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This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 (“the Act”). It explains the steps that Leeds Building Society (“the Society”), together with its subsidiary and associated companies, have taken in 2025 to give us reasonable assurance that slavery and human trafficking are not taking place in our supply chains or any parts of our business.
Leeds Building Society is the UK’s fifth largest building society providing savings and mortgage services to around 1 million members. We're a proud mutual, owned by our members: the people who have mortgages and savings with us. We have a wide range of savings and mortgages. Our purpose is to put home ownership within reach of more people, generation after generation.
We're based entirely in the UK and our Head Office is in Leeds, West Yorkshire. We pride ourselves on the service we provide our members through the Society’s national branch network, online, our contact centres, and our intermediary network in relation to home finance products.
The Society employs approximately 1800 colleagues directly. We also complement the skills and expertise of our colleagues via the services provided by a number of third party suppliers. We manage these suppliers diligently to ensure that they match the expectations of the Society in relation to slavery and human trafficking.
The Society is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. The Society’s trading subsidiary and associated companies are Leeds Mortgage Funding Limited and Leeds Building Society Covered Bonds LLP.
The Society’s supply chain includes circa 600 suppliers of goods and services that we buy from the external market. These goods and services include professional services (such as conveyancing services), office consumables, corporate clothing and IT software. The regulated nature of financial services means that we operate within a low-risk industry for modern day slavery, we do however remain vigilant and take our responsibilities under the Act seriously.
To support our commitment, we have due diligence processes and risk management procedures in place to effectively manage our third party relationships. Details of these are in the next section. Additionally, we require our suppliers to abide by our Supplier Code of Conduct. This includes several activities which will help to detect and eradicate slavery and human trafficking within their business. In turn, this provides assurance that our supply chains are free of slavery and human trafficking.
There are three elements to our business where we ensure we complete sufficient due diligence to provide opportunities to identify cases of slavery or human trafficking to allow us to take any necessary action. These three elements are our colleagues, our suppliers and our members.
All colleagues employed directly by the Society are vetted and referenced before they begin work to ensure they have the right to work in the UK.
Once employed, our colleagues are contractually required to adhere to our policies and standards. Providing the requirements and guidance helps ensure that the risk of slavery and human trafficking in the business or supply chains is limited and encourages concerns to be reported.
In 2025, the Society maintained its accreditation as a Living Wage employer by the Living Wage Foundation. As part of our commitment to Fair Reward, we have paid at least the real Living Wage to all colleagues since 2014 and we have been an accredited Living Wage Employer since 2019.
We formally recognise the Leeds Building Society Colleague Association as the only independent trade union available to colleagues for the purposes of consultation on the terms and conditions of employment at the Society.
We understand the importance of colleague wellbeing and the risks associated with financial problems or other challenging circumstances. Therefore, we offer a 24/7 colleague assistance programme to enable colleagues to access counselling, legal advice and more. We also have a network of trained mental health first aiders throughout the Society who are available to offer guidance and support to colleagues who request this.
In this statement’s policy section, you will see that we have implemented a Third Party Management policy. Underpinning this, we have a set of standards including our Onboarding & Due Diligence Standard, Contracting Standard, and Third Party Management Standard. The policy and standards are updated on a periodic basis and were last reviewed and updated in April 2025.
Colleagues are advised by our Third Party Management team, on a case-by-case basis, on due diligence at the point of entry into supplier arrangements and throughout the contract lifecycle. We take a risk-based approach and focus on industries that carry a higher risk of slavery or human trafficking. The due diligence we complete is appropriate and proportionate to the risks involved for individual arrangements. As part of onboarding suppliers, we undertake checks to give us assurance that suppliers are also paid the real Living Wage. For any suppliers providing human resources, we ensure that the supplier has carried out vetting and reference checks equivalent to our own.
To further enhance our due diligence processes, in 2022, we launched a sustainability due diligence tool. This focuses on sustainable procurement and labour and human rights. We have a process for enhanced screening of our third party suppliers that present a higher risk of slavery.
Modern Slavery clauses are included in the Society’s standard supplier agreements. When contracting on a supplier’s standard terms, the Society looks to ensure requisite modern slavery provisions are included.
Oversight and governance are provided by our Operational Resilience Committee and operational areas are expected to attest against controls on at least an annual basis under the Risk Management Framework.
To help our colleagues identify members who could be at risk of slavery or human trafficking or have been subject to this, our learning and development team provide vulnerable customer training. Where there are any concerns, colleagues will report these and they will be assessed on a case-by-case basis. Any action taken is always with the best interest of our members at the forefront.
As part of our member onboarding, we carry out due diligence checks to ensure accounts opened meet our carefully agreed criteria and occasions of suspicious activity are picked up and processed appropriately.
We also have ongoing monitoring in place and a specialist fraud team. This team use a defined set of criteria to assess transactions and member activity that could indicate involvement in fraudulent activity, some of which could be the result of slavery or human trafficking. Once fraudulent activity is identified, internal processes are followed to ensure appropriate action is taken.
As part of our ongoing strategy, we continue to cherish our branch network which helps our members who use our services via this channel to develop relationships with our branch colleagues. This means colleagues are in a strong position to identify changes in behaviour which could indicate vulnerabilities. In line with the vulnerable customer training, branch colleagues are then able to report any concerns and propose support if needed.
Within the Society, ethical and compliant behaviour sits at the heart of what we do. We have implemented a variety of policies and processes which are reviewed on a periodic basis and made available to our directly employed colleagues. These must be adhered to as part of a colleague’s contractual obligations and set out the expectations for colleagues to act ethically and with integrity. The policies and standards are set out in the following table. These documents help to support the Society’s commitment to reducing the risk of modern slavery and human trafficking in the business and the supply chains. They also provide opportunities to allow any cases to be identified.
The policy has been designed to articulate how the Society manages People Risk throughout the employment lifecycle.
The purpose of this standard is to encourage the disclosure of actual, potential or perceived conflicts of interest in order to protect the integrity and reputation of the Society and its members.
This standard sets out the principles behind our recruitment methods to ensure effectiveness, efficiency and fairness.
The purpose of this standard is to encourage colleagues to report suspected wrongdoing as soon as possible. This standard provides guidance on how to raise a protected disclosure or reportable concern without fear of retribution, victimisation or detriment.
This documents the expectations we have for suppliers including details of processes suppliers should have in place to provide assurance to the Society that our supply chain is free of slavery and human trafficking.
The purpose of this policy is to set high level standards for the management of third party arrangements. This policy also supports the operational resilience policy and details the minimum standards the Society has in place to meet legislative and regulatory requirements associated with managing third parties.
All colleagues receive regular training on our business values. Training is provided on a variety of topics that is role specific, but all colleagues are regularly trained on:
By adhering to our policies and processes, we are reasonably assured that there have been no cases of modern slavery or human trafficking associated with any of our direct employees or within our supply chains since we started monitoring this. However, we remain committed to ensuring we can identify cases and continue to review our policies and procedures to support our efforts.
In 2025, we worked to gain better visibility of our fourth party suppliers. We updated our Supplier Code of Conduct to require our suppliers to ensure they are completing proportionate due diligence to identify any cases of modern slavery or human trafficking.
In 2026, to strengthen our commitment to ensuring there are no cases of modern slavery or human trafficking in our business or supply chains, we plan to leverage expertise from peer working groups to further enhance our current practices.
As part of our commitment to ensuring we are a responsible business, we set up the Leeds Building Society Charitable Foundation in 1999 to provide funding to charity work across the UK that supports our purpose. For further information about the foundation see About Charitable Foundation | Leeds Building Society.
Via the Foundation, the Snowdrop Project based in Sheffield received a 3-year grant in 2024 to support their work with survivors of modern slavery. Volunteering opportunities have been made available to Society colleagues and, in 2025, colleagues volunteered 210 hours to support the project. In addition to the support from the Foundation, the Society also funded the decorating of two properties with this project.
As modern slavery and human trafficking is unfortunately still an issue, we will continue to explore opportunities to support victims of modern slavery through our work with communities and will seek opportunities to raise awareness of the issues faced.
The Society remains committed to doing all that it reasonably can to contribute toward helping eradicate modern slavery and human trafficking and will keep policies and procedures under review in 2026.
This statement was approved by our Board on 26 February 2026 and is signed on behalf of the Board by Annette Barnes, Interim Chief Executive Officer.
Annette Barnes
Interim Chief Executive Officer
