This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 (“the Act”). It sets out the steps that the West Bromwich Building Society and its subsidiary companies are undertaking to ensure there is no slavery or human trafficking in either its own business or the supply chains it uses.
This statement covers the activities of the West Bromwich Building Society and its subsidiary companies. It relates to actions and activities during the financial year 1st April 2017 to 31st March 2018.
Statement of Policy on the Society’s approach to slavery and human trafficking
It is the policy of the Society to adopt a zero tolerance approach to slavery and human trafficking in all its forms both in its supply chain and its business operations. The Society is committed to the continued enhancement of policies, procedures and business practices that extend its diligence in identifying issues related specifically to slavery and human trafficking and the associated fundamental human rights in general.
Organisational structure and supply chains
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.
The Society employs circa 750 staff and operates out of a central office with a network of 37 branches. It is proud to be a Voluntary Living Wage employer, paying its employees and ensuring the employees of all suppliers staff who work on site on a permanent basis at least the Voluntary Living Wage. The exception to this are those employees on an Apprenticeship scheme where the Society pays in excess of the minimum required amount.
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.
Although the financial services industry is not one in which there is a high risk of the occurrence of modern slavery, the Society has in place specific policies, procedures and processes which previously reflected and incorporated provisions of the Act but which have been further amended during 2017-18 to give greater emphasis to the identification of such issues earlier in the supplier selection and management process. For example, it is policy that appropriate anti-slavery risk assessment and due diligence are carried out early in the supplier selection process and as part of the periodic review of existing suppliers.
The following supplier 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 these 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 - kitchen staff, farm workers, fruit and vegetable pickers, fish / seafood fishermen
- Marketing and promotional merchandise
- IT and electronics manufacture, disposal, dismantling and recycling
- Facilities management - Cleaning staff, building and maintenance operatives, furniture manufacturers, construction workers
- Recruitment services
Existing activities and further steps
- The Society’s Supplier Code of Conduct is now required to be considered for inclusion in formal contracts. The Supplier Code of Conduct covers four key principles:
1. Human Rights and Employment Practice
Suppliers must respect basic human rights and conduct business ethically with its employees, customers and sub-contractors.
2. Environmental Management
Suppliers must respect the environment in which they operate, minimise environmental pollution and promote good energy use by reducing, reusing and recycling.
3. Occupational Health and safety
Suppliers must respect the health and safety of its employees and provide a safe workplace.
4. Business Ethics
Suppliers must extend the principle of fair and honest dealings to all parties with whom they do business, including sub-contractors and employees. New and updated contracts will normally include specific reference to compliance with this Code. Small local suppliers may be provided with some exemption relating to the documentation of procedural aspects of compliance but are expected to comply.
- From 2016, all new Society-drafted contracts also include a Modern Slavery Act clause.
Other actions that were progressed in 2017-18 include:
- Enhancement of internal record control and administration to more efficiently and accurately recognise where the risk of any given supplier being in contravention of the Act has been assessed.
- Supplier data cleansing to enhance supply chain risk mapping in order to identify suppliers who, directly or through their subcontractors, may present a slavery risk to the Society.
- Inclusion in the existing Whistleblowing Procedure for Suppliers, their Employees and Contractors a contact point within the Society for disclosures.
In the coming year the Society also intends to make further progress in the following areas:
- Further record enhancement and risk mapping of suppliers
- Embed systematic and continuous modern slavery risk assessment and subsequent action plans to address any issues
- Review existing internal staff training provision to understand how education on the Act could be incorporated
- Continue to ensure that all Society-drafted contracts contain a Modern Slavery Act clause to be flowed down all layers of the supply chain
- Ensure that all required suppliers adhere to the Society’s Supplier Code of Conduct
- Ensure all suppliers continue to award their staff who work on site at least the Voluntary Living Wage
- Continuously assess and improve the measures that the it has already implemented
This statement has been approved by the Society's Board, who will review and update it annually.