MTR Group Ltd

Modern Slavery Act 2015

Modern Slavery and Human Trafficking Statement for the Year Ended 31 March 2019

1. Our Policy

MTR Group Ltd (MTR) is opposed to slavery and human trafficking in any part of our activities or our supply chains. We are therefore committed to ensuring that we have adequate policies and procedures in place to identify and prevent these practices.

2. Our Business

The principal activities of MTR are the repair of consumer electronics and the retail sale of mobile phones and other electrical devices.

We are a part of the DCC Group. DCC is a leading international sales, marketing and support services group with a clear focus on performance and growth. Its headquarters are in Dublin Ireland. It is listed on the London Stock Exchange and is a constituent of the FTSE 100 Index.

DCC currently has operations in 18 countries and employs over 12,000 people. Additional information on DCCis available at www.dcc.ie.

3. Our Structure

Our business distributes through various channels shown. We distribute second hand mobile phones, tablets, laptops and other accessories and also provide specialist supply chain services and logistics to customers across the consumer, B2B and enterprise markets from the world’s leading brands.

4. Our Supply Chains

The majority of the products we sell are sourced from reputable suppliers who are based in the UK and the European Union. We also source a number of products from China, Hong Kong, and the United States.

The following table contains a summary of the activities that we consider present the highest risk of slavery and human trafficking in the industries in which we operate, with, in each case, a summary of the steps we have in place to avoid these affecting our activities or our supply chains.

Industry Risk Steps Taken
Conditions and treatment of workers in third party factories that supply MTR and its suppliers with technology products located in higher risk countries for slavery and poor working conditions and/or limited legal protections. Factory audits undertaken by our Quality team include an extensive range of questions designed to identify actual or potential violations of workers’ rights, human rights and local laws, including assessing the potential for modern slavery and people trafficking.

Any factory not meeting the standards set out in our policies and procedures in this area (see further sections 5 and 6 below) automatically fail the audit.

Wherever possible corrective actions will be agreed immediately with the factory to resolve the identified issues.

Where this is not possible we will not purchase products from the factory.


5. Our Policies on Slavery and Human Trafficking


The DCC Code of Conduct sets out our Group’s commitment to acting ethically and with integrity towards our employees and in all our business relationships. Specifically, section 2 of the Code sets out our commitment to fair employment practices and section 14 of the Code sets out our commitment to preventing, as far as practicable, slavery and human trafficking in our supply chains.

In addition, the DCC Group Supply Chain Integrity Policy sets out the approach taken by every business in the DCC Group to ensuring that all the products we sell meet applicable legal and ethical standards.

Both documents are available at http://www.dcc.ie/responsibility/our-policies.

Our policy on slavery and human trafficking is set out in section 1 of this statement.

6. Procedures on Slavery and Human Trafficking

As part of our compliance with the policies referred to above we take the following steps:

  • Assess potential risk areas in our supply chains;
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains, including by reviewing, where necessary, the controls that our suppliers have in place and carrying out other suitable checks;
  • Monitor potential risk areas in our supply chains on a periodic basis; and
  • Monitor and assess external recruitment services providers to mitigate the risk of slavery and human trafficking occurring (inclusive of the mitigations laid out above within our supply chain)

7. Assurance and Key Performance Indicators

Responsibility for ensuring that our procedures are adequate and are adhered to in all areas of our activities rests with the directors of MTR.

We report on compliance with the DCC Group Code of Conduct and Supply Chain Integrity Policy every six months.

8. Training and Awareness

We provide training to relevant employees on supply chain risks, including the risk of slavery and human trafficking at suitable intervals. Our participation in industry associations and our dealings with suppliers also provide information on where slavery and human trafficking risks may arise in the industries where we are active and best practice in avoiding them.

9. Nature of this Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ended 31 March 2019.

This statement has been approved by the directors of MTR. Ltd.

James Goddard
MTR Group Ltd
1 September 2019