Modern Slavery Act Transparency Statement 2016
This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 (the Act) and sets out the steps that Leeds Building Society (the Society) has taken in 2016 to ensure that slavery and human trafficking are not taking place in its supply chains or any parts of its business.
Our Supply Chain
Our supply chain encompasses over 500 suppliers of goods and services to the Society which enable us to help people save and have the home they want. Whilst operating within a low risk industry for modern day slavery, we purchase a wide variety of goods and services from the external market including professional services (such as conveyancing services), office consumables, corporate clothing and IT software.
Our Policies and Processes
The Society has implemented a variety of policies including a Procurement and Supplier Management Policy which require colleagues to act ethically and with integrity in all of their business relationships. We are taking a risk based approach to review the procurement of goods and services which are derived from industries that carry a higher risk of modern day slavery. This means that as part of our due diligence process when tendering for goods and services or when re-negotiating a contract with an incumbent supplier, we will seek assurance from suppliers that they are adhering to the requirements of the Act.
Colleagues across the business are advised by our Procurement and Legal Services teams on approaches to due diligence which are proportionate to the expenditure and the risks involved in individual procurement exercises. Oversight and governance is provided by our bi-monthly Operational and Regulatory Risk Committee and operational areas are expected to attest against controls on an annual basis under the Risk Management Framework. Our Procurement team also monitors the statements of our supplier partners who are required to make their own statements pursuant to the Act.
Additionally, the Society ensures it complies with employment legislation by requiring suppliers to pay at least the minimum wage on all third party contracts provided with a labour component (such as cleaning services). The Society also formally recognises the Leeds Building Society Staff 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.
Our Compliance with Policy Standards
The Society maintains a Speak Up Policy which provides guidance to all colleagues on how to disclose malpractice and provides information on how they will be protected from any form of retribution, victimisation or detriment under the Public Interest Disclosure Act 1998. Colleagues can express their concerns confidentially via our Speak Up Hotline service. Relevant training is provided annually to colleagues to ensure continued understanding of and compliance with Society policies across all areas of required conduct.
Chief Operating Officer