Modern Slavery and Human Trafficking Policy

Last Updated 21 Oct 2017 in Business Conduct

Overview

It is the responsibility of everyone working for the Society to help prevent and report slavery within our business or supply chain. The policy outlines what we can all do.

Key points covered:

The different forms modern slavery takes
How to report any concerns you have
Other relevant policies to refer to

1. Our Stance on Modern Slavery

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking. The Society has a zero tolerance approach to modern slavery and we are committed to safeguarding against the possibility of slavery or human trafficking taking place within the Society or our supply chain. Our modern slavery statement sets out the steps that we are taking to do this.

It is the responsibility of everyone working for The Midcounties Co-operative to support with the prevention, detection and reporting of modern slavery in any of our businesses or supply chain. You should avoid any activity that may lead to a breach of this Policy and should report any concerns immediately using the reporting procedure below.

2. Identification of Modern Slavery

Slavery: victims are deprived of their freedom and forced to work.
Servitude: victims are under an obligation to provide services through coercion
Human trafficking/ child trafficking: people are moved, often internationally, so that they can be exploited.
Forced Labour: people are forced to work against their will for little or no pay, often under the threat of violence to themselves or their families.
Debt bondage: victims work to pay off debts that they have no realistic chance of being able to clear.
Sexual exploitation: victims are forced to perform abusive and non-consensual sexual acts.

3. Reporting procedure

If you believe or suspect a breach of this Policy has occurred or that it may occur, you must report it immediately by speaking to your Line Manager, the Society Secretary & Head of Governance or via a confidential phone line 0800 458 7809 (further details can be found in the Whistleblowing Policy) You can also call the Modern Slavery Helpline for advice and guidance on 0800 0121 700.

You are encouraged to raise concerns about any issues or suspicion of modern slavery in any part of the Society or its supply chain at the earliest possible opportunity, provided that it is safe to do so. If you feel uncertain about any particular acts or treatment of individuals please speak to your Line Manager, a member of the HR Team or use SpeakInConfidence (https://speak2us.at/midcounties).

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of the Society or its supply chain.

4. Associated Policies and Procedures

We operate a number of internal policies, as noted below, to ensure that we are conducting business in an ethical and transparent manner. Also, to ensure all colleagues feel supported and safe in their working environment.

Whistleblowing Policy- we encourage you to make disclosure of any malpractice taking without fear of retaliation. You can use our confidential telephone line to make such disclosure. [Any disclosure in relation to modern slavery or human trafficking will be reported to the police for investigation.]

Code of Business Conduct- we are committed to obtain and maintain the highest level of ethical standards and this Policy sets out the Society’s expectations.

Supplier Ethical Code of Conduct: - we are committed to building fair and sustainable relationships with our suppliers in order to secure decent working conditions for everybody involved in the production of products for The Midcounties Co-operative. We recognise the essential contribution that our suppliers make in achieving our aims and aspirations for sound sourcing, and an ethical code of conduct is in place to ensure that our suppliers meet key criteria to achieve this.

Recruitment Policy/Joiners, movers and leavers processes- we have a robust Recruitment Policy and clear HR processes in place to ensure checking of eligibility to work in the UK to safeguard against forced work, human trafficking and modern slavery. Anyone that does not produce the correct documentation to show this eligibility will not be able to start or continue to work for the Society.

Diversity, Inclusion and Equality Policy Statement- We have a zero tolerance attitude to bullying, harassment or victimisation of any kind and seek to eliminate any conditions, procedures and behaviours that lead to discrimination.

5. Responsibility

The Board of Directors have overall responsibility for ensuring that the Policy complies with the Society’s ethical and legal obligations.

The prevention, detection and reporting of modern slavery in any part of The Society or supply chain is the responsibility of everyone working for the Society. You must avoid any activity that may lead to a breach of this Policy and should report any concerns immediately under the reporting procedure outlined in this Policy.

Our Society’s annual report, whilst not explicitly referring to modern slavery, outlines our approach to Social Responsibility. Social Responsibility is one of the Society’s four key values and an integral part of being a co-operative enterprise. The Society undertakes a number of actions to ensure it supports its local and global communities and the environment.

The Society produces a separate Social Responsibility Report which sets out our commitments, targets and achievements. A copy can be found on the ‘about us’ pages at www.midcounties.coop .

To ensure the Society continues to meet its social responsibility objectives the following member of the Executive has named responsibility:

Phil Ponsonby, Chief Executive Trading, holds overall accountability for social responsibility, including overall accountability for social responsibility in marketplace trading along with the other Trading Group General Managers. Most products in the Society’s food stores are sourced through Federal Retail and Trading Services Limited (FRTS) the federal purchasing body of the co-operative retail movement. The Society adheres to the buying guidelines adopted by FRTS.

Refer to page 34 of the Society’s 2016/2017 annual report for further details on the ‘about us’ pages at www.midcounties.coop .

Policy name:	Modern Slavery and Human Trafficking Policy	Date of last review:	October 2017
Policy owner:	PSG	Issue number:	PSG-MS-001