Modern Slavery Transparency Statement 2017-18
Post Office Limited (POL) and Post Office Management Services Limited (trading as ‘Post Office Insurance’) (’POI’).
This statement is made pursuant to section 54(1) of the Act. It sets out the steps taken by Post Office and POI during year ending 31 March 2018 to prevent modern slavery and human trafficking in its business and supply chains.
Post Office and POI 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.
While this is only the second statement in which we report on our efforts to prevent modern slavery in line with the requirements of the Act, we have been focused 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 2017/18 financial year to further 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 more than 170 products and services Post Office directly manages around 2% of the Network branches. The remainder of the branches are managed on an agency basis by Postmasters and multiple partners. We operate throughout the UK, however our supply chains connect with suppliers with a global reach.
Post Office banking services are provided in Post Office branches on behalf of the customers of UK banks.
Postmasters can operate one or more branches. As agents they have control over how their branches are run on a day-to-day basis. All those working in an agency Post Office branch are employed directly by the Postmaster. The Postmaster is self-employed and typically takes on a Post Office as an adjunct to their own retail business.
We have guidance and contractual standards for postmasters which can be viewed here.
A proportion of the agency part of our network is run by multiple partners – corporate retail organisations who themselves have a multiple number of high street stores, some with Post Offices.
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 wide range of suppliers, ranging from small and medium enterprises to large multinationals, each one of which has its own supply chain. The majority of the purchasing is controlled centrally by the Procurement team who also set the Supplier Relationship Management standards to ensure that our teams maintain a consistent approach to supplier management across Post Office.
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.
We operate a number of policies to ensure that 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 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.
We operate a Whistleblowing Policy so that all 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.
Our recruitment policy 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/POI 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. Additionally our supplier pre-qualification process requests information from potential suppliers to assess their suitability as a supplier and provide evidence of their compliance with 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/POI
Post Office understands that our third party supply chains carry with it the risk of modern slavery and human trafficking.
The assessment we have undertaken so far indicates that there could be a risk of non-compliance within our agency network as there are a large number of people employed by Postmasters (including multiple partners) who are not employees of Post Office or POI. They work directly for the Postmasters. During 2017 we reviewed the Postmaster Contract of Engagement and have written Guidelines to assist them in complying with MSA legislation. These guidelines were issued December 2017.
We have established 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.
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 2017 statement||Progress on 2017 proposals|
|Update Postmaster selection and appointment process to address MSA requirements.||We reviewed the Postmaster contract and believe it is robust enough to cover the Act. We also supplemented the contract process with a set of Guidelines for Postmasters.|
|Amend our standard form procurement contracts.||We reviewed our standard form procurement contracts and believe our ‘applicable laws’ clause covers POL for breaches of MSA. Our PQQ process has also been amended to take account of MSA and suppliers must confirm that they comply with their obligations under the MSA and provide a copy of their MSA Statement.|
|Develop a communication plan to ensure our suppliers, staff and agents are aware of Post Office’s obligations in relation to Modern Slavery and informing them about the Modern Slavery Helpline.||We sent multiple communications regarding Modern Slavery during 2017/18, including communications to Postmasters.|
|Review of audit and compliance, to develop a relevant Training Plan.||We reviewed our standard form procurement contracts and believe our ‘applicable laws’ clause covers POL for breaches of MSA. Our PQQ process has also been amended to take account of MSA and suppliers must confirm that they comply with their obligations under the MSA and provide a copy of their MSA Statement.|
WHAT COMMITMENTS ARE WE MAKING TO TACKLE MODERN SLAVERY IN THE YEAR AHEAD
As part of our initiative to identify and mitigate risk throughout 2018/19 we are committed to:
§ Improve the due diligence assessment for onboarding new suppliers to our systems
§ Review our supply base and revise our supplier management processes
§ Raise awareness of Modern Slavery across our supply base
§ Raise awareness of Modern Slavery across Post Office, its suppliers and within the agency network.
§ Educate field teams out in the agency network on spotting signs of Modern Slavery.
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: firstname.lastname@example.org 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.
This statement shall be reviewed and published annually.
This statement was approved by the Post Office Board and POI Board of Directors on 25 September 2018.
Interim Chief Executive Officer