Modern Slavery and Human Trafficking Statement 2016

This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by Newcastle Building Society Group during year ending 31 December 2016 to prevent modern slavery and human trafficking in its business and its supply chains.

Introduction

The Newcastle Building Society Group has a zero tolerance approach to modern slavery of any kind within our operation. We all have a responsibility to be aware of the risks, however small in our business and wider supply chain. Staff are expected to report concerns, using appropriate reporting channels and management are expected to act upon them.

Organisation's Structure

The Newcastle Building Society Group consists of Newcastle Building Society and 3 key
subsidiary companies; Newcastle Financial Advisers Limited, Newcastle Strategic Solutions Limited and Newcastle Systems Management Limited. The Society is the United Kingdom’s 8th largest building society and the largest building society in the North East of England. The Newcastle Building Society Group has 28 branches and employs in excess of 1,000 staff across its branch network and head office sites.

Our Business

The Newcastle Building Society Group like all mutual organisations exists and functions for the benefit of its members, and so core to our vision is being a trusted provider of family savings, mortgages and financial advice delivered with good customer outcomes and great customer service.
In addition, our subsidiary companies, Newcastle Strategic Solutions Limited is dedicated to the provision of outsourcing for financial services and Newcastle Systems Management Limited provides system development and on-going operational support to both the Society and the business clients of Newcastle Strategic Solutions Limited.

Responsibilities

The Newcastle Building Society Group’s board of directors has overall responsibility for
ensuring our Modern Slavery and Human Trafficking policy complies with our legal and ethical obligations, and that all those under our control comply with it. All our staff must observe our policy on Anti-Slavery and Human Trafficking and be aware that turning a blind eye is unacceptable.

Supply Chain Risk

As the provider of financial services, the Newcastle Building Society Group is not in an
industry with a high risk of modern day slavery and is not part of a supply chain, however in delivering our services, we procure goods and services from suppliers who do operate supply chains some of which are global. We have adopted a risk based approach to reviewing our supply chains which may carry a higher risk; these supply chains and suppliers which supply goods and/or services to us include:-
• IT and electronics manufacture including the disposal, dismantling and recycling
stages;
• Marketing and promotional merchandise;
• Cleaning staff;
• Staff uniform supplier;
• Corporate hospitality

We manage these risk areas through our procedures set out in our Anti-Slavery and Human Trafficking policy and elsewhere and we have not identified any evidenced reason to believe that slavery or human trafficking exists in the above currently.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.


Staff are able to report any suspicion of modern slavery or human trafficking under our
Whistleblowing policy. This policy is to protect and support staff who make a non-malicious allegation in the best interests of the Newcastle Building Society Group, providing a confidential contact point and responding in an appropriate manner.


Wherever possible we will seek to perform critical functions in-house and will only outsource functions where such arrangements will avoid undue conduct risk, operational risk, andreputational risk. Where we outsource functions, we perform due diligence on all outsourcingpartners to satisfy ourselves of the robustness of outsourcing arrangements. This is fully documented under our Outsourcing policy.


We tell companies we do business with that we are not prepared to accept any form of
exploitation. Our Contracts policy advises that no agreements should be entered into by the Society which breach any law or regulation. The Contracts Policy also provides that any material contract must be reviewed by our Legal Services team prior to signature who will ensure there is a clause which obliges each party to comply with all applicable laws or regulations, in force from time to time.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide regular training to all our staff.

Further Steps

Following a review of the effectiveness of the steps we have taken this year to ensure that
there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:


• Ensure all of our supplier contracts (both existing and new) contain an anti-slavery
clause, this clause, which flows down through all layers of our supply chain, prohibits
suppliers and their employees from engaging in slavery and human trafficking;

• Review of existing training for all staff;

• Continued incorporation of the requirements of the Act to relevant policies and
procedures (both new and existing), as part of the annual review process;

• Continue to review, update and develop new procurement policies and procedures
(including risk assessment of suppliers) to address and incorporate provisions of the
Act;

• Review of our recruitment agency panel.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and
constitutes our Group’s slavery and human trafficking statement for the financial year ending 31 December 2016.

 

Date: 23 February 2017

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