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 2022 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. Colleagues 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 2 key subsidiary companies; Newcastle Financial Advisers Limited and Newcastle Strategic Solutions 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 31 branches and a dedicated financial advice location and employs in excess of 1,400 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 company, Newcastle Strategic Solutions Limited is dedicated to the provision of outsourcing for financial services and provides system development and on-going operational support to both itself and the Society.
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 colleagues 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;
- Colleague 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.
Colleagues are able to report any suspicion of modern slavery or human trafficking under our Whistleblowing policy. This policy is to protect and support colleagues 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, and reputational risk. 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 Procurement & Supplier Management 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 colleagues.
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:
- We will continue to ensure all of our supplier contracts (both existing and new) contain an anti-slavery clause, prohibiting suppliers and their employees from engaging in slavery and human trafficking and ensure obligations under the Act are replicated throughout their own supply chain and other contractors (where possible);
- Releasing regular updates and reminders of our obligations to all colleagues; and
- We will further review our Procurement & Supplier Management policies and procedures (including risk assessment of suppliers) to ensure they continue to address and incorporate provisions of the Act and are in line with best practice.
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 2022.
James Ramsbotham
CHAIR
NEWCASTLE BUILDING SOCIETY GROUP
Date: 28th April 2023