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Modern Slavery Statement
Creative Car Park Limited Modern Slavery Policy Statement – October 2025
This statement by Creative Car Park Limited constitutes the Company’s modern slavery and human trafficking statement for the financial year ending on 31 March 2025 and is made pursuant to s54(1) of the Modern Slavery Act 2015.
Our Commitment
We will not tolerate slavery and human trafficking within our business and supply chain. We are committed to acting responsibly in business relationships and ensuring that slavery and human trafficking does not occur anywhere in our business operations and have published a Modern Slavery Policy as part of our staff handbook policies and procedures. We will also require our suppliers and business partners to take the necessary steps to avoid and/or tackle slavery and human trafficking.
We will continue to enforce the Company’s policies, processes and procedures throughout the coming year in support of our commitment.
Structure, Business and Supply Chain
We are a Private Car Park Management Company. We manage private car parks and other parking areas on behalf of our clients, who are landowners, tenants or otherwise occupants or residents of premises with adjacent car parks. Our associated group company, Civil Enforcement Limited, undertakes enforcement of the terms and conditions of parking at these car park premises and is responsible for the issuing of Parking Charges to the registered keepers of vehicles that have breached the terms of parking, and the associated recovery of the sums due under those notices.
Our business focuses on providing bespoke car park management solutions and services to clients in the UK only. The Company operates a UK operations centre which includes a call centre operation for sales and client liaison and a separate operations team for the motorist facing side of the business, including customer service, appeals and complaints handling function, and has outsourced arrangements for certain technical processes to supplement these operations.
We support, and are committed to, the welfare of all our employees in terms of pay, working hours, environment, health and safety, and wellbeing. We do not expect, and will not tolerate, violations of basic human rights or UK employment practices by any member of staff or within our supply chain. Our employees are engaged on a variety of full-time and part-time working arrangements and are appropriately remunerated and incentivised; the Company does not operate zero-hour contracts. Contractors are also employed by the Company from time to time who are mainly based in the UK and are attached to or employed by regulated and professional organisations.
Creative’s primary suppliers are manufacturers and providers of car parking equipment, telecommunications and payment services providers and third-party debt recovery companies. These suppliers are based in the UK and subject to the Modern Slavery legislation.
Creative’s external supply relationships include companies based outside the UK but these entities are subject to contractual obligations in respect of modern slavery and human trafficking.
Policies in Relation to Slavery and Human Trafficking
The Company has a responsibility to conduct its business in an ethical and transparent way. Accordingly, we adhere to a set of business principles which include a commitment to human rights and employment legislation principles. Policies and procedures underpin the Company’s overall control and governance structure, as well as supporting our employee culture, including policies covering conduct, whistleblowing, recruitment, anti-bullying and harassment, health and safety, anti-bribery and corruption, diversity and equality, compassionate leave, disciplinary, and religious observation and holidays. These policies, which are set out in our Staff Handbook and provided to all employees at induction, are reviewed and updated as appropriate by our Directors and management team in line with changes to best practice and/or legislation and as guided by the Head of Human Resources and Legal Counsel.
In addition to the Chief Executive Officer, the Company employs a senior executive management team to support and guide its critical business and compliance functions, including a Chief Financial Officer, Director of Technology, Client Services Director, Sales Director, Head of Human Resources and Legal Counsel. Together they collaborate to attract the best suppliers and secure best value from them, to manage contractual, commercial and regulatory risks, and to ensure that relevant regulatory and legal obligations are met, subject to regular Board level oversight on a monthly or, when required urgently, an ad hoc basis.
The Company’s policies and frameworks reflect our commitment to minimise the risk of modern slavery or human trafficking occurring anywhere in our business operations.
Due Diligence Processes, Risk Assessment and Management
We include appropriate measures in our due diligence processes to engage suppliers and business partners on a risk assessed basis. As part of the procurement and supplier performance management policy we ensure that all our suppliers undergo a due diligence process before engagement and continued oversight and performance management during that engagement. Compliance with human rights, fair treatment and reasonable remuneration for employees as well as safe working conditions are all reviewed.
As part of the pre-employment and recruitment process for our employees, we ensure that all employees are legally permitted to work within the UK and that they are joining us of their own free will and are not coerced to join us. The company is regulated by the British Parking Association and the DVLA (a Government body), and background and financial checks are undertaken on all of our employees as required by contract. We also require our suppliers to operate in a similar manner, where it is appropriate in context of the services they provide to the Company. A new Statutory Parking Code and UKAS led Conformity Assessment Scheme (CAS) will impose additional formal regulation of the industry, in particular private Car Park Operators, and this is expected to come into force in 2026. Further training will take place once the Code is finalised and the CAS has been brought into effect.
Training
We maintain a training program to raise awareness of conduct, human rights and diversity and inclusion amongst our employees through management or external expert led face-to-face sessions and via online training platforms, and to give staff the ability to recognise potential instances of modern slavery and other abuses. We have, since the last review, implemented and conducted a comprehensive staff training program on anti-bribery and corruption, Equality Act and discrimination and reasonable adjustments for those with protected characteristics.
We also ensure all our employees are aware of our whistleblowing policy, via an induction training course and familiarisation with the employee handbook. Employees are advised how to report potential or actual incidents. We encourage employees to report all potential or actual incidents that relate to wrongdoing or actual or suspected illegal or serious inappropriate activity, whether related to modern slavery or not. A confidential reporting system through the HR Director is provided for employees to report their concerns confidentially.
Effectiveness
We monitor for any incidents of actual or suspected illegal or serious inappropriate activity.
During the last financial year ended there were no incidents relating to modern slavery or violations of human rights identified and no incidents were reported by employees, whether internally via management, or via the whistleblowing portal. There were also no incidents reported relating to our supply chain, either by internal supplier relationship managers or our suppliers themselves.
This statement has been approved by the Creative Car Park Board.
October 2025