It’s heart-breaking to know modern slavery exists within our communities. It’s a serious crime that is too easily overlooked.
Victims are often found in restaurants, hotels and pop-up industries, such as car washes; with many too frightened to come forward for help.
In 2017, our first modern slavery statement was signed off by the Society Board. We developed it with other Co-op societies to make it clear, informative, and most of all, effective.
This statement gives our commitment to ensure modern slavery does not take place anywhere within our business or supply chain.
The main areas we focus on are:
Raising awareness: As part of Anti-Slavery International and Euro Co-ops Sustainability Task Force Group, we share information and best practice to help tackle the issue across the world
Supplier engagement: Whenever we engage with a new, direct supplier, they will receive a copy of our modern slavery statement and stick rigidly to our employment legislation
Training and employment: We support the Bright Future Programme and are strengthening our partnership with City Hearts, helping to give those rescued from modern slavery a safe environment and the chance of a better future
Tackling Modern Slavery - Our 2020 Update
Bright Future Programme
The Bright Future programme has continued to develop, and we were one of the first organisations to join the Co-op Group in working with Bright Futures UK, which is a collaborative employment scheme that brings charities and businesses together to create jobs 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.
The Bright Future scheme has grown to include 44 organisations, who are co-operating to support victims of slavery, including John Lewis, Typhoo, Dixons Carphone and the Body Shop. Within our Society’s ‘Values in Action’ plan we made a commitment to ‘become a founding member of Bright Future Co-operative and ensure employment opportunities for Modern Slavery survivors’. We're delighted to report that in line with this aim, Bright Future has now been successfully registered as a cooperative. We are one of the founding members of that Co-operative and our Chief Values Officer, Pete Westall, represents our Society on the Bright Future Board.
Other Activities to Tackle Modern Slavery
Following on from our supplier modern slavery awareness event that we hosted last year in partnership with Business in the Community (BITC), we have been working with these suppliers to implement changes to help tackle the issue of modern slavery back in their workplaces, resulting in each of these businesses receiving a BITC certificate for completing modern slavery awareness training.
We have reached out to other organisations during the last year to raise awareness of Modern Slavery through a range of events, including our Chief Values Officer, Pete Westall, presenting to students at Oxford Brookes University about Values and Ethics in Business, and the role businesses must take to help tackle modern slavery. Pete Westall also presented at Business in the Community’s 2019 West Midlands Regional Showcasing Event in Birmingham, raising awareness amongst a range of businesses around the issue of Modern Slavery.
View our full modern slavery statement
Modern Slavery statement for financial year 2019/20
Slavery and Human Trafficking Statement for the financial year 2019/20
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that The Midcounties Co-operative 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 three years ago. This 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.
Midcounties Co-operative 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 have four core values that underpin our Purpose and guide the way we work.
We operate a range of businesses in Food, Travel, Healthcare, Funeral, Childcare, Utilities, 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 Utilities, Childcare, Travel and Flexible Benefits businesses trade across the UK.
Our high-risk areas
We have taken steps to understand in greater 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, and we continue to engage with our suppliers to further understand and discuss risks associated with modern slavery.
We ensure that all of our first meetings/contact with suppliers include the issuing of the following documents from our Head of Procurement;
- Ethical code of conduct
- Copy of our Modern Slavery Statement
As part of our due diligence processes and checks, 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 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 instances of modern slavery and where they can go for help.
- Recruitment policy. We operate a robust recruitment policy; this includes conducting eligibility to work in the UK checks for all prospective colleagues to safeguard against human trafficking or individuals being forced to work against their will.
- Whistleblowing policy. We operate a whistleblowing policy so that colleagues can raise concerns about inappropriate practices within our Society or supply chain without fear of reprisal.
- Code of business conduct. This code explains how we behave as an organisation and how we expect our Colleagues and suppliers to act.
- Diversity and Inclusion policy. This policy sets out our commitment to equal opportunities and the avoidance of discrimination, and applies to all aspects of employment with us. The policy outlines where colleagues can go for help and report any incidents of discrimination.
We have independent and confidential services such as Speak In Confidence, an anonymous conversation system allowing direct communication between colleagues and senior managers. We also have an Employee Assistance Programme, a free confidential helpline service, available to colleagues so they can talk to professionals on any personal, home or work-related issues.
To further increase the support channels for our colleagues, within the 2019/2020 reporting year we set up a partnership with Grocery Aid, a national charity that helps people across the whole of the grocery industry with emotional, practical and financial support. All of our colleagues are provided with the dedicated helpline number for Grocery Aid.
The majority of the 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 (SSC) which can be found at https://www.co-operative.coop/ethics. The SSC sets out the workplace and employment standards that we expect of all our suppliers. It is based on the Ethical Trading Initiative 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 2,000 co-op own branded supplier sites are covered, comprising over half a million workers across six continents and 72 countries.
Training and capacity building of our suppliers through FRTS is also a key focus, and through the FRTS 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. Through this FRTS training and capacity building programme 20 supplier events were completed in 2019, reaching over 1,000 delegates and including 844 supplier sites.
Outside of FRTS sourced products, our businesses follow our supplier ethical code of conduct. A core focus area for our business within our direct supply chain is our ‘Best of Our Counties’ range in our Food Retail business. This is a unique range of locally sourced food and drink found in our Food Stores, sourced within the relevant Store’s home or neighbouring county.
Over the last year we have carried out a full audit and risk assessment on all of our ‘Best of our Counties’ local supplier processes. We’ve also partnered with a third party to carry out ongoing audits of these local suppliers, ensuring that all of our ‘Best of our Counties’ suppliers adhere to our ethical code of conduct and adhere to relevant employment legislations. Only local suppliers who adhere to these standards and pass our auditing process can be included in our ‘Best of our Counties’ range.
In addition, our Head of Procurement works 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 includes ensuring our terms and conditions take account of ethics and modern slavery for our preferred suppliers.
Following on from our supplier modern slavery awareness event that we hosted last year in partnership with Business in the Community (BITC), we have been working with these suppliers to implement changes to help tackle the issue of modern slavery within their workplaces. This has resulted in each of these businesses receiving a BITC certificate for completing modern slavery awareness training.
We have implemented training and awareness-raising activity in relation to modern slavery with our colleagues, members and partner organisations:
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
Our Head of Procurement is examined each year on ethical procurement issues, including Modern Slavery, as part of her ongoing professional qualification
Colleague representatives have been engaged in awareness-raising and signposting of support agencies
Access to our Modern Slavery and Human Rights policy is available to all colleagues through our ‘Colleagues Connect’ website. ‘Colleagues Connect’ also enables our colleagues to engage in two-way feedback and is an additional channel for concerns to be raised.
We have a dedicated webpage on our website to raise awareness of Modern Slavery amongst our members, including hosting on this web page a theatre production in which we sponsored our community partner ‘Justice in Motion’ to raise awareness of Modern Slavery.
We reached out to other organisations during the year to raise awareness of Modern Slavery through a range of events, including our Chief Values Officer presenting to students at Oxford Brookes University about Values and Ethics in Business, and the role businesses must take to help tackle modern slavery. Our Chief Values Office also presented at Business in the Community’s 2019 West Midlands Regional Showcasing Event in Birmingham, raising awareness amongst a range of businesses around the issue of Modern Slavery.
We will continue to deliver training to raise awareness of Modern Slavery during the coming year.
We were one of the first organisations to join the Co-op Group in working with Bright Future, a collaborative employment scheme that brings charities and businesses together to create jobs 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.
The Bright Future scheme has grown to include 44 organisations, who are co-operating to support victims of slavery, including John Lewis, Typhoo, Dixons Carphone and the Body Shop.
Within our Society’s ‘Values in Action’ plan we made a commitment to ‘become a founding member of Bright Future Co-operative and ensure employment opportunities for Modern Slavery survivors’. We can report that in line with this aim, Bright Future has now been successfully registered as a cooperative. We are one of the founding members of that Co-operative and our Chief Values Officer represents our Society on the Bright Future Board.
We have engaged with 6 individuals as part of the Bright Future program to support and develop employability skills and opportunities, with 4 of these individuals gaining work experience through our Food Retail business, and 2 through our Childcare business. This valuable experience enabled these individuals to gain skills and pursue their chosen careers. We currently have one of these individuals in permanent employment with the Society, working in our Food Retail business.
Through our Society’s ‘Values in Action’ plan we will continue to support employment opportunities for vulnerable members of society and ensure employment opportunities for Modern Slavery survivors.
Our performance indicators
On a broader scale, our Society uses the United Nations Sustainable Development Goals to track our progress through Business in the Communities’ Responsible Business Tracker. These 17 Development Goals form the 2030 Agenda for Sustainable Development – including decent work and reduced inequalities. We were amongst 94 businesses that completed BITC’s Responsible Business Tracker for the 2019/2020 reporting year. Our overall score was classed as ‘outstanding’, leading our benchmarking group and scoring significantly higher than the cohort average.
We can gauge the effectiveness of the steps we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if no reports are received from colleagues, the public, or law enforcement agencies to indicate that Modern Slavery practices have been identified.
We have received no reports of incidents relating to Modern Slavery to date.
All of our colleagues have access to our Modern Slavery and Human Trafficking Statement through our Colleagues Connect website.
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. Specific measures we have taken include:
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 Ethical code of conduct
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 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 for this statement
This statement was approved by the Board of Directors on 27 July 2020