Modern Slavery Transparency Statement 2019-20

MODERN SLAVERY ACT TRANSPARENCY STATEMENT 2019/20

Post Office Limited (Post Office) & Post Office Management Services Limited (POMS).

This statement is made pursuant to section 54(1) of the Act. It sets out the steps taken by Post Office & POMS during year ending 31st March 2019 to mitigate the risks of modern slavery and human trafficking in its business and supply chains.

Post Office and POMS are committed to combating the risk of modern slavery or human trafficking in our supply chain and business operations. We are committed to taking appropriate steps to ensure that everyone who works for Post Office in any capacity, benefits from a working environment in which their fundamental rights and freedoms are respected.

This is the third statement in which we report on our efforts to mitigate the risks of modern slavery in line with the requirements of the Act.  Our history has seen us focus on the rights and wellbeing of the people who work for Post Office and for our suppliers for many years. Our statement provides details of our policies, our approach and the actions we have taken in the 2018/19 financial year to strengthen our programme and commitment to respect and uphold people’s fundamental rights and freedoms.

 

OUR BUSINESS AND SUPPLY CHAIN

Post Office is the UK’s largest retail network and the largest financial services chain in the UK. We have provided services for more than 370 years and currently supply a range of essential products and services to communities right across the UK.

Our UK Government mandate is to provide at least 11,500 Post Offices, some within certain geographical, demographic and social criteria that provide a unique operational challenge for Post Office compared to other wholly commercial retail or financial institutions.  We are often at the heart of the local communities, some of which can be challenging environments to operate in.

Post Office directly controls around 2% of the Network of branches which consumers will generally recognise as the larger branches often situated in the centre of towns and cities across the UK. The remainder of the branches are managed on an agency basis by independent small retailers and shop owners operating Post Office services within their own store. Business owners may own more than one shop operating Post Office services and have a range of other non connected business interests. We also have agent managed facilities within some larger high street commercial partners, who like the smaller independent retailers, provide their own trained and friendly staff to provide our Post Office services to consumers.

Banking services

Post Office banking services are provided in Post Office branches on behalf of the customers of UK banks.

Postmasters

Postmasters can operate one or more branches. As agent’s they have full control over how their branches within their retail premises are run on a daily basis. All those working in an agency Post Office branch are employed directly by the retailer. The Retailer is self-employed and typically takes on a Post Office as a valuable community service provided within their own retail business. Post office has no direct control over the operation of these independent SME businesses but does have the ability to influence and inform.  Post Office aims to support Postmasters with their Post Office operations and influence their behaviours.               

Commercial partners

A large proportion of the agency network is managed by commercial partners – corporate retail organisations with familiar fascia brands who themselves have a multiple number of high street stores.

Trade Unions

In our directly managed branch network, we work closely with the Communications Workers Union (CWU) and Unite (CMA) Communications Managers Association.

Third Party Suppliers

We also procure products and services from a range of managed suppliers, ranging from small and medium enterprises to large multinationals. Purchasing for our own managed Post Office’s is controlled centrally by the Procurement team who also set the Supplier Relationship Management standards to ensure our teams maintain a consistent approach to supplier management.

 

OUR BELIEFS AND PRINCIPLES

Respect for the dignity of the individual and the importance of each individual’s human rights form the basis of the behaviours we expect in every workplace and are communicated through our Code of Business Standards. We will not accept any form of discrimination, bullying or harassment. We require all our managers to implement policies designed to ensure equality of opportunity and inclusion for all Post Office employees.

 

OUR POLICIES

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

 

CODE OF BUSINESS STANDARDS

We have a Code of Business Standards which underpins everything we do. The Code is mandatory and extends to everyone directly employed by Post Office. It requires all of us to act ethically and comply with legal requirements at all times, putting our principles into practice in everything we do. The Code of Business Standards was updated during the 2017 financial year to include references to Modern Slavery.

 

WHISTLEBLOWING

We operate a Whistleblowing Policy so that all Post Office employees know how to raise concerns regarding wrongdoing or dangerous practices. The policy was updated during the 2017 financial year to include references to concerns about Modern Slavery.

There are a number of ways people can report any concerns regarding slavery or human trafficking within Post Office, by either contacting the Whistleblowing Officer or via our anonymous external confidential reporting service ‘Speak Up’ which is regularly communicated to all employees, suppliers and contractors. This is overseen by our General Counsel (Whistleblowing Officer). Every report submitted is assessed and investigated.

 

RECRUITMENT & ONBOARDING POLICY

Our recruitment and onboarding policy for Post Office employees sets out the overarching principles and controls to be followed and applied to ensure that personnel resourcing is conducted in a fair, open and transparent manner, including conducting eligibility to work in the UK checks for all employees.

 

DUE DILLIGENCE PROCEDURES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING IN OUR BUSINESS AND SUPPLY CHAIN.

Post Office/POMS employs solely within the UK.

Our recruitment procedures ensure that all prospective employees are legally entitled to work in the UK. All successful applicants must produce, on their first day, one of the following: their original passport, driving license or birth certificate. Additionally, to comply with the Asylum and Immigration Act 1996 requirements, if they are from a non-European Economic Area (EEA) country, evidence of a right to reside and work in the UK must be produced.

We carry out reasonable and practical due diligence in the sourcing of goods and services and ensuring that the Act's obligations form part of the procurement process. As part of this process we have conducted a review of the criteria used by Post Office to evaluate whether suppliers meet Post Office’s minimum tendering requirements. We have also reviewed our standard form procurement contracts to ensure that they make explicit reference to the Act, as well as covering other areas of company information, policies and procedures. This enables the procurement team to assist Business Units to identify and assess any potential risks relating to the goods or services being procured.

 

IDENTIFYING, ASSESSING AND MANAGING RISK

WHERE ARE THE RISKS OF MODERN SLAVERY AT POST OFFICE/POMS?

Post Office understands that our procurement of goods and services from third parties carry with it the risk of modern slavery and human trafficking.

We understand that a potential for risk of modern slavery sits within our agency network as there are a large number of people employed by independent retailers acting as Postmasters (including commercial partners) who are not direct employees of Post Office or POMS.

 

GOVERNANCE

We have a cross-functional steering group through which we develop and coordinate our approach to addressing modern slavery risks within our operations and supply chain. This group consists of expertise from the legal, procurement, compliance and operational functions in Post Office.

 

TRAINING

We provide annual Compliance Awareness Training to all our employees and postmasters, which is tailored to ensure an appropriate level of understanding of issues such as modern slavery and the Act's requirements.

 

WHAT DID WE DO THIS YEAR?

Proposals from 2018 Statement Progress on 2018 proposals
Improve the due diligence assessment for onboarding new suppliers to our systems We carried out a detailed assessment of our new supplier on-boarding process and identified a number of recommendations which will help ensure a robust assessment of new suppliers and their ways of working. 
Review our supply base and revise our supplier management processes

We have designed an enhanced process and detailed content to be included in new system described above.

Our CSR questionnaire is being trialled with a small cross section of suppliers, to test, review and make improvements to the question format, evaluation process and feedback/ improvement plan.

We have aligned this with Post Office Compliance and Audit functions who conduct physical audits of Supply Chain suppliers.  This ensures maximum benefit from our efforts and no duplication, or overburdening of the suppliers.

Raise awareness of Modern Slavery across our supply base  

We created our Supplier Code of Conduct and published it on our public website.

http://corporate.postoffice.co.uk/our-suppliers

This Code of Conduct is used in the on-boarding process and other procurement exercises.

Depending on the outcomes of the CSR questionnaire, we will devise additional awareness material as appropriate and distribute to our suppliers proactively.

Raise awareness of Modern Slavery across Post Office, its suppliers and within the agency network. We issued guidance and Modern Slavery awareness raising material for Postmasters through our branch Network management teams and communication channels. 
Educate field teams out in the agency network on spotting signs of Modern Slavery. We sourced best practice training and awareness materials from suppliers and developed it to align and resonate with our Branch network management field teams.  We will start to roll this training out to frontline staff.

WHAT COMMITMENTS ARE WE MAKING TO TACKLE MODERN SLAVERY IN THE YEAR AHEAD?

- As part of our initiative to identify and mitigate risk throughout 2019/20 we are committed to:

- Implement our new IT system to track and monitor the on-boarding of new suppliers, ensuring a robust assessment and oversight of their ways of working and risk profile around Modern Slavery. 

- Review our supply base retrospectively by applying the focus of our new IT tracking system.

- Raise awareness of Modern Slavery across our existing suppliers where they are found to be lacking focus.

- Continue to raise awareness of Modern Slavery across Post Office branch network across both directly managed and agency branches.

- Deploy specific MS awareness training to our field teams to enable them to robustly spot signs of Modern Slavery.

- Review the guidance given to Postmasters to ensure alignment with wider business activity and network support teams.

 

REMEDIATION PROCESSES

If you have any concerns about the issues raised in this statement or if you think you have identified signs of Modern Slavery then please contact us on the below contacts:

- Post Office’s Whistleblowing Officer: whistleblowing@postoffice.co.uk or by telephone on: 07900 216851.

- The Government’s Modern Slavery Helpline on 0800 0121 700.

 

We encourage any individual who has concerns about unethical behaviour in any part of our business or operations to speak up and to do so without fear of retaliation. We will review all instances of non-compliance, on a case-by-case basis and will implement appropriate remedial action.

 

REVIEW

This statement shall be reviewed and published annually.

 

Alistair Cameron
Interim Chief Executive Officer