Introduction
The Modern Slavery Act 2015 (the Act) requires West Bromwich Building Society to mitigate the risk of slavery or human trafficking taking place in its business, operations or supply chain. This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 (“the Act”) and applies to the West Bromwich Building Society and its subsidiaries. This statement refers to the financial year from 1st April 2025 – 31st March 2026.
Our commitment
We are committed to adopting a zero-tolerance approach to slavery, servitude, forced or compulsory labour, or human trafficking (collectively referred to as “modern slavery” in this statement) in all its forms both in supply chains and business operations. We ask that our suppliers will not engage in any practice that amounts to slavery by asking them to agree to our terms and conditions included in all our Purchase Orders.
Organisational structure and supply chains
The West Bromwich Building Society is a mutual financial services organisation offering retail saving and residential mortgage products. Other financial products are offered via third parties. Additionally, the Society operates closed books of commercial and other loans.
The Society employs circa 742 colleagues and operates at our head office with a network of 34 branches. We are proud to have recently been awarded accreditations such as the Sunday Times Best Places to Work and all three Living Wage accreditations (wage, hours and pension), providing colleagues with security for their financial futures. In addiction all suppliers who work on site on a permanent basis are paid at least the Living Wage.
The Society applies rigorous standards in the recruitment and employment of its colleagues and complies with all employment legislation and applicable regulations.
Although the financial services industry is not considered one in which there is a high risk of the occurrence of modern slavery, the Society has in place specific policies, procedures and processes which reflect and incorporate provisions of the Act.
Higher risk activities and management
The risk may be present both in the UK and abroad and may relate to the pay and working conditions of the staff employed to manufacture or produce, for example:
- colleague uniforms - fabric, finishings and finished garments that are used in the Society’s uniform;
- catering - kitchen workers, farm workers, fruit and vegetable pickers, fish / seafood fishers;
- marketing and promotional merchandise;
- IT and electronics manufacture, disposal, dismantling and recycling;
- facilities management - cleaning colleagues, building and maintenance operatives, furniture manufacturers, construction workers; and
- recruitment services.
Training on modern slavery and trafficking
- The Society keeps its compliance with the Act under review in line with the 2017 Government guidance on Transparency in Supply Chains and the 2019 Government guidance on modern slavery statements;
- The Society’s established Supplier and Outsourcing Risk Management Framework sets out the requirement for compliance with the Act within its supplier selection and management processes, as well as within the procurement lifecycle;
- Society policies are reviewed to ensure compliance with the Act; and
- Suppliers are required to comply with the Society’s Supplier Code of Conduct.
Other actions that were progressed in 2025/26 include:
- The Society has achieved its B Corp™ accreditation in recognition of its responsible business practices;
- The Society continues to advocate for ethical business practices and the B Corp™ accreditation is incorporated into the Society’s Code of Conduct for Suppliers. This further supports that the Society’s high standards of ethical behaviour are reflected throughout the supply chain by requiring its suppliers to either adopt or strive to adopt the B Corp™ accreditation;
- The Code of Conduct for Suppliers is published on the Society’s website and is highlighted to all suppliers regularly;
- The Society continues to undertake due diligence relating to modern slavery as part of the process for selecting contractors;
- Regular horizon scanning is undertaken to identify any potential changes to relevant legislation to ensure that the Society remains compliant and maintains high levels of transparency in the management and reporting of its zero-tolerance approach to modern slavery;
- The Society continues to articulate its requirements in relation to anti-modern slavery and human trafficking to those Society colleagues responsible for any aspect of procurement and the management of relationships with suppliers through mandatory training on joining the Society and ongoing training through the Society’s training programme.
In the coming year the Society also intends to commit to the principle of continuous improvement by:
- Ensuring that best practice and changes in relevant legislation are effectively embedded in the Society’s zero-tolerance approach to modern slavery and reflected in its Modern Slavery and Human Trafficking Statement;
- Continuing to provide a clear and effectively communicated Modern Slavery and Human Trafficking Statement, including seeking guidance from organisations expert in the production of clear and concise publications to identify any improvements;
- Continuing to embed the Society’s approach to minimising the risks of modern-slavery and human trafficking within its supply chains by reinforcing the Society’s zero tolerance approach through training and guidance to support colleagues in maintaining awareness of the issue of modern slavery and human trafficking;
- Identifying examples of customer behaviour that may raise suspicion of a customer that may be a modern slavery victim, introducing the term as an example of vulnerability under the Society’s Vulnerable Customer Policy; and
- Refreshing awareness of the robust whistleblowing procedure which encourages and empowers all Society colleagues to raise concerns regarding modern slavery and human trafficking without fear of reprisal or detrimental treatment.
This statement has been approved by the Society's Board, which will review and update it annually.
Jonathan Westhoff
Chief Executive
