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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 2022 to 31st March 2023.
It is the policy of the Society to adopt a zero tolerance approach to slavery, servitude, forced or bonded labour, or human trafficking (collectively referred to as “modern slavery” in this statement) in all its forms both in its supply chains and its business operations. The Society will not support any arrangement or relationship that is knowingly involved in modern slavery. The Society is committed to the continued enhancement of policies, procedures and business practices that extend its diligence in identifying issues related specifically to modern slavery and fundamental human rights in general.
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 643 staff and operates out of a central office with a network of 34 branches. It is proud to have recently been awarded accreditation as a Living Hours employer for its commitment to providing colleagues with the security and stability of hours they need to meet their everyday needs. This complements the Society’s continued commitment to be a Living Wage employer, paying its employees and all suppliers who work on site on a permanent basis at least the voluntary Living Wage.
The Society applies rigorous standards in the recruitment and employment of its staff and complies with all employment legislation and applicable regulations.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 reflect and incorporate provisions of the Act but which have been enhanced 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 review of suppliers. A recent policy addition is that a review of a supplier’s modern slavery statements is also undertaken as part of the due diligence process.
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 evidence or reason to believe that slavery or human trafficking exists within our existing contracted supply chains). 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:
Other actions that were progressed in 2022-23 include:
In the coming year the Society also intends to make significant progress in the following areas:
This statement has been approved by the Society's Board, which will review and update it annually.
Jonathan Westhoff
Chief Executive