Slavery & Human Trafficking Policy
Modern Slavery Statement
This statement is published pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Principality’s Modern Slavery and Human Trafficking statement for the financial year ending 31 December 2018. It has been approved by the Society’s Board of Directors and is reviewed annually.
Principality Building Society has a zero tolerance to slavery, servitude, forced labour and human trafficking. The Society is committed to conducting business with honesty and integrity and treating everyone with dignity and respect. The Society engages with its partners and suppliers to help raise awareness and understanding, in order to mitigate the risk of Modern Slavery.
Progress during 2018
With the aim of further reducing the risk of slavery within our supply chain, we focused on deepening our understanding of the risks involved through our formal risk assessment process, raising awareness around instances of reported human trafficking and modern slavery and through continuing to deliver relevant training within the business.
In May 2018 a number of colleagues from within the business attended a Terrorism and Human Trafficking seminar hosted by a peer group Society. Amongst the speakers at that seminar were HMRC, the National Crime Agency and a representative of the ‘Unseen’, a charity which helps people who are classified as ‘Survivors of Modern Slavery.'
Our Business and Structure
The Society is a low risk UK Building Society focused on providing residential and commercial mortgages and savings along with general insurance products. The Society aims to offer good value, straightforward and transparent products, supported by prudent underwriting and outstanding customer service.
The Society has simplified its operating model through the disposal of a number of subsidiary businesses and through placing the loan book of Nemo Personal Finance into run-off.
Sourcing and Due Diligence
We have developed our sourcing processes further, expanding the questions we ask as part of this process to provide a deeper understanding of the action prospective suppliers are taking within their business and supply chain. Additionally, our Supplier Code of Conduct, created during 2016, is given to potential suppliers during the tender process to outline the Society’s expectations.
Key Performance Indicators
Incidences of Modern Slavery Identified
A key indicator of the effectiveness of our actions is the number of issues that have been identified and reported to the Society’s Compliance, Conduct and Financial Crime Risk Committee, and of those the number that have been closed to the satisfaction of the Society. During 2018, one issue relating to modern slavery was identified within the branch network.
Supply Chain Risk Assessment
During 2018, a Modern Slavery risk assessment was created which aims to identify the number of suppliers for whom further information is required to satisfy ourselves that appropriate action is being taken to address the modern slavery risks inherent to their business. This risk assessment will be reviewed annually in future.
During 2018, new suppliers were contacted for further information about their approach to mitigating supply chain risks as part of the tender process and there were no negative responses. All current suppliers were contacted during 2017 as part of the GDPR mailing and no negative responses have been received.
Training & Awareness
Training and awareness is central to enabling the business to identify the risk of modern slavery and take appropriate action. During 2018 the Society has established a relationship with Unseen, a leading UK based modern slavery charity to help raise awareness. The Procurement Team also completes an annual CIPS assessment which focuses on Ethical Procurement and covers Human Rights and Modern Slavery in depth.
We recognise that the modern slavery and human trafficking landscape is constantly evolving and we are committed to maintaining up-to-date knowledge of the issues. In 2019, we will continue to provide training as appropriate to colleagues and will continue to engage with suppliers in higher risk sectors and with other financial services companies to develop and share best practice.
Principality. Where home matters.