Ethics & Diversity

‘Modern Slavery Statement – 2025

The Society is committed to ensuring that modern slavery and human trafficking have no place in its operations or supply chains.

Organisation and structure

The Society operates as a single entity within the UK, with a clearly defined governance structure overseeing its activities. As a single entity operating exclusively within the UK, the Society assesses its exposure to modern slavery risks as low. Nevertheless, we remain vigilant and proactive in maintaining ethical supply chains. We uphold this commitment by fostering transparency and accountability across all aspects of our business.

Our leadership team is responsible for ensuring compliance with relevant legislation, including the Modern Slavery Act 2015, and for embedding ethical chain practices standards throughout our operations. The Society works closely with key business areas — including procurement, risk management, and human resources — to ensure robust oversight and due diligence regarding modern slavery risks.

Colleague Awareness

All colleagues receive training to recognise and respond to potential risks of modern slavery within our business and supply chain. Colleagues are encouraged to report concerns through our Risk Event process or via the Speak Up Policy, ensuring swift investigation and action.

Supply Chain Due Diligence and Risk Assessment

The Society prioritises long-term relationships with local suppliers and key third parties, ensuring responsible sourcing and ethical partnerships.

All key third parties have undergone a rigorous due diligence process. Given that the majority operate within the UK, we maintain confidence in their ethical standards and business practices.

We continuously review our risk assessment processes to identify any emerging risks and strengthen our approach.

Monitoring and Continuous Improvement

While the Society believes the risk of modern slavery and human trafficking within its operations remains low, we are committed to ongoing assessment and enhancement of our policies and procedures. Future developments, including legislative updates and best practice recommendations, will be incorporated into our approach.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015

Iain Kirkpatrick, Chief Executive – May 2025

The Society values the differences that a diverse workforce brings to the organisation.

It is the Society’s Policy to establish and maintain a working environment, terms and conditions of service and employment practices and procedures which will ensure that no job applicant or employee receives less favourable treatment on the grounds of gender, marital status, race, colour, nationality, ethnic origin, disability, sexual orientation, gender reassignment, religion or belief, pregnancy, maternity, paternity, shared paternity, age, educational background and professional background. 

The Society is also committed to ensuring that the workplace is free from all forms of discrimination and harassment.

It is part of the Society’s Policy to employ, and provide a suitable environment for, people with disabilities. Where possible, all reasonable facilities will be provided for employees with disabilities to pursue their careers without difficulty or disadvantage.

Application and Scope

This Policy will apply not only to current employees, but also to prospective employees. Although the primary impact of this Policy may be felt in the areas of recruitment, promotions and transfer, the Policy nevertheless is applicable to any employment matter in which the equitable treatment of a potential, current or ex-employee may be at issue, for example:

• Access to training opportunities
  
• Interpretation of conditions of service
  
• Application of disciplinary/grievance procedures, etc
  
• The provision of references

The Society supports the Women in Finance Charter and in doing so seeks to attain a minimum of one third representation of the under-represented gender in each of the following groups:

• All Society Employees
• The Society’s Executive Team
• The Society’s Board

In setting these targets, the Society is aiming to support a healthily diverse and inclusive workforce and senior team, whilst recognising that in a smaller organisation relatively large percentage changes can result from normal staff turnover.

As at 31 August 2023, based on our targets set, we are:

Above target at 43% of women, being on the Society’s Board

Above target at 50% of women being in the Society’s Executive Team

Just below target for men, being the under-represented gender, at 30% across all Society Employees.

The Society will publish annually within its Report and Accounts and on its website the targets and its performance against them.

When we signed up to the Charter in 2016 we had 65% female representation. As of 31 August 2023 we have 70% female representation with 46% female representation in senior management.

We will continue to focus on embedding an inclusive culture and ensure that our organisation becomes more diverse as a result.

As a mutual organisation a key aspect of our purpose is to ensure that we place the needs of our colleagues, members and communities at the heart of all we do. This commitment includes our desire to operate our business in a sustainable way which extends to our impact on the environment, stretching beyond purely legal and regulatory requirements.

We are committed to good environmental performance coupled with a supporting programme of continuous improvement as part of our operations and support activities.

We are committed to compliance with legislative and regulatory requirements, and as such retain our aim to be Net Zero as a business by 2050. However, we recognise that we are likely to prioritise shorter term actions to target Scope 1, 2 and selected Scope 3 emissions initially, given that they are more within our gift to influence.

We have worked to re-set our approach to environmental compliance based upon expert professional advice, internal resource prioritisation together with a lack of direction from industry governing bodies.

By the end of 2024 we will produce a Carbon Footprint statement for the first time, and this will assist by establishing greater visibility of what is driving our performance. Once completed we will use the data to support development of a high-level strategy linked to specific GHG Scope categorization.

This approach will ensure that we understand the actual impact of our activities by category and allow us to start developing a short-term action plan, formal targets and a longer term costed path towards achieving Net Zero as the mortgage scenario becomes clearer.

Additionally, as part of our wider commitment to embed wider ESG elements to our business activities, we will instil a clear focus on how we can reduce our environmental impact by promoting good practice and continuous improvement as an explicit element of our overall strategy. This will include our commitment to benchmark our business from an objective externa perspective by pursuing BCORPS accreditation.

In support, we will seek to further embed awareness of business and personal responsibilities with all colleagues, ensuring that consideration of the environmental impact of all new or renewed activities and contracts is a pre-requisite.

Energy

We have renewed our energy contracts during 2024 and source only renewable electricity for all operational business locations. We have removed the use of gas from our operation at Welland House, meaning that we only have one branch office as a regular user.

Environmental considerations were explicit in both the appointment of our external contractors and the practices and solutions adopted as part of the development of Newcombe House which resulted in an EPC rating of B (Originally E).

Moving towards Net Zero

We engaged with Inspired Energy to help us understand both our current position and challenges moving forward as part of our Board Strategy Day in November 2023 and it was clear that our biggest challenge is in relation to our mortgage book. This is likely to remain the case in the immediate term (along with all other lenders) and therefore we will be developing our approach to ensure that aspects which are more completely within our control are prioritised.

We will produce our first Carbon Footprint Statement for 2024 which will be used to support development of our wider strategy which will feature short, medium and long term targets as part of our eventual path to Net Zero.

We will benchmark our activity by pursuing BCORPS accreditation.

FCA Certified Paper

We use 100% recycled paper within the Society and for communicating to members. Where possible, alternative communication platforms will be used to reduce the use of paper. The printing of documents by colleagues will be contained at a minimum level and avoided whenever possible.

Waste reduction and disposal

We will continue to reduce the amount of waste we produce, and reuse and recycle where possible.

Supplier and contractor relationships

Supplier due diligence was introduced to include clear oversight of their approach to sustainability as part of Head Office development and we will look to embed further with other supplier relationships going forward.

Members

We are committed to working with the wider community to further benefit environmental impact locally.

Colleagues

We will engage with colleagues across the business to raise awareness of how they can positively impact our environment both in the office and whilst working from home.

Legislative and regulatory requirements

We will act in an environmentally responsible manner, meeting or exceeding relevant UK and European legislative and regulatory requirements.

Environmental management

We will incorporate environmental factors into business decisions as we embed the principals of ESG. We will commit to the continuous improvement of our environmental management and performance. This Policy, and the actions it commits to, is the responsibility of the Society’s Board, with the Chief Executive taking lead responsibility.

This Policy will be reviewed annually to ensure that it is up-to-date and to measure the Society’s compliance with it.

Explanatory Notes: BCORP Certified B Corporations are leaders in the global movement for an inclusive, equitable, and regenerative economy and are unique in that they measure a company’s entire social and environmental impact.

Carbon Neutral definition

A company is carbon neutral if they balance the carbon dioxide they release into the atmosphere through their everyday activities with the amount they absorb or remove from the atmosphere. This is most commonly achieved through the purchase of carbon offsets.

Net Zero definition

Working to achieve a target of completely negating the amount of greenhouse gases produced by business activities, to be achieved by reducing emissions and implementing methods of absorbing carbon dioxide from the atmosphere. For emissions levels that remain, they may still be negated through the purchase of carbon offsets.

Tim Neal Head of Footprint
July 2024