Slavery & Human Trafficking Statement


C.Walton Limited (CWL) is a company providing the automotive industry with vehicle inspection, repair and refurbishment services. With a dedicated vehicle preparation facility at Bruntingthorpe Proving Ground, Leicestershire, and satellite sites at Long Bennington and Wyton, we are equipped with modern vehicle preparation, repair and painting, storage and office facilities. CWL has the most technically advanced vehicle repair and pre-delivery inspection centre in the UK.

CWL strives to be an ethical organisation and act with integrity in all activities, with the utmost respect for Human Rights and the global community, in which we seek to be a positive contributor.

We take a zero-tolerance stance on Modern Slavery and Human Trafficking in all its forms. As detailed in our ‘Human Rights & Modern Slavery Policy’, we seek to ensure no instances occur across our business or within our supply chain.

Any suspected instances of a breach to this policy will be dealt with strongly on a case by case basis, with full investigation and, where found proven, remedial action will be taken, potentially including dismissal and/or contract cancellation.


CWL understands its business context, its stakeholders and the associated sources of risk, in relation to the potential for human rights infringements within its sphere of operations. The organisation understands its market and responsibilities:

The business operates a risk-based management approach in line with its ISO 9001 Certification, specifically in this context in recruitment and procurement activities.

  • Outsourcing to specialist service providers, building close relationships with these, the majority who are integrated on-site, with facilities and joint operations;
  • Significant labour requirements for skilled workers with broad, specialist technical skills and resourcing to create a strong, diverse workforce, through responsible recruitment practises;
  • Contracted labour supplements our workforce, enabling flexibility for our service providers, by utilising assured and regulated intermediaries;
  • Global parts sourcing requires a far-reaching multi-tiered international supply chain, guaranteed by working closely with international brands with the highest standards.


The business operates a risk-based management approach in line with its ISO 9001 Certification, specifically in this context in recruitment and procurement activities.

Therefore, CWL are mindful of good practice in its procedures and practises to avoid making demands on staff, suppliers or subcontractors that might drive behaviours which could lead to human rights violations, for example:

  • Clearly communicating our expected standards of management, staff and suppliers;
  • Avoidance of insufficient or late payment, high pressure deadlines as a result of poor demand forecasting;
  • Mindfulness of seeking low cost, quick turnaround products and services;
  • Consideration of Service Level Agreements (SLAs), performance management metrics or Key Performance Indicators (KPIs) creating supply chain vulnerabilities;
  • Sourcing a wide supply base – to ensure security of multiple sources of ethical supply.


At our core is a policy framework based on fundamental principles and ethical standards. These underpin our Company Management System (CMS), which provides strong governance and robust process, with integrated safeguards to ensure our business respects the rights of all parties.

These values are ingrained across an array of procedures and activities:

  • Human Rights & Modern Slavery Policy – outlining our strong ethical stance;
  • Recruitment & Selection and Equality & Diversity employment policies – focused on our people, business needs and ensuring compliance to legislation;
  • Procurement & Vendor Control Procedure – identifying the correct businesses to work with through detailed assessment, ensuring appropriate due diligence is undertaken. This may include the utilisation of Supplier assessment forms, specifically requiring declaration of compliance with legislation and adoption of ethical business practises. Vendor assessment and monitoring levels are commensurate with the evaluated potential risk;
  • Supplier contracts – providing clear terms on acceptable practises, required standards, performance levels and likely actions in the event of breaches;
  • Supplier performance monitoring and audits – ensuring ongoing vigilance of existing suppliers to ensure standards are maintained;
  • Periodic policy and documentation review - to ensure these remain accurate, reflect best practice and implement any improvements;
  • Induction Process – raising awareness with all new staff;
  • Training for all – awareness training to all employees and role specific training for managers, HR and Procurement specialists;
  • Supplier engagement and on-site service provider integration – suppliers are co-located within the business site, enabling collaborative working;
  • Third party, regular, independent Health and Safety and ISO9001 audits of our facilities and Quality Management Systems - through a specialist consultancy;
  • Certification to ISO9001 – ensuring appropriate processes are in place and adhered to;
  • Business context documentation – enabling CWL to understand its market, opportunities, risks and strategic position;
  • Business stakeholder mapping – to ensure we understand the interests of all parties around us;
  • Regular Management Review of the Quality Management System, operational performance and Health and Safety provision – Senior Management regularly scrutinising all aspects of the business;
  • Communications activities - making policies clear and accessible to staff and interested parties through our Intranet Web Portal and website.


There are plans to strengthen and continually improve the business’ position, to increase its capability and maturity in this area.

The following are envisaged:

  • Supply chain ethics policy / code of conduct;
  • Supplier assessment questionnaire – to expand the detail and scope of investigation into the provision of Modern Slavery protection measures;
  • Supplier audit activity – enhancement to cover onsite supplier staff welfare, including working conditions, Health and Safety provision, employment contract terms etc;
  • Risk identification and management - ongoing evaluation of specific Modern Slavery, Trafficking and Human rights potential risks and suitable mitigation actions;
  • Extended supply chain review – working with suppliers to ensure the subsequent supplier tier below them in the chain has robust policies and practices;
  • Whistle blowing facility to report suspected breaches in policy;
  • Communications – ongoing communication to all staff and suppliers of human rights responsibility and their roles within this;
  • Supplier engagement programme – to build stronger, long term relationships, offer more guidance and support initiatives to enhance worker conditions, reward commitment and providing investment for long-term continual improvement


Bruntingthorpe in Leicestershire is the home of Cox Automotive Vehicle Solutions, Manheim Vehicle Services, Manheim Auction Services and Bruntingthorpe Proving Ground. Situated within a 670-acre site, Cox Automotive customers and vehicle manufacturers, finance companies and dealers can access the extensive proving ground facilities at Bruntingthorpe which range from vehicle testing through to vehicle launches, media events and dealer training.

ISO 9001 Certified (BIAS)