This statement is made pursuant to section 54(1) of the Act. It sets out the steps taken by Post Office, POMS & Payzone during year ending 31 March 2026 to mitigate the risks of modern slavery and human trafficking in its business and supply chains.
Modern Slavery Act Transparency Statement 2026/27
The statement includes Post Office Limited (POL) and Post Office Management Services Limited (POMS), which is 100% owned by POL. The statement covers the group activities aligned to the financial year running 1st April 2025 to 31st March 2026.
This statement is made pursuant to section 54(1) of the Act. It sets out the steps taken by POL and POMS during the year ending 31st March 2026 to mitigate the risks of modern slavery and human trafficking in its business, branch network and supply chains, and sets out our planned approach for 2026/27.
Commitment
Modern slavery is a crime and a violation of fundamental human rights, manifesting itself in forms such as slavery, servitude, forced labour and human trafficking. It deprives individuals of their freedom and dignity, often for personal or commercial gain.
We’re committed to ethical and responsible business practices and proactively work to prevent, identify and address modern slavery risks and embed respect for human rights at all levels of our business and supply chain. To do this, we continuously improve policies, enhance training, conduct due diligence and raise awareness amongst colleagues, partners and stakeholders.
We support and uphold respect for human rights enshrined in the UN Universal Declaration of Human Rights and the ILO Fundamental Conventions. We aim to approach human rights in line with the UN Guiding Principles on Business and Human Rights (“UNGPs”) and the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Business Conduct (“OECD Guidelines”).
Leadership and 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, corporate affairs and operational functions in POL. The outputs of the Modern Slavery Steer Co, including review of the Modern Slavery Statement, are fed into the Executive Committee and subsequently the Audit, Risk and Compliance Committee, a Board-level committee.
In 2025/26, modern slavery and human rights were discussed at each committee once. The business made a commitment to strengthen governance around modern slavery and human rights and conduct a benchmarking analysis, as we recognise that there are areas that need to be strengthened.
Structure, Business and Supply Chain
POL provides a range of essential products and services to communities across the UK. POL provides cash services, mail and parcel services, travel, bill payment services and life and general insurance policy cover, offered through POMS.
POL’s UK Government mandate is to provide at least 11,500 Post Offices, some within certain geographical, demographic and social criteria that present a unique operational challenge for POL compared with other wholly commercial retail or financial institutions.
Post Office branches are operated by independent retailers and business owners who provide Post Office services from their own premises under contractual arrangements with POL. 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 corporate partners, who, like smaller independent retailers, provide their own trained staff to deliver our services to customers. Although POL does not employ branch staff or manage their day-to-day retail operations, it retains contractual and operational mechanisms through which it sets and monitors requirements relating to the delivery of Post Office services.
Postmasters
Postmasters can operate one or more branches. They have control over how the branches within their retail premises are run daily. All those working in a Post Office branch are employed directly by the self-employed postmaster. POL has no day-to-day control over the operation of these independent SME businesses but does have the ability to support and inform through onboarding training, compliance training and branch performance checks.
Corporate Partners
A large proportion of the branch network is managed by corporate partners, which are corporate retail organisations with familiar brands that have a number of high street stores.
Trade Unions
We work closely with the Communication Workers Union (CWU) and Unite Communication Managers Association (CMA), through which communication channels are provided for employee engagement and feedback.
National Federation of SubPostmasters
Postmasters are represented by the National Federation of SubPostmasters (NFSP). This group provides a mechanism for feedback.
Third-Party Suppliers
We procure products and services from a range of managed suppliers, ranging from small and medium-sized enterprises to large multinationals. For example, purchasing office equipment and furniture for fitting out and refreshing branch infrastructure is controlled centrally by the POL Procurement team. The team also sets Supplier Relationship Management standards to ensure our teams maintain a consistent approach to supplier management.
Our Supplier Code of Conduct outlines our expectations of suppliers and the action they should take to prevent modern slavery.
Our Policies and Processes
We operate several policies to ensure we conduct business in an ethical and transparent manner. These include:
1. Code of Business Conduct
Our Code of Business Conduct is a centrepiece of our ethical culture. It sets out what we stand for, the principles to which we hold ourselves accountable and our expectations for how we act and make decisions.
Our Code of Business Conduct applies to employees, directors, contractors, business partners and retail partners working for and with POL and POMS. Our Code is reviewed every three years, and any modifications are approved by the POL Executive Committee and Board.
Respect for the dignity of the individual and the importance of individual human rights form the basis of the behaviours we expect in every workplace and are communicated through our Code of Business Conduct. We will not accept any form of discrimination, bullying or harassment.
We require all our managers to implement and adhere to policies designed to ensure equality of opportunity and inclusion for all POL and POMS employees. We provide a range of resources and training for managers and employees to support this and engage with employee networks to gain additional input on best practice.
Our Code is available on the Post Office Corporate website and internal intranet pages. It is provided to new hires during onboarding and linked from many of our company policies.
Our Code was updated in 2018 to include a dedicated section on modern slavery. Following a review in July 2024, our Code was endorsed by the Institute of Business Ethics. The Code is available here.
2. Our Supplier Code of Conduct
Our Supplier Code of Conduct outlines our expectations of suppliers in relation to modern slavery. Suppliers should:
- Ensure all UK workers receive the minimum wage and undergo robust immigration checks.
- Map supply chains to identify where there is the highest risk of and exposure to modern slavery.
- Undertake site inspections.
- Provide training to employees and local suppliers on modern slavery risks and compliance.
- Review supplier contracts to include obligations to comply with the Modern Slavery Act 2015.
- Prepare a statement outlining the steps they are taking to tackle modern slavery and publish it if required to do so by the Act.
3. Supplier Onboarding
Our supplier onboarding process requires all applicable suppliers to provide information to POL on modern slavery. This includes supply chain mapping of high-risk areas for modern slavery, developing a strategy to address modern slavery risks in their business and supply chain, undertaking modern slavery training, whistleblowing and remediation.
4. Recruitment and Onboarding Policy
Our Recruitment and Onboarding Policy for employees sets out the overarching principles and controls to be followed and applied to ensure personnel resourcing is conducted in a fair, open and transparent manner. This includes conducting eligibility-to-work checks for all employees in the UK.
Risk Assessment
POL understands that areas of our supplier base involving goods and services from third parties carry a greater risk of modern slavery and human trafficking.
We understand that a potential risk of modern slavery exists within our branch network, as many people are employed by or engaged as independent retailers acting as postmasters, officers in charge or assistants, including corporate partners, who are not direct employees of POL or POMS.
Due Diligence Procedures in Relation to Slavery and Human Trafficking in Our Business and Supply Chain
POL and POMS employ solely within the UK and undertake a range of due diligence steps relating to employment and the sourcing of goods and services.
Our recruitment procedures ensure that all prospective employees are legally entitled to work in the UK. All successful applicants must produce one of the following: their original passport, driving licence or birth certificate. Additionally, to comply with the requirements of the Asylum and Immigration Act 1996, applicants from a non-European Economic Area country must produce evidence of their right to reside and work in the UK.
We carry out reasonable and practical due diligence in the sourcing of goods and services and ensure that the Act’s obligations form part of the procurement process. As part of this, we have conducted a review of the criteria used by POL to evaluate whether suppliers meet POL’s minimum tendering requirements.
Our standard supplier contract templates have been updated and include explicit wording on modern slavery and human trafficking. This enables the Procurement team to assist business units in identifying and assessing potential risks relating to the goods or services being procured.
Contracts using our terms and conditions allow us to audit our suppliers at any time if we are concerned about modern slavery risks.
Whistleblowing
All POL colleagues, postmasters and partners are made aware of how to raise concerns regarding wrongdoing or dangerous practices through mandatory training and communications. This includes references to concerns about modern slavery.
There are several ways people can report concerns regarding slavery or human trafficking within POL. People can contact the independent Speak Up Team directly or use our confidential reporting service, which is operated by the independent company Unseen on behalf of POL.
This is regularly communicated to employees, postmasters, suppliers and contractors and is overseen by our Speak Up Team. Every report submitted is assessed and investigated.
In June 2026, POL ran communications around National Whistleblowing Awareness Month to raise awareness of the Speak Up Policy and process.
Training
We provide annual Compliance Awareness Training to all our employees and awareness courses to our postmasters. Both are tailored to ensure everyone is able to identify signs of potential modern slavery or human trafficking within our network and report them in line with our moral obligations and company policies.
For employees, this training is mandatory and forms part of our performance management process.
What Did We Do This Year?
We reviewed the mandatory annual Modern Slavery Awareness Training to ensure that all employees can robustly identify signs of modern slavery. We also increased our communications to postmasters and employees to help them recognise the signs of modern slavery and understand how to report it.
Progress Against Previous Years
| Theme | 2022/23 | 2023/24 | 2024/25 | 2025/26 |
|---|---|---|---|---|
| Policies and governance | Drafted a Modern Slavery and Human Trafficking Policy to support business processes and underpin the Modern Slavery Statement. | |||
| Due diligence | Began surveys of our key suppliers. | Continued surveys with lower-risk suppliers. | We planned to incorporate a question on modern slavery into our supplier ESG survey. | |
| Monitoring effectiveness | Across all years of our modern slavery work we have engaged with our Network team to provide relevant support around monitoring for modern slavery beyond the training programme we provide. | Across all years of our modern slavery work we have engaged with our Network team to provide relevant support around monitoring for modern slavery beyond the training programme we provide. | Across all years of our modern slavery work we have engaged with our Network team to provide relevant support around monitoring for modern slavery beyond the training programme we provide. | We engaged with our Network team to provide relevant support around monitoring for modern slavery beyond the training programme we provide. |
| Grievance and remedy | Reviewed the modern slavery investigation process to ensure that Post Office teams are supported if they identify signs of possible modern slavery and that the most appropriate escalation points are in place. | |||
| Training | Launched training in 2022/23 for all employees as part of the annual compliance calendar and have continued to roll this out every year since. | In 2023/24 we added a version of the training aimed at postmasters and added this to our onboarding training. | Moved the training calendar to align with Anti‑Slavery Day to enable us to gain greater traction and be more topical. | Again aligned training with Anti‑Slavery Day to enable us to gain greater traction and be more topical. |
| Communications | Across all years of our modern slavery work we have communicated with colleagues and our network, latterly building in case studies to reflect the real-world impact of this issue. | Across all years of our modern slavery work we have communicated with colleagues and our network, latterly building in case studies to reflect the real-world impact of this issue. | Across all years of our modern slavery work we have communicated with colleagues and our network, latterly building in case studies to reflect the real-world impact of this issue. | Across all years of our modern slavery work we have communicated with colleagues and our network, latterly building in case studies to reflect the real-world impact of this issue, including planned communications around National Whistleblowing Awareness Month to raise awareness of the Speak Up Policy and process. |
What Commitments Are We Making to Tackle Modern Slavery in the Year Ahead?
Policies and Governance
As part of POL’s ESG transformation programme, a review of POL’s approach to modern slavery and human rights will be undertaken to identify areas that need to be strengthened.
Risk Assessment
We will review modern slavery risks within key business functions to strengthen our approach.
Due Diligence
We will review and, where required, set out a roadmap to strengthen our due diligence processes in relation to modern slavery and human rights.
Training
We will track the percentage of employees undertaking modern slavery and human rights training and review the effectiveness of this training.
We will provide training and capacity building across different business functions in relation to modern slavery and human rights.
Communications
We will increase communications relating to modern slavery across stakeholder groups to improve awareness and understanding of the reporting processes.
Raising Concerns
POL provides a range of accessible and confidential channels for raising concerns around modern slavery and communicates these to relevant internal and external stakeholders.
- Post Office’s Speak Up Officer: speakup@postoffice.co.uk
- The Government’s Modern Slavery Helpline: 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 reports of non-compliance on a case-by-case basis, with remedial action taken where issues are substantiated.
Review
This statement shall be reviewed and published annually.
This statement has been reviewed and approved by the Board and signed by Neil Brocklehurst.
Neil Brocklehurst
Chief Executive
28 September 2026
Previous copies of our Modern Slavery Act Transparency Statement