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 active subsidiary company: Crocus Homes Limited. The Society has eight branches and employs around 200 staff across its branch network and head office sites.
Serving the communities has been rooted at the core of the Society for over 170 years. Whilst the community has grown to include Members across the country, the sense of responsibility and connection is unchanged. The Society is here to serve protect our community and help to ensure that it thrives.
The Society’s vision is to help our Members to achieve financial happiness and aims 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 its Members, it is also proactive in its wider communities, who are supported through the Society’s wider programme of Environmental, Social and Governance activities under its 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 in turn that 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 its services, it procures goods and services from suppliers who operate with extended, and sometimes global supply chains, some of which may present a higher risk.
The Society has adopted a risk-based approach to reviewing its suppliers that may carry a higher risk.
The Society is committed to ensuring that there is no modern slavery or human trafficking in any part of its business or extended supply chain and expects its suppliers and partners to act in the same way. An assessment of potential suppliers' Modern Slavery risk and controls is carried out prior to contracting with them, to ensure that they meet the Society’s own standards.
The Society ensures third party contracts contain clauses regarding Modern Slavery and assesses 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 suppliers are required to maintain a Modern Slavery Statement, The Society retains a copy of the Statement as part of its onboarding process and due diligence checks and will not engage with a supplier who does not produce a Statement where they are required by law to maintain one.
Where functions are outsourced, due diligence is carried out in order for the Society to be satisfied with 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. This process provides a confidential and independent contact, who will then respond in an appropriate manner.
5. Training
Regular training is provided 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 its policies and processes to prevent modern slavery and human trafficking in its business and extended supply chain and have found no further steps are required at this stage. However, this area remains under review, and further enhancements will be made if required.
This statement was approved by the Board on 8th February 2024
