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Modern Slavery and Human Trafficking Statement 2018 - 2019


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 2018 to 31st March 2019.

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 36 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.

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 2018-19 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 certain suppliers.

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 evidenced reason to believe that slavery or human trafficking exists within our existing contracted supplier 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’s Supplier Code of Conduct is now required to be considered for inclusion in formal contracts. The Supplier Code of Conduct covers 4 key principles including Human Rights and Employment Practice.

All new Society-drafted contracts include a Modern Slavery Act clause.

Other actions that were progressed in 2018-19 include:

  • 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; and
  • Inclusion in policy and procedure of a mechanism whereby staff can securely report suspected instances of modern slavery, to complement the existing supplier whistleblowing procedure.

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

  • Review existing training provision to understand how education on the Act should 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 suppliers adhere to the Society’s Supplier Code of Conduct; and
  • Continuously assess and improve the measures that it has already implemented.

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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