This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that The Midcounties Co-operative Society has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain. We issued our first such statement last year. This second statement outlines the progress we have made in the last year.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Midcounties Co-operative has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
The Society is a consumer co-operative owned and controlled by its members. We are part of the global co-operative movement, and subscribe to co-operative values and principles that govern all co-operatives around the world.
We operate a range of businesses in Food, Travel, Healthcare, Funeral, Childcare, Energy, Post Offices and Flexible Benefits. Our heartlands are in Oxfordshire, Gloucestershire, Buckinghamshire, Shropshire, Staffordshire, the West Midlands, Wiltshire and Worcestershire. However, we also trade in the surrounding counties and our Energy, Childcare, Travel and Flexible Benefits businesses trade across the UK.
Our high risk areas
The main direct supplier ‘high risk area’ is in our Funeral business where masonry stone is purchased from India. The Society has longstanding steps in place to mitigate risks with this arrangement. We have thorough due diligence to ensure our suppliers uphold their code of conduct agreements, including a bespoke agreement for masonry suppliers, ongoing audits of progress against their commitments, and regular visits from senior management.
We are also taking steps to understand in more detail the areas of our Society and supply chain in which there may be a greater risk. Work has been ongoing throughout the year to review supplier terms and conditions/contracts to take into account ethics and modern slavery. We have implemented a process in which all first meetings / contact with suppliers include the issuing of the following documents from our Head of Procurement:
- Ethical code of conduct
- Signed copy of our Modern Slavery Statement
- Standard letter seeking their confirmation of adherence to employment legislation.
Due diligence processes and checks in place have also been reviewed, and as a result all suppliers must return a signed copy of our Ethical Code of Conduct, to confirm their adherence to all related Midcounties polices, including Modern Slavery.
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- Modern Slavery and Human Trafficking Policy. This policy sets out the Society’s stance on modern slavery and explains how Colleagues can identify any instances of this and where they can go for help.
- Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all potential Colleagues to safeguard against human trafficking or individuals being forced to work against their will.
- Whistleblowing policy. We operate a whistleblowing policy so that all Colleagues know that they can raise concerns about how other colleagues are being treated, or practices within our Society or supply chain, without fear of reprisals.
- Code of business conduct. This code explains the manner in which we behave as an organisation and how we expect our Colleagues and suppliers to act.
We have independent and confidential services such as SpeakInConfidence, which is an anonymous dialogue system allowing direct communication between colleagues and senior managers. We also have an Employee Assistance Programme (EAP) which is a free confidential helpline service for colleagues to talk to professionals on any personal, home or work related issues.
The majority of suppliers we work with transact with our Food Retail business. We are members of the buying group Federal Retail Trading Services (FRTS), which purchases on behalf of our Food Retail business. FRTS has its own Modern Slavery Statement and Sound Sourcing Code (SSC) of Conduct which can be found at https://www.co-operative.coop/. The SSC sets out the workplace and employment standards that we expect from all our suppliers. It is based on the Ethical Trading Initiative’s (ETI) Base Code and core international labour standards, and includes checks on forced labour and modern slavery.
FRTS suppliers are identified for audit using a risk-based approach determined by their responses to Sedex (Supplier Ethical Data Exchange) questionnaires, worker profiles, country of origin, and sector analyses. Through this monitoring programme over 1,800 co-op own branded supplier sites are covered, comprising over half a million workers across six continents.
Training and capacity building of our suppliers through FRTS is also a key focus. Through our ethical trade supplier engagement programme we continue to provide a variety of bespoke and interactive training opportunities for suppliers on an ongoing basis, as well as providing access to tools and collaborative initiatives to help suppliers address the underlying causes of human rights issues and to manage risks such as modern slavery.
Outside of FRTS sourced products, our businesses follow our Society’s supplier ethical code of conduct. Supplier visits and follow up audits are carried out for suppliers identified as potentially ‘high risk’.
We have appointed a Head of Procurement to work closely with each business group to plan and deliver a robust purchasing and procurement strategy for ‘goods not for resale’ across the Society. This work will include ensuring our terms and conditions take account of ethics and modern slavery for our preferred suppliers.
We have implemented training and awareness raising activity in relation to modern slavery with our colleagues and members:
- Managers across the Society have been briefed on our policies and processes and engaged in awareness raising around modern slavery
- Our specialist HR colleagues have received additional training on Modern Slavery in partnership with Business in the Community
- Colleague representatives have been engaged in awareness raising and signposting of support agencies
- An awareness raising session took place with our members at our 2018 AGM, with guest speaker Paul Gerrard, Policy Director at Co-op Group, providing an insight into real life issues surrounding Modern Slavery in the UK.
We will continue to deliver training to raise awareness of modern slavery during the year.
We have joined other businesses and co-operative societies across the UK in becoming a Bright Future business partner. Bright Future is an innovative scheme providing employment opportunities for victims of Modern Slavery. Business partners such as ourselves work with local charities to match employers with slavery survivors who are then offered a four-week paid employment work placement, leading to a non-competitive job interview.
We have supported two individuals during the last 12 months as part of this programme and will continue to support Bright Future throughout the year.
Our performance indicators
We record the number of colleagues who have received Modern Slavery awareness training during the year. For the year ending July 2018 that number was 868, and included colleagues from across the Society. The total number of colleagues employed was 8,404.
We have received no reports of incidents relating to Modern Slavery to date.
We will take appropriate action if we suspect or are advised of any instances of modern slavery or human trafficking within the Society or our supply chain.
An annual review of commitments made in this statement is undertaken by the Society to ensure due diligence, specifically looking at the following:
- Suppliers: Continue to ensure that whenever we engage a new direct supplier that they receive a copy of our Modern Slavery Statement, and that they sign up to adhere to our employment legislation
- Training and capacity building of suppliers: Through FRTS continue to provide a variety of bespoke and interactive training opportunities for suppliers on an ongoing basis, as well as providing access to tools and collaborative initiatives to help suppliers address the underlying causes of human rights issues and to manage risks such as modern slavery.
- Training our colleagues: Ensure all Managers across the Society have been briefed on our policies and processes, and specialist colleagues have received additional training
- Employment: Monitor the number of colleagues we support through the ‘Bright Future’ programme, supporting those who have been rescued from Modern Slavery to get back into the workplace
- Policies: On-going monitoring of our policies in place to ensure that we continue to raise awareness around tackling Modern Slavery throughout our operations.
Approval of this statement
This statement was approved by the Board of Directors on 30 July 2018.