Slavery and Human Trafficking Statement for the 2022 Financial Year

This statement is made on behalf of Cazoo Ltd and the following companies in its group: Cazoo Subscription Services Limited, Cazoo Wholesale Services Limited, Cazoo Data Services Limited, Cazoo Properties Limited, SMH Fleet Solutions Limited and CD Auction Group Limited (“Cazoo”, “we”, “us”, “our”)*.

Cazoo does not tolerate slavery or human trafficking and seeks to uphold the highest ethical standards in its business. 

This statement describes the steps we have taken during the year to ensure that slavery and human trafficking is not taking place in any of our supply chains or in any part of our business. We have published this statement in accordance with section 54 of the Modern Slavery Act 2015 (the “Act”).

Cazoo’s structure, business and supply chains

Our mission is to transform the car buying and selling experience across the UK by providing better selection, transparency, convenience and peace of mind. Our aim is to make buying or selling a car no different from ordering any other product online, where consumers can simply and seamlessly buy, sell and finance a car entirely online for delivery or collection.

Our supply chain includes:

  • People: recruitment, agency and training services

  • Technology: providers of computer hardware and software services

  • Data: industry and vehicle data licensors

  • Professional services: accountancy, tax, legal and other similar services

  • Advertising and marketing: online and above-the-line marketing services

  • Refurbishment: services to maintain and refurbishment our cars for sale

  • Facilities: services to maintain, repair and fit out our sites

Cazoo’s policies and procedures

We consider that we have a responsibility to uphold the highest ethical standards in the way we work. This is why the wellbeing of our customers, our team and the communities we serve is our priority.

Cazoo has implemented policies and procedures designed to combat slavery and human trafficking in its supply chains and its business generally. These policies are regularly reviewed. They include the group’s Procurement Policy and the group’s Code of Business Conduct and Ethics.

Our Procurement Policy is designed to ensure fair competition between prospective suppliers to Cazoo and to ensure that those suppliers are objectively assessed before being appointed, including by reference to the measures they take to eliminate slavery and human trafficking.

Our Code of Business Conduct and Ethics is intended to deter supplier wrongdoing and to promote high standards of integrity in all of Cazoo’s business. Our policies also require suppliers to pay at least minimum wage to their workers.

Cazoo’s due diligence and contracting processes

We require all suppliers that we appoint to complete our supplier due diligence process, which includes questions designed to identify slavery and human trafficking risks.

Our due diligence questionnaire explains to suppliers the behaviours and ethical standards that we expect of them. We require our suppliers to confirm their compliance with legislation, including the Act, and to declare any breaches at the due diligence stage.

Cazoo considers carefully the responses provided by suppliers to the due diligence questionnaire and will take action where issues are identified. Cazoo may refuse to onboard a supplier if its due diligence responses are unsatisfactory.

Cazoo’s standard contractual terms for suppliers require supplier to comply with the Act. Where Cazoo engages with a supplier using other terms, Cazoo seeks equivalent contractual assurances.

Key risk areas

Our supply chain is complex and varied, but we’ve identified the following priority areas where the risk of slavery and human trafficking is greatest. Suppliers in these areas are subject to enhanced due diligence review to ensure full compliance.

These areas are:

  • Facilities fit-out, maintenance and management

  • Vehicle refurbishment services supplied to our production centres

  • Staffing and recruitment agencies

  • Consultancy and freelancers

Cazoo conducts regular business reviews with key suppliers, and uses these reviews to escalate any issues of concern identified.

Analysing the effectiveness of our measures

We carry out proportionate checks on our suppliers to identify whether slavery or human trafficking exists in our supply chain. To date, we have not identified any non-compliance, but we have plans in place to escalate, investigate and take action in future if any issues are identified.

Any risks identified in these areas can be escalated to directors and, if appropriate, to the Environmental, Social and Corporate Governance Committee of the Cazoo Group Limited board.

Training and whistleblowing

Cazoo employs people in many locations across the UK. Members of the procurement team are trained to identify risks relating to slavery and human trafficking through Cazoo’s due diligence processes.

Cazoo has an established confidential, independent whistleblowing helpline to enable staff to report suspected malpractice (including in relation to slavery and human trafficking). Cazoo has a Whistleblower Protection Policy to ensure that staff raising legitimate concerns can do so without fear of adverse consequences. We also have an internal investigation policy and reporting process for reporting anything else of concern.


This statement is made under section 54(1) of the Modern Slavery Act 2015 and is the group’s slavery and human trafficking statement for the financial year ending 31 December 2022. It was approved by the board of Cazoo Ltd on 18 May 2023.

Alex Chesterman OBE
Director, Cazoo LTD
18 May 2023

*Cazoo Ltd falls within the scope of section 54(2) of the Act. Other named companies make this statement voluntarily.