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Modern Slavery Statement

Modern Slavery Statement

1. Statement

1.1 This statement sets out The CitNOW Group’s actions to understand all potential modern slavery risks related to the business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in the business and its supply chains.

1.2 CitNOW is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.

1.3 As an equal opportunities employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves. 1.4 Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

1.5 We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

2. Organisational Structure

2.1 We are a Software and Technology Development company. Our Applications are for the automotive industry to make videos and gather images of vehicles for their customers, the motorist. Our people and customers are at the forefront of our business, therefore their wellbeing is fundamental when creating our
business processes.

2.2 CitNOW has a global workforce operating over offices in 8 countries including UK, France, Portugal, Spain, Germany, Italy, Denmark and the USA. We also have a Reseller network in further markets, and engage with third parties to support us in our business offerings to customers.

3. Our Business

3.1 CitNOW Group operates through the following divisions:

3.1.1 Zype TV Ltd (t/a CitNOW) – Development of our Applications and software to the automotive industry.

3.1.2 Eight Technology Ltd (t/a Dealerweb) – creation of automotive sales and lead management systems.

3.1.3 Zype TV Ltd (t/a Tootle) – our part exchange solution.

3.1.4 Reef Business Systems Ltd (t/a Reef) – creation of automotive sales and lead management systems.

4. Employment Procedures

4.1 CitNOW operates a robust Recruitment & Selection Policy and Procedure in line with (UK) employment law (as applicable), including “right to work” document checks, reference checks, contracts of employment, and checks to ensure all employees are above minimum working age (16).

4.2 The business carries out annual reviews relating to market-related pay and reward, this is linked to industry benchmarking.

5. Listening to our People

5.1 We seek feedback from employees through our platform Suggestion Ox where they can submit concerns, questions or ideas anonymously. This platform is available to all employees and is encouraged from the Management Board. Employees are able to submit responses relating to making CitNOW a better place to work, raising any concerns they may have or a question to our Management Board. All responses are submitted to the Management Board on a monthly basis and are reviewed at the monthly Management Board Meeting. All questions are answered during the monthly company webinar.

5.2 We have an annual Employee Engagement Survey which is open to all CitNOW employees, giving them a further platform to be heard by the business anonymously. In 2021, 85% of our global workforce completed the survey. The results from the survey help managers and the HR team identify behaviours and practices that could lead to a failure of ethics, controls or governance before they occur. This confidential feedback would also allow potential instances of exploitation in any form to be raised and investigated.

6. Our policies

6.1 We operate a number of internal policies and procedures to ensure that we are conducting our business in an ethical and transparent manner. These include:

  • Consultant Code of conduct – a document that all consultants would sign and agree to before providing any services relating to behaving in a professional manner and complying with CitNOW rules and policies
  • Health & Safety Policy – our policy that ensures that all activities and work will be carried out in a safe manner and we will ensure the health, safety and welfare of our employees and others who may be affected by our activities.
  • Environmental Policy – our policy which sets out what we do as a company to be environmentally aware, and any steps we wish to take in the future on how to better our business operations when it comes to environmental factors.
  • Recruitment & Selection Policy – a robust policy, including conducting eligibility to work in the UK, checks for all employees to safeguard against human trafficking to individuals being forced to work against their will.
  • Supplier Due Diligence Questionnaires – An annual questionnaire that we send out to our third party suppliers. The responses are then checked by a member of our Management Board and if deemed satisfactory we continue to work with the supplier.
  • Reseller Agreements – Our existing Resellers are recommended parties whose business practices have been reviewed and approved by our Executive Management Team. Before entering a new market and assigning a Reseller we will complete an assessment covering:
    • Is the market an existing or recent conflict zone;
    • Does market research indicate it at high risk for ecountering incidences of modern slavery;
    • Can a prospective Reseller provide assurances their business does not knowingly support or has found to be involved in slavery, servitude and forced or compulsory labour;
    • The Reseller Agreement or addendum to an existing contract states that the Reseller agrees to adhere to the principals of the UK Modern Slavery Act 2015 and will make every effort not to be involved with modern slavery or human trafficking.

7. Our Supply Chain

7.1 Due to our business offerings, we create and manage our product and software offerings in house, however our suppliers supply us with indirect offerings, such as communication services and data warehouses. Our supply chains are based throughout the world and we conduct due diligence checks on all of our suppliers. The due diligence checks include checks of their security, technical and organisational measures as well as regulatory checks to ensure
they are compliant with laws and regulations, including the Modern Slavery Act 2015.

7.2 Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chains.

7.3 When considering moving into a new territory or geographical area, a checklist process is adopted by the relevant departments to assess whether the area would be high risk. CitNOW would not operate in a country or territory where Human Trafficking or Slavery was highly probable or there was currently
any conflict.

7.4 We currently operate in the following countries:

Country Legal Entity Employees Contractor* Reseller**
United Kingdom Yes Yes Yes No
Netherlands Yes Yes Yes No
France Yes Yes No No
Spain Yes Yes No No
Portugal No Yes No No
Italy Yes Yes No No
Denmark Yes Yes No No
Sweden No No Yes No
USA Yes No Yes No
Canada Yes No Yes No
Germany Yes Yes No No
India No No No Yes
South Africa No No No Yes
Ireland No Yes No Yes
UAE No No No Yes
China No No No Yes
Malaysia No No No Yes

* This is a Full Time Contractor in the market that manages the local customer base
** A Reseller is based in a local market and is responsible for the customer base in that market but they are not directly employed by CitNOW

8. Embedding the principles

8.1 We will continue to embed the principles throughout this financial year by:

  • advising staff on the Modern Slavery Act 2015 through an Internal Modern Slavery Policy of which all staff must read and accept.
  • ensuring that consideration of the modern slavery risks and prevention are added to CitNOW’s policy review process as an employer and procurer of goods and services.
  • making sure CitNOW’s strategies and contract terms and conditions are aligned with and enforce the act.
  • continuing to take action to embed a zero tolerance policy towards
    modern slavery and human trafficking.
  • implementing a formal Whistleblowing Policy, outlining Suggestion Ox and other means in which staff can raise any concerns.
  • creating a Supplier Code of Conduct, of which we ask all suppliers to sign up to after their responses to the Due Diligence Checks have been deemed satisfactory.

8.2 Our Management Board is responsible for the compliance and implementation of this Statement. This Statement will be reviewed on a 6 monthly basis. At the end of the financial year, a new Statement will be published.


Date of Publication: 14th September 2021