1. Introduction
This statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 (“The Act”) and sets out the steps that Saffron Building Society (“the Society”) together with its subsidiary and associated companies have taken to ensure that slavery and human trafficking are not taking place in its supply chains or any parts of its business.
The “Society” has zero-tolerance to any kind of modern slavery within its business and recognises that it has a responsibility to be aware of the risks, however small, in our business and wider supply chain. Colleagues are encouraged to report concerns, using appropriate reporting channels and management are expected to act upon them.
2. Our business
The Society consists of Saffron Building Society and one subsidiary company: Crocus Homes Limited. The Society has eight branches and employs in excess of 170 staff across its branch network and head office sites.
Serving our communities has been rooted at the core of the Society for over 170 years. Whilst our community has grown to include Members across the country, our sense of responsibility and connection is unchanged. We are here to serve and protect our community and help to ensure that it thrives.
Our vision is to help our Members to achieve financial happiness and we aim to achieve this by providing easy to understand, competitive savings and lending products to the retail market supported by first rate service. In addition to serving our Members we are also proactive in our wider communities, who we support through our wider programme of Environmental, Social and Governance activities under our programme “For Years to Come”.
3. Responsibilities
The Board of Directors has overall responsibility for ensuring that the Society complies with all legal and ethical obligations regarding modern slavery, and that in turn all colleagues comply with these obligations.
4. Supply chain risk
As a provider of financial services, the Society is not considered to be a participant in an industry with a high inherent risk of modern-day slavery. However, in delivering our services, we procure goods and services from suppliers who operate with extended, and sometimes global supply chains, some of which may present a higher risk. We have adopted a risk-based approach to reviewing our suppliers that may carry a higher risk.
We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or extended supply chain and we expect our suppliers and partners to act in the same way. We assess potential suppliers’ Modern Slavery risk and controls prior to contracting with them, to ensure that they meet our own standards.
We ensure third party contracts contain clauses regarding Modern Slavery and we assess that our suppliers are adhering to their contractual and ethical responsibilities surrounding Modern Slavery. This includes requiring them to conduct regular Modern Slavery risk profiling within their own supply chains, implement appropriate controls to prevent Modern Slavery and to notify us immediately if they become aware of any incidents of Modern Slavery within their supply chains.
Where any of our suppliers are required to maintain a Modern Slavery Statement, we retain a copy of the Statement as part of our onboarding process and due diligence checks and we will not engage with a supplier who does not produce a Statement where they are required by law to maintain one.
Where we outsource functions, we perform due diligence on all outsourcing partners to satisfy ourselves of the robustness of outsourcing arrangements. This is fully documented under our Third Party Management Policy and framework.
Colleagues can also report any suspicion of modern slavery or human trafficking under our Whistleblowing Process, which is designed to protect and support colleagues who make a non-malicious disclosure in the best interests of the Saffron and / or the wider community. This process provides a confidential and independent contact, who will then respond in an appropriate manner.
5. Training
We provide regular training to all our colleagues to ensure that a good level of understanding of the risks of modern slavery and human trafficking is maintained.
6. Further steps
The Society has conducted a review of the effectiveness of our policies and processes to prevent modern slavery and human trafficking in our business and extended supply chain. Following this review, we intend to take the following further steps:
- The Society remains committed to doing all that is reasonably can to contribute toward helping eradicate modern slavery and human trafficking and will keep policies and procedures under review.
- Introduce a new supplier due diligence questionnaire on Modern Slavery to support the Society in assessing the risk of modern slavery and human trafficking in the supply chair.
- Implement a new refreshed e-learning course, including how to respond to modern slavery identified within our supply chains.
- Review the Society’s whistleblowing policies to ensure they adequately accommodate the reporting of modern slavery issues in the business and supply chain.
