Modern Slavery Act Transparency Statement 2019
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 (“the Act”) and sets out the steps that Leeds Building Society (“the Society”) together with its subsidiary and associated companies have taken in 2019 to ensure that slavery and human trafficking are not taking place in its supply chains or any parts of its business.
Who we are and what we do
Leeds Building Society is Britain’s fifth largest building society and has over 800,000 members. The Society’s trading subsidiary and associated companies are Leeds Mortgage Funding Ltd and Leeds Building Society Covered Bonds LLP.
The Society is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Our mission is to help people save and have the home they want. We provide our services through the Society’s national Branches, online and member contact centres, as well as through its intermediary network in relation to home finance products.
Our Supply Chain
The Society’s supply chain includes over 500 suppliers of goods and services that we buy from the external market including 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, but nevertheless we remain vigilant and take our responsibilities under the Act seriously.
Our Policies and Processes
The Society’s business values include integrity and this is one of the ways that we ensure ethical and compliant behaviour sits at the heart of what we do. We have implemented a variety of policies including, in 2019, a Third Party Management Policy which requires colleagues to act ethically and with integrity in all of their third party supplier relationships. This Policy is reviewed regularly, together with its accompanying standards and procedures. We take a risk based approach when reviewing procurement of goods and services and place a specific focus on industries that carry a higher risk of modern day slavery.
In 2019, we rolled out new Third Party Management training briefings to colleagues with responsibility for the management of third party suppliers. This was introduced to ensure that colleagues are able to assess supplier compliance with the Act on an annual basis during the lifetime of the relationship.
Colleagues across the Society are also advised by our Third Party Management team on approaches to due diligence at the point of entry into supplier arrangements, which are proportionate to the risks involved in individual procurement exercises. Oversight and governance is 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.
Our Compliance with Policy Standards
The Society employs over 1,400 colleagues throughout our business, and all are vetted and referenced before they begin work. All receive regular training on our business values, which include matters relating to financial crime and public interest disclosures in accordance with our Speak Up Policy and Processes. In 2019, the Society was accredited 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 have now extended this to ensure individuals working on our sites and employed by our third party suppliers are also paid the real Living Wage.
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.
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 2019.
This statement was approved by our Board on 26 March 2020 and is signed on behalf of the Board by Richard Fearon, Chief Executive Officer.
Chief Executive Officer