Slavery & Human Trafficking Policy
Slavery and Human Trafficking Statement
This statement has been produced in compliance with Section 54, Part 6 of the Modern Slavery Act 2015 (the Act) and sets out the steps that the Principality Building Society and its subsidiary business Nemo Personal Finance Limited (“the Principality Group”) have and which continue to be taken to ensure that slavery and human trafficking are not taking place in its supply chains or any parts of its business.
The Principality Building Society is the UK’s sixth largest Building Society and collectively with Nemo Personal Finance Limited employs over 1,000 people. The Building Society operates through 71 branch and agency offices which are located across Wales and the border area with England. The Building Society’s central administrative office is located in Cardiff. Nemo Personal Finance operates from a single location in Cardiff.
Slavery and Human Trafficking Policy
The Principality Group operates a number of policies which reflect its commitment to acting ethically and with integrity in business relationships, designing and implementing controls which are designed to ensure slavery and human trafficking is not taking place anywhere in its supply chains.
The Principality Group regularly re-evaluates its business practices to ensure high standards of business behaviour and social responsibility. The Society’s Board is committed to promoting fairness and dignity for all colleagues and others involved in the Principality Group. This commitment extends to the products, goods and services provided by suppliers.
It is important to Principality Group that all suppliers represent the Society in a manner that reflects its focus on doing the right thing for customers, colleagues and wider stakeholder groups.
The Principality Group aims to establish a supplier code of practice. This code of practice will include key areas such as human rights standards relating to forced or involuntary labour, human trafficking, child labour, working hours, wages and benefits, freedom of association, harassment and bullying. Principality Building Society will expect all suppliers to adhere to the supplier code of practice.
Supply Chain Risk
As the Principality Group is not in an industry with a high risk of modern day slavery, a risk based approach has been adopted to review supply chains that fall within sectors that carry a higher risk of modern day slavery. On a case by case basis and where considered necessary either by the Board or the Group Management Committee further assurance is obtained that suppliers are acting ethically and with integrity.
In addition, where suppliers are required to make their own statements in accordance with the Act, the Principality Group will monitor the content of the statements published.
Due Diligence Processes for Slavery and Human Trafficking
As part of the Principality Group’s approach to identifying and mitigating risk, appropriate due diligence work is carried out when engaging and working with both new and existing suppliers, whilst also ensuring that the work undertaken is proportionate to the services or goods to be provided and the risk involved.
The Principality Group provides relevant training and career development for all employees. Managers receive further support that includes training and line manager guidance to ensure consistency on the application of recruitment processes, management of suppliers and policies on fair treatment at work and equality and diversity. The Group’s Procurement team provides additional training on the requirements of the Act to all relevant managers who are responsible for managing third party supplier relationships.
National Living Wage/Low Pay
The Principality Group is committed to being a fair and reasonable employer and ensures that salaries remain competitive within the market through a variety of methods, including role evaluations and external benchmarking. The Society ensures that all colleagues are paid at the level of at least the national living wage rate, regardless of age.
Laurence Philip Adams
14 February 2017
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