Modern Slavery Statement

IMO Car Wash Group Limited

Modern Slavery and Human Traﬃcking Statement

IMO structure and business

We are a developer and operator of car wash sites.

The IMO Car Wash group of companies is owned by Driven Brands and became part of the Driven Brands group

of companies in August 2020. Driven Brands, a publicly trading US organisation that encompasses more than

5,200 locations across 13 countries and approximately $6.5 billion in annual system-wide sales is the largest

automotive aftermarket services company by location count in North America.

The Car Wash division now represents one of four aftercare segments within Driven Brands. In 2024 it washed

more than 25 million cars a year through a network of more than 700 locations across Car Wash International,

making it the world’s largest local car wash conglomerate during 2024. Car Wash International is responsible

for all Car Wash sites outside the US, covering 12 countries across Europe and Australia. In the United Kingdom,

our car wash sites are operated by independent operators under contract with one of our subsidiaries, Anduﬀ

Car Wash Ltd, under the IMO car wash brand. Our business is organised into 243 operating sites across the

United Kingdom.

The senior management team of IMO Car Wash Group Ltd through 2024 comprised Tracy Gehlan (then the

President, International), Adam Green (who served in the early part of 2024 as the Managing Director for the

UK business, and then the Chief Operating Oﬃcer), and Jonathan Fitzpatrick and Scott O’Melia as directors.

Between the end of 2024 and the issue of this Statement the senior management team has changed. Tracy

Gehlan has resigned, and Adam Green is now the President. The Managing Director of Anduﬀ Car Wash Ltd

and the UK business is Nazim Ilyas. Jonathan Fitzpatrick has been replaced as a director by Michael Diamond.

Our supply chains

Our supply chains include chemical and equipment suppliers, maintenance contractors, brush manufacturers

and self-employed car wash operators.

We expect organisations and individuals from whom we procure products and services and other companies

we engage with to ensure their goods, materials and labour related supply chains to be fully compliant with the

Modern Slavery Act 2015 and free from ethical ambiguities.

Individuals with evidence of non-compliance with the Modern Slavery Act in connection with our supply chains

are encouraged to follow the reporting procedure outlined in our Whistleblowing Policy.

Our policy on slavery and human traﬃcking

We are committed to ensuring that there is no modern slavery or human traﬃcking in our supply chains or in

any part of our business. Our Anti-slavery and Human Traﬃcking Policy reflects our commitment to acting

ethically and with integrity in all our business relationships and to implementing and enforcing eﬀective systems

and controls to ensure slavery and human traﬃcking is not taking place anywhere in our supply chains. The

policy is available internally at all times to all employees, and can be provided externally on request.

1Due diligence processes for slavery and human traﬃcking

The Board is responsible for reviewing potential risks where Modern Slavery could occur within our business.

Having risk assessed our business, the Board has identified that there is low risk of Modern Slavery within the

IMO business itself. We have identified that many non-EU nationals work in the car wash industry generally

and that there is therefore potential for human traﬃcking and/or forced labour at car wash sites. Our car wash

sites are operated independently by self-employed operators. We believe that our sites have a notably lower

risk than hand car wash operations because the level of manual labour involved at our car wash sites is far

lower than at hand car wash sites. However, we recognise that that risk may still exist within the operation of

our car wash sites. The self-employed operators of our car wash sites engage staﬀ directly and IMO has no

direct oversight or control over the employment practices of those operators. We have ensured that our

contracts with operators require them to comply with the Modern Slavery Act 2015 and we have the right to

terminate our contract with the operator if they fail to comply. We do operate robust compliance checking on

our operators, and our own employees regularly visit our sites and would have visibility of any poor or unsafe

working conditions, as well as any sign of employees living at any of our sites.

Our Whistleblowing Policy also encourages reporting of any concerns and commits to protect employees from

any retaliation for reporting a concern in good faith, even if that concern is eventually shown to be unjustified.

We will continue to monitor potential risk areas in our supply chains.

All of our employees receive the statutory employment rights to which they are entitled and we verify that all

of our employees have the legal right to work in the UK. Our employees are provided with safe working

conditions and we have the expectation that they will be treated at all times with dignity and respect.

Our eﬀectiveness in combating slavery and human traﬃcking

We have:

• Agreed responsibilities for the Anti-Slavery and Human Traﬃcking Policy and this statement and

received unanimous support from our Senior Management Team;

• Raised awareness to key members of staﬀ who regularly interact with our supply chain and contractors;

and

• Incorporated the Anti-Slavery and Human Traﬃcking Policy in our standard set of Company policies

and as part of our induction programme for all new employees.

We have the following policies in place for employees:

• Code of Conduct and Ethics

• Anti-Slavery and Human Traﬃcking Policy

• Equal Opportunity Policy

• Grievance Policy

• Whistleblowing Policy

Employees are reminded of the policies from time to time and notified of any updates.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the anti-

slavery and human trafficking statement of IMO Car Wash Group Ltd and its UK subsidiaries for the financial

year ending 31 December 2024. The Board of IMO Car Wash Group Ltd approved this statement in June 2025.

Scott O’Melia

On behalf of IMO Car Wash Group Limited

Scott O'Melia
Director
On behalf of IMO Car Wash Group Limited

Date: 30 June 2025