand and is proud to still retain a
strong family culture across our 5 Centres.

We strive to deliver an exceptional customer experience; our colleagues are highly trained,
enthusiastic, knowledgeable and driven to deliver our fundamental commitment to our customers;
we strive to get it right first time and make each and every interaction special. Our ultimate aim is to
be considered the best privately owned company to work for in the industry and the best company
to do business with.

Our Colleagues and Policies

Our colleagues are all provided with a written contract of employment as well as access to a
company handbook which contains the policies that governs their employment. Each colleague has a
personal responsibility to read the handbook, as well as to ensure that they fully understand our
obligations and the consequences associated with any breach of those obligations. We are
committed to uncompromising integrity in all that we do and how we relate to each other and to our
customers.

It is a fundamental policy of Stephen James (Automotive) Ltd to conduct business with reference to
our 5 core values which are; Unquestionable Honesty, Unrivalled Service, People Obsession,
Outrageous Creativity and Giving Back. We appreciate that our employees play a key role in
maintaining high standards and ensuring that, as a business, we are compliant in all aspects of
regulations set forth by the UK Government.

As part of our commitment to combating modern slavery, we have implemented the following
policies:

Our board of directors has overall responsibility for the effective operation of this policy and for
ensuring compliance with the relevant statutory framework. The Group HR Manager has day-to-day
responsibility for operating the policy and ensuring its maintenance and review.

Our Third Party Supply Chain

The Motor Trade supply chain is one of the most complicated in any industry. The breadth, depth
and interconnectedness of the automotive supply chain make it challenging to effectively manage
and mitigate the risk of modern slavery. We also recognise that the nature of the motor industry is
such that our supply chain for new and used vehicles is multifaceted as any given vehicle will have its
own supply chain for the various component parts. We therefore understand that ultimately our
vehicle supply chain begins with the sourcing and manufacturing of the raw materials required for
any part of a vehicle. As our relationship is with the vehicle manufacturer and not with their supply
chain, we’re keen to engage with our suppliers to ensure that they match our high standards and the
ethos of the Modern Slavery Act 2015 and filter this message down throughout their own supply
chain.

Stephen James (Automotive) Ltd is committed to ensuring there is transparency in our own business
and in our approach to tackling Modern Slavery throughout our supply chains and expect the same
high standards from all of our contractors, suppliers and other business partners. We establish a
relationship of trust and integrity with all our suppliers, which is built on mutually beneficial factors.
The use of service provider contractors in our organisation is largely within our facilities support area
but not limited to this part of our business.

Due Diligence

Stephen James (Automotive) Ltd continues to take its responsibilities seriously and build upon the
actions already in place to assist in the identification and mitigation of the risk of Modern Slavery.

Our Approach:

Whilst ultimately the majority of risks within the business rest with our manufacturers and suppliers
we are not complacent and will continue as a Company to seek to identify and manage any potential
risks associated with Modern Slavery. We have endeavoured to put safeguards in place to ensure, so
far as is reasonably practicable, that the working practices of those employed directly by us and
those with whom we have a direct contractual arrangement with also have a similar zero tolerance
to Modern Slavery.

We are fully committed to consolidate this work in all that we do. We shall continue our efforts in
identifying and addressing any form of slavery that could exist within our businesses at Stephen
James and within our supply chain.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes
Stephen James (Automotive) Ltd.’s Modern Slavery statement for the financial year ending 31
December 2018.

Stephen James (Automotive) Ltd

Richard Ennis
Managing Director