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 is 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 2016 to 31st March 2017.
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 Living Wage employer, paying its employees and all suppliers who work on site on a permanent basis the voluntary Living Wage.
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.
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 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 - 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
The Society’s approach to slavery and human trafficking
The Society has zero tolerance to slavery and human trafficking and is taking steps to ensure that it is not taking place in its supply chain. In 2016 the Society’s Procurement policy, procedures and processes were amended to reflect and incorporate provisions of the Act. For example, it is now policy that the appropriate anti-slavery risk assessment and due diligence are carried out when selecting new suppliers and as part of the periodic review of existing suppliers.
A Supplier Code of Conduct was created that covers 4 key principles including Human Rights and Employment Practice and in 2017 all existing suppliers will be asked to confirm their adherence to this Code.
From 2016, all new Society-drafted contracts include a Modern Slavery Act clause.
Other actions that also commenced in 2016 are ongoing and will require longer timescales:
- Continual risk assessment of the Society’s position in relation to slavery and human trafficking, both as an employer and as a purchaser of goods and services.
- Supply chain risk mapping to identify suppliers who, directly or through their subcontractors, may present a slavery risk to the Society.
In the coming year the Society also intends to make significant progress in the following areas:
- Complete the ongoing actions started in 2016
- Create an Anti-slavery Policy
- Develop a work programme to :
- Iteratively assess the Society’s whole supply chain for slavery and human trafficking.
- Define and implement a systematic methodology for continuous slavery risk assessment and subsequent action plans to address any issues
- Review existing training provision to understand how education on the Act should be incorporated
- Enable Society staff and suppliers to report any suspicion of slavery or human trafficking under the Society’s relevant reporting policies
- 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 suppliers adhere to the Society’s Supplier Code of Conduct
- Continuously assess and improve the measures that it has already implemented
This statement has been approved by the Society's Board, who will review and update it annually.