Modern slavery statement for the 2016/17 financial year
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that The Midcounties Co-operative Limited has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within its business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Society 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 other areas of our operations and supply chains in which there may be a greater risk. Work has commenced to review supplier terms and conditions/contracts to take into account ethics and modern slavery. The due diligence processes and checks currently in place will also be reviewed.
We operate a number of internal policies to ensure we conduct business in an ethical and transparent manner. These include:
- Modern Slavery and Human Trafficking policy. This sets out the Society’s stance on modern slavery and explains how colleagues can identify any instances and where they can go for help.
- Recruitment policy. To safeguard against human trafficking or individuals being forced to work against their will, we operate a robust recruitment policy, including checks for all potential colleagues on their eligibility to work in the UK.
- Whistleblowing policy. We operate a whistleblowing policy which allows colleagues, without fear of reprisal, to raise concerns about how other colleagues are being treated, and about suspect practices within our Society or supply chain.
- 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 also operate independent and confidential services such as SpeakInConfidence, a system allowing direct communication between colleagues and managers on an anonymous basis, and our Employee Assistance Programme, 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 of Conduct which can be found at https://www.co-operative.coop/.
Through 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.
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 plan to create and deliver training on modern slavery to our leadership team, HR and procurement teams and other relevant colleagues. This will ensure an understanding of the signs of modern slavery and what steps to take if it is suspected.
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.
Our Internal Audit function will undertake an annual review of the commitments made in this statement.
This statement was approved by the Board of Directors on 24 July 2017.