Otto Car - Modern Slavery Policy

Organisation

This statement applies to Otto Car Ltd (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2025/2026.

Organisational Structure

Otto Car Ltd operates as a single centralised organisation based in the United Kingdom, with offices spread between London, Birmingham and Manchester.

The Organisation’s primary activity is offering car leasing and financing options tailored to professional drivers. All operations are conducted within the United Kingdom, and there are no overseas offices.

Definitions

The Organisation considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or having restrictions placed on freedom of movement.

Commitment

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude, and forced or compulsory labour. No labour is provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.

Supply Chain

In order to fulfil its activities, the Organisation’s main supply chains include those related to the sourcing of automotive vehicles and the service and maintenance of such vehicles from trusted suppliers based in the United Kingdom, as well as the use of contractors to assist in the daily running of the organisation based in India.

Steps

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including:

• Reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery;
• Implementing measures to identify and assess the potential risks in its supply chains;
• Conducting impact assessments of its operations on potential instances of slavery;
• Creating action plans to address risks related to modern slavery;
• Embedding a zero-tolerance policy towards modern slavery in all aspects of its operations.

Embedding the Principles

We will continue to embed the principles through:

• Offering training to employees on the Modern Slavery Act 2015, including guidance on how to respond if they suspect instances of slavery or human trafficking.
• Ensuring team members involved in procurement activities are familiar with and adhere to the modern slavery procurement guidance available on GOV.UK.
• Integrating modern slavery risk assessments and prevention strategies into Otto Car’s policy review process as part of our responsibilities as an employer and buyer of goods and services.
• Incorporating references to modern slavery and human trafficking into Otto Car’s procurement strategies, as well as contract terms and conditions.
• Reinforcing a zero-tolerance stance on modern slavery through consistent and meaningful action.
• Providing training to employees responsible for procurement, recruitment, or workforce management on modern slavery and ethical employment practices.

This statement has been approved by Gurinder Dhillon, Managing Director, for the financial year ending 31 March 2026. This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.