Modern Slavery Statement


This Slavery and Human Trafficking Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 relating to Transparency in Supply Chains. This statement sets out the steps Sapphire Vehicle Services Limited and Sapphire Fleet Management have continued to take to address the risk of slavery and human trafficking within its operations and supply chain.

Organisational Structure

Sapphire Vehicles Services Limited is a commercial vehicle fleet management company currently operating 15 depots throughout the United Kingdom, Sapphire supports customers from a variety of industry’s with the day to day running of their commercial vehicles. Key operations include fleet management, vehicle leasing, commercial vehicle workshop services and roadside assistance.

Sapphire Fleet Management started 1st April 2021 and will offer state of the art Fleet Management options countrywide.

The business units operates autonomously drawing on support centrally from parent company Ballyvesey Holdings Limited in respect of health and safety, the environment, legal counsel, human resources, property, IT, insurance and finance.

Countries of Operation and Supply

Sapphire Vehicle Services and Sapphire Fleet Management operate in the United Kingdom.

Sapphire Vehicle Services Limited and Sapphire Fleet Management remain committed to review and evaluate our supply chains to identify human trafficking risks and slavery risks and we continue to review all aspects of the supply chain function with zero tolerance for non-compliance.

Sapphire’ primary supply chain includes:

  • Commercial vehicle manufacturers and parts suppliers
  • Commercial vehicle parts and equipment suppliers
  • Manufacturers of goods and materials

The procurement of services and supplies is undertaken professionally by supply chain and or procurement specialists within the central supply chain function or within the business unit.  It is our intention to maintain long term relationships with customers and suppliers and we actively encourage collaborative working and good industry practice.

As a business we continue to support the Stronger Together Programme, and fully endorse the work being done to reduce forced labour and human trafficking in the United Kingdom and across the world. 


Responsibility for the organisation’s anti-slavery and human trafficking initiatives is as follows:

  • Policies:                               Human Resources
  • Risk assessments:            Procurement & Group H&S Management Team
  • Investigations:                  Group Finance & HR/Compliance
  • Training:                              Procurement & Human Resources

Relevant policies

Sapphire Vehicle Services Limited and Sapphire Fleet Management are committed to ensuring there is no modern slavery or human trafficking in its supply chain or in any part of its business with a zero tolerance for non-compliance.

This statement reflects that commitment to acting ethically in all business units and to establishing an effective system to ensure slavery and human trafficking is not present in the supply chain. Sapphire Vehicle Services Limited operates under a number of policies, which underpin our ethical approach to business:

  • Whistleblowing policy – Sapphire Vehicle Services and Sapphire Fleet Management encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact James Darragh BVH Group Director on 02890 849321.
  • Employee code of conduct – Sapphire’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Supplier code of conduct – Sapphire is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.
  • Recruitment policy – Sapphire uses only specified, reputable employment agencies to source labour and where not possible seeks to verify the practices of any new agency it is using before accepting workers from that agency. 


Sapphire Vehicle Services Limited and Sapphire Fleet Management assesses compliance in its existing supply chain and will continue to undertake due diligence when considering taking on new suppliers to include:

  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
  • evaluating the modern slavery and human trafficking risks of each new supplier
  • reviewing on a regular basis all aspects of the supply chain based on supply chain mapping
  • conducting supplier audits or assessments which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers  and requiring them to implement action plans;
  • participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular as evidenced by our participation in “Stronger Together” initiatives;
  • Invoking sanctions against suppliers who fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship;

Performance indicators

During 2021 there were no reported incidents or investigations associated with modern slavery and or human trafficking in Sapphire Vehicle Services Limited. The organisation continues to review its key performance indicators around modern slavery and human trafficking and as a result we will continue to:

  • require all staff working in procurement and HR to have completed training on modern slavery;
  • develop a system for supply chain verification prior to supplier on boarding; and
  • review existing supply chains

Recruitment & Training

Sapphire Vehicle Services Limited and Sapphire Fleet Management undertake selective pre-employment screening, references, conducts identity checks and confirmation of entitlement to work in the United Kingdom on all employees prior to commencement of employment. These measures have extended into 2021 and have been heighted by the United Kingdom’s departure from the EU.

New employees are given an overview of the essential policies and information in relation to Sapphire Vehicle Services Limited and Sapphire Fleet Management policies, procedures and other matters such as whistle blowing, dignity at work, and equality. Looking ahead into 2022 and 2023 the introduction of a centralised H&S and HR online training portal and employee engagement platform will heighten levels of awareness, information and communication.  Part of this exercise we see the development of a centralised dashboard to provide uniformity and heightened visibility to management teams around employee training. For all employees the ongoing process of training and communication around modern slavery and human trafficking with continue unabated utilising the very effective resources provided by Stronger Together across all media formats. 

Awareness-raising programme

As well as training specific staff, the organisation has raised awareness of modern slavery issues by utilising the Stronger Together portfolio of multimedia resources to communicate, to highlight, to inform, to advise and to support, focusing on the key aspects of:

  • the basic principles of the Modern Slavery Act 2015;
  • how employers and employees can identify and prevent slavery and human trafficking;
  • what we all can do to highlight slavery or human trafficking issues to the relevant parties within the organisation and beyond;

Board approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015, for the financial year ending 30 September 2020. It applies to Sapphire Vehicle Services Limited and Sapphire Fleet Management has been approved by the Board of Directors.

Signed by:           Perry Reeves

Managing Director

Date 26 March 2021