Modern Slavery

Slavery and Human Trafficking Statement for the financial year 2023/24

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 our business or supply chain.  We issued our first such statement seven 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.

Our business

The 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.  Our purpose is ‘Through the power of co-operation, we’re building a fairer, more sustainable, and ethical future.’

We have four core values that underpin our Purpose and guide the way we work:

We operate a range of businesses in Food, Travel, Childcare, Energy, Telecoms, Post Offices and Flexible Benefits. The profits we make allow us to support the communities we serve. 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, Telecoms and Flexible Benefits businesses trade across the UK.

Our high risk areas

We continue to take steps to ensure that we understand the areas of our Society and supply chain in which there may be a greater risk of modern slavery being present.  Work has been ongoing throughout the year with our suppliers to ensure that our terms and conditions/contracts take into account ethics and modern slavery, and we continue to engage with our suppliers to further understand and discuss those risks.  

We issue our suppliers with the following documents through our contract management process:

• Ethical code of conduct

• Copy of our Modern Slavery Statement

As part of our due diligence processes and checks, 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 have a robust contract management process in place, ensuring that all contract managers take responsibility for engaging suppliers in our ethical code of conduct and modern slavery statement. 

Our policies

We operate a number of internal policies to ensure we are conducting business in an ethical and transparent manner.  These include:

1. 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.

2. 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.

3. 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.

4. Code of business conduct. This code explains how we behave as an organisation and how we expect our Colleagues and suppliers to act.

5. 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. 

6. Ethical Co-operative Policy for business activities: Ensuring that our Trading Groups follow the letter and spirit of our ethical values when making business decisions including procurement, supplier engagement, and any business developments. Within this policy we emphasise our commitment to ensuring that the people and communities providing the products and services we buy and sell are treated fairly, and that their fundamental human rights are protected and respected.

7. Purchasing Policy: Ensuring the Society and every individual involved in purchasing, procurement and supply management processes within the Society, use their best endeavours to ensure that our purchasing and contracting activities are ethical, socially responsible and sustainable, and consistent with and in support of our Supplier Code. Through this policy our Society is committed to buying from reputable suppliers who meet and promote ethical trading standards and behaviours throughout its supply chain.

We have independent and confidential services such as an Employee Assistance Programme, offering a free confidential helpline service that is available to colleagues so they can talk to professionals on any personal, home or work related issues.  We also have a partnership in place 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.

Our Suppliers

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 3,200 supplier sites are covered, comprising almost 900,000 workers across six continents and over 60 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, over the last year 1,513 suppliers were engaged, reaching over 6,400 delegates.

A further example through FRTS is our support of Fairtrade. We have championed the Fairtrade movement since 1994, supporting trade justice through better prices, working conditions and terms of trade. As a co-operative, we have supported Fairtrade suppliers all over the world to make an impact by improving livelihoods and the environment. From launching the world’s first own-label Fairtrade product in 2000, to more recently making an industry-first commitment in 2022 to source 100% of our South African wine as Fairtrade, we are dedicated supporters of the movement.  We will continue to support suppliers all over the world through our support of the Fairtrade Mark, helping workers and farmers to improve their social, economic and environmental conditions.     

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 local supplier range in our Food Retail business. 

We continue to carry out audit and risk assessments on our local supplier processes, ensuring that our local suppliers adhere to our ethical code of conduct and relevant employment legislation.

A further example outside of FRTS includes our overseas suppliers through Co-op Holidays, in which we are working with almost 50 partners worldwide, offering us around 190 direct Hotels and Tours.  We ensure that these suppliers follow our robust contracts management process, ensuring their adherence to all related Midcounties’ polices, including Modern Slavery, and ensuring that our contract managers take responsibility for engaging suppliers in our ethical code of conduct and modern slavery statement.

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.

We operate our contract management process, which includes an electronic contract management database that is used by our Procurement and Legal colleagues, and the relevant contract managers working for our Society.  The system allows us to hold all our contracts in a centralised place, so we have better visibility of both the suppliers’ and our Society’s obligations under each contract. 

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

• 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.

We will continue to raise awareness of Modern Slavery during the coming year. 

Employment  

We were one of the first organisations to join Bright Future Co-operative as a business member. The co-operative was formed in 2020 to bring charities and businesses together to create stable employment for survivors 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, and potentially a permanent role.   

Bright Future Co-op now has over 30 members, either as referral partners or as business members from across different sectors, collaborating to offer employment and support to survivors of Modern Slavery. Members who have joined during the year include Morrisons, ALDI & Heart of England Co-op, as well as fresh food manufacturer Bakkavor & Speedy Services, the provider of equipment hire for the construction industry. To date over 85 people have found stable work through Bright Future Co-op. 

To further develop opportunities, Bright Future Co-op launched a new online platform during the year, enabling greater visibility of employment opportunities suitable for survivors of Modern Slavery, thus ensuring referrer members have easy access to the most up to up to date information to discuss with candidates.

The Society’s Chief Values Officer has been chair of Bright Future Co-op since launch and the Society’s Head of Legal Services is Secretary of that Society.

Through our Society’s Sustainability strategy, 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 are one of a range of businesses that complete Business in the Community’s annual Responsible Business Tracker. This year we were one of highest scoring businesses with a score of 87%, improved from 81% the previous year, and above the cohort average of 48%.  

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.

Our Society’s Sustainability Steering Group is in place to monitor progress and support the achievement of our sustainability activity, including our ‘Fairer’ strand which includes our activity around supporting vulnerable members of the community into employment linked to our Bright Future Co-op partnership.   

Action

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.

Review

An annual review of commitments made in this statement is undertaken by the Society to ensure due diligence. Specific measures we have taken include:

• Direct Suppliers: continue to engage our suppliers in our Ethical Code of Conduct, to confirm their adherence to all related Midcounties’ polices, including Modern Slavery, and following our contract management process, ensuring that all contract managers take responsibility for engaging suppliers in our ethical code of conduct and modern slavery statement.

• Suppliers through FRTS: continue to engage suppliers in the Sound Sourcing Code of Conduct (SSC) through our cooperative buying group (FRTS), setting out the workplace and employment standards that we expect of our suppliers, based on the Ethical Trading Initiative Base Code and core international labour standards.   

• 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.

• Supporting Fairtrade: through FRTS continue to champion the Fairtrade Mark and support Fairtrade suppliers all over the world, helping workers and farmers to improve their social, economic and environmental conditions.    

• 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 people supported through the Bright Future Co-operative, supporting those who have been rescued from Modern Slavery back into the workplace

• Policies: ongoing 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 27/07/2024.

Heather Richardson

President