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Modern Slavery and Human Trafficking Statement 2023/2024

Introduction

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 2023 to 31st March 2024.

 

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, 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.


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 over 700 staff and operates out of a central office with a network of 34 branches. It is proud to have 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. 


Higher risk activities

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:

  • 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; and
  • recruitment services.

Existing activities and further steps

  • The Society keeps its compliance with the Act under review in line with the 2017 Government guidance on Transparency in Supply Chains and the 2019 Government guidance on modern slavery statements;
  • The Society’s Third Party Risk Management Framework sets out the requirement for compliance with the Act within its supplier selection and   management processes, as well as within the procurement lifecycle;
  • Society policies are reviewed to ensure compliance with the Act, including in relation to Anti-Bribery and the Criminal Finances Act 2017;
  • Suppliers are required to be compliant with the Society’s Supplier Code of Conduct; and
  • The Society continues to robustly assert to all existing and prospective suppliers that, without exception, all of the Society’s supplier contracts must contain anti-modern slavery obligations. This allows the Society to terminate a contract immediately should a supplier fail to comply with its obligations under the Act.

Other actions that were progressed in 2023-24 include:

  • the Society has maintained its Good Business Charter (GBC) accreditation in recognition of its responsible business practices. The GBC consists of ten 10 components which include ethical sourcing;
  • the Society continues to advocate for ethical business practices and the GBC is incorporated into the Society’s Code of Conduct for Suppliers. This further ensures that the Society’s high standards of ethical behaviour are reflected throughout the supply chain by requiring its suppliers to either adopt or strive to adopt the Good Business Charter;
  • the Code of Conduct for Suppliers is published on the Society’s website and is highlighted to all suppliers regularly;
  • the Society continues to incorporate questions relating to modern slavery as part of the process for selecting contractors and will obtain Modern Slavery Statements (where applicable) and any other relevant policies and procedures; 
  • ongoing awareness of best practice and horizon scanning for potential changes to relevant legislation to ensure that the Society remains compliant and maintains high levels of transparency in the management and reporting of its zero-tolerance approach to modern slavery; 
  • the Society has continued to ensure its zero-tolerance expectations in relation to anti-modern slavery and human trafficking are met within its supply chains, particularly in the context of changing working practices in different industries resulting from the Covid-19 pandemic and global economic changes; 
  • the Society continues to articulate its requirements in relation to anti-modern slavery and human trafficking to those Society colleagues responsible for any aspect of procurement and the management of relationships with suppliers through mandatory training on joining the Society and ongoing training through the Society’s training programme. 

In the coming year the Society also intends to make significant progress in the following areas:

  • the Society will continue to monitor its suppliers by risk profile as part of its procurement processes;
  • including in relation to modern slavery; 
  • ensure that both best practice and changes in relevant legislation are effectively embedded in the Society’s zero-tolerance approach to modern slavery and reflected in its Modern Slavery and Human Trafficking Statement;
  • continue to provide a clear and effectively communicated Modern Slavery and Human Trafficking Statement, including seeking guidance from organisations expert in the production of clear and concise publications;
  • continue to embed the Society’s approach to minimising the risks of modern-slavery and human trafficking within its supply chains by providing appropriate training and guidance to support colleagues in maintaining awareness of the issue of modern slavery and human trafficking; and
  • continue to ensure the provision of a robust whistleblowing procedure which encourages and empowers all Society colleagues to raise concerns regarding modern slavery and human trafficking without fear of reprisal or detrimental treatment. 

This statement has been approved by the Society's Board, which will review and update it annually.

 

Jonathan Westhoff
Chief Executive

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