1.1 This statement sets out West Bromwich Building Society's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in either its own business or the supply chains it uses. As a Financial Services firm the Society is not part of a supply chain, however in delivering its services, the Society procures goods and services from suppliers who do operate supply chains, some of which are global.
1.2 This statement relates to actions and activities during the financial year 1 April 2015 to 31 March 2016.
2. Organisational structure and supply chains
2.1 This statement covers the activities of the West Bromwich Building Society and its subsidiary companies.
2.2 The West Bromwich Building Society is a mutual financial services organisation offering retail saving and residential mortgage products. Other financial products are offered via third parties. Additionally, the Society operates closed books of commercial and other loans.
2.3 The Society employs circa 750 staff and operates out of a central office with a network of 37 branches.
3. Higher-risk activities
3.1 The following procurement categories are, by their very nature, considered to be at higher risk of slavery or human trafficking (although the Society has not identified any evidenced reason to believe that slavery or human trafficking exists in the above currently). The risk may be present both in the UK and abroad and may relate to the pay and working conditions of the staff employed to manufacture or produce:
- Staff uniforms – fabric, finishings and finished garments that are used in the Society’s uniform;
- Catering - farm workers, fruit and vegetable pickers, fish / seafood fishermen;
- Marketing and promotional merchandise;
- IT and electronics manufacture and also the disposal, dismantling and recycling stages; and
- Cleaning staff.
4.1 Responsibility for the Society’s anti-slavery initiatives is as follows:
4.2 Policies: The Group Secretary is responsible for ensuring that the Society’s policies are compliant with the Act. The Society’s Modern Slavery and Human Trafficking Statement is reviewed, ratified and approved by the Society’s Board annually.
4.3 Risk assessments: The Society operates a Risk Management Framework; this drives a consistent approach to the identification, assessment and management of risk. The initial assessment in respect of slavery and human trafficking was conducted in accordance with this and risks will be monitored via this framework on an ongoing basis.
4.4 Investigations / due diligence: All human rights concerns are taken seriously and addressed promptly by the Society. If any instance of slavery and / or human trafficking is identified or suspected within the supply chain, this will be fully investigated.
5. Relevant policies
5.1 The Society operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
5.2 Open Door Reporting Policy: The Society encourages all of its employees 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 risk of slavery or human trafficking. The Society's Open Door Reporting procedure is designed to make it easy for employees to make disclosures, without fear of retribution. Employees who have concerns can raise them confidentially to an approved nominated individual or via the confidential telephone line.
5.3 Supplier Code of Conduct: The Society's Supplier Code of Conduct communicates the Society’s global requirements in the areas of human rights, health and safety, business integrity and environmental management. Suppliers, consultants and agents providing goods and services to the Society are required to comply with this Code.
5.4 Procurement Policy: The Society 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 Society will create a Supplier Code of Ethics by the end of 2016, and will require that all suppliers adhere to it by July 2017. Suppliers will also be required to cascade this Code of Ethics to any subcontractors that they may engage in the course of delivering goods or services to the Society.
6. Supplier due diligence
6.1 The Society undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Society’s due diligence and reviews include the following:
- Assessing the risk of human-rights abuses in relevant areas of the Society’s business
- Suppliers presenting a low risk are monitored regularly as part of Supplier Relationship Management. Any change in their sourcing and / or supply chain policy would lead to a reassessment of their risk rating by the Society.
- Where suppliers, and this will usually depend on the category of goods or services being provided, have a risk assessment higher than “low”, the appropriate due diligence is carried out by Procurement. This includes reviewing the suppliers’ ethical sourcing policy and conducting at least one site inspection upon selection of a supplier. Random site inspections may be carried out throughout the contract lifecycle for established suppliers.
- Taking steps to improve substandard suppliers' practices, and supply chain transparency, including providing advice to suppliers and requiring them to implement action plans; and
- Invoking sanctions against suppliers that 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 and involving any relevant authorities.
- Since August 2015 all of the Society’s internally-drafted contracts require suppliers to comply with the Master Slavery Act 2015. By December 2016 all suppliers will be required to adhere to the Society’s Supplier Code of Conduct.
7.1 The Society has reviewed its position in light of the introduction of the Modern Slavery Act 2015 (the “Act”). As a result, the Society will be taking the following actions to develop and improve its position in relation to the Act. Actions will commence in 2016, and whilst some will be completed during the year, others will require longer timescales.
- Review of existing training provision to understand how education on the Act should be incorporated.
- Consideration of the use of other awareness mechanisms (e.g. posters, intranet, etc.).
- Incorporation of the requirements of the Act to relevant policies (both new and existing), as part of standard and ongoing review processes.
- Continual risk assessment of the Society’s position in relation to slavery and human trafficking; both as an employer and a purchaser of goods and services.
- Specific actions in relation to the Society’s supply chain:
- Review and update existing, and develop new, procurement policies and procedures (i.e. contracting and supplier relationship management) to address and incorporate provisions of the Act.
- Investigation of high risk purchase areas identified at 3.1 and development of action plans to address any issues.
- Development of work programme to iteratively assess the Society’s whole supply chain for slavery and human trafficking.
8. Document approval
8.1 This statement has been approved by the Society's Board, who will review and update it annually.