Modern Slavery Statement

Introduction

This statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 (“The Act”) and sets out the steps that Saffron Building Society (“the Society”) together with its subsidiary and associated companies have taken to ensure that slavery and human trafficking are not taking place in its supply chains or any parts of its business.

The “Society” has zero-tolerance to any kind of modern slavery within its business and recognises that it has a responsibility to be aware of the risks, however small, in our business and wider supply chain. Colleagues are encouraged to report concerns, using appropriate reporting channels and management are expected to act upon them.

Purpose and Objectives

The purpose of the Policy is to set out the steps that Saffron Building Society (“the Society”) together with its subsidiary and associated companies have taken to ensure that slavery and human trafficking are not taking place in its supply chains or any parts of its business.

Scope

This policy applies to the Saffron Building Society group.

Framework

Policy Level

This policy is Level One and will be reviewed and approved at least annually

Approval Body

This policy is approved by the Board and will be subject to review and recommendation from the Executive Committee.

Statement

Our Business

The Society consists of Saffron Building Society and one subsidiary company: Crocus Homes Limited. The Society has nine branches and employs in excess of 200 staff..

Serving our communities has been rooted at the core of the Society for over 170 years. Whilst our community has grown to include Members across the country, our sense of responsibility and connection is unchanged. We are here to serve and protect our community and help to ensure that it thrives.

Our vision is to help our Members to achieve financial happiness and we aim to achieve this by providing easy to understand, competitive savings and lending products to the retail market supported by first rate service. In addition to serving our Members we are also proactive in our wider communities, who we support through our wider program of Environmental, Social and Governance activities under our program “For Years to Come”.

Responsibilities

The Board of Directors has overall responsibility for ensuring that the Society complies with all legal and ethical obligations regarding modern slavery, and that in turn all colleagues comply with these obligations.

Supply Chain Risk

The Society operates within the financial services sector and is not typically associated with sectors recognised as having the highest inherent modern slavery risk. However, the Society recognises that modern slavery can occur across all industries and that risk may arise through the procurement of goods and services, including where suppliers operate extended or international supply chains or rely on subcontracting arrangements.

Potential areas of risk for the Society include, but are not limited to, information technology and digital services, facilities management, construction and maintenance, cleaning and security services, and other outsourced or third‑party arrangements. The Society also recognises that its visibility is strongest at tier‑one supplier level, with reduced transparency further down the supply chain.

Modern slavery risk within the Society’s supply chain is managed through the Third Party Management Framework and overseen through established governance arrangements. Supplier risk is assessed at onboarding and reviewed on a proportionate basis throughout the lifecycle of the relationship. Where enhanced due diligence is required, this is undertaken in line with the Society’s risk‑based approach.[RS1] 

To gain assurance that the likelihood of modern slavery within the Society’s business and supply chain is low, the Society undertakes proportionate due diligence at supplier onboarding and throughout the lifecycle of third‑party relationships. This includes assessing suppliers based on the nature of the goods or services provided, jurisdiction of operation, use of subcontracting, and workforce profile.

The Society requires relevant suppliers to confirm compliance with applicable modern slavery legislation, provide copies of published Modern Slavery Statements where legally required, and confirm the existence of appropriate policies, controls and training within their own organisations. Standard contractual clauses are used to set clear expectations in relation to modern slavery and human trafficking, including notification and remediation requirements.

Risk assessments and due diligence outcomes are reviewed as part of the Society’s Third Party Management Framework, with enhanced scrutiny applied where higher inherent risk indicators are identified. This structured approach enables the Society to identify, assess and manage modern slavery risk on an informed and proportionate basis and provides ongoing assurance over supplier compliance.

The Society is committed to ensuring that modern slavery and human trafficking do not take place in any part of its business or extended supply chain and expects its suppliers and partners to operate to the same standards. The Society assesses potential suppliers’ modern slavery risk and controls prior to contracting, to ensure alignment with its expectations and ethical standards.

Third‑party contracts include clauses addressing modern slavery, and the Society monitors supplier compliance with contractual and ethical requirements. This includes requiring suppliers to conduct appropriate modern slavery risk profiling within their own supply chains, implement proportionate controls, and notify the Society promptly should any incidents or concerns be identified.

Where potential modern slavery risks or concerns are identified, these are escalated appropriately, and suppliers are expected to take timely remedial action. The Society may increase monitoring, require corrective actions, or reconsider the relationship where concerns cannot be adequately addressed.

Where suppliers are required by law to publish a Modern Slavery Statement, the Society retains a copy as part of its onboarding and due diligence processes and will not engage with a supplier that fails to meet this requirement.

Where the Society outsources functions, due diligence is undertaken on all outsourcing partners to assess the robustness of arrangements. This is documented and managed in accordance with the Third Party Management Policy and supporting framework.

Colleagues are encouraged to report any suspicion of modern slavery or human trafficking through the Society’s Whistleblowing Process, which is designed to provide protection and support for colleagues making disclosures in good faith. This process offers a confidential and independent reporting route, with concerns investigated and addressed appropriately.

The Society provides regular modern slavery awareness training to colleagues, with a particular focus on roles involved in procurement, supplier management and outsourcing oversight. Training is refreshed periodically and is designed to support early identification of risk and reinforce reporting routes, including the Whistleblowing Process.

The Society regularly reviews the effectiveness of its policies and processes to prevent modern slavery and human trafficking and tracks progress against previously identified actions. During 2025, this included further enhancement of third‑party due diligence processes and refreshed training materials. The Society will continue to keep its approach under review and take proportionate steps to strengthen controls where appropriate.

Monitoring and Effectiveness 

The Society monitors the effectiveness of its approach to preventing modern slavery through a combination of supplier due diligence processes, contractual controls, and governance oversight. Modern slavery considerations form part of third‑party onboarding, periodic review activity and escalation processes where concerns are identified.

Oversight of modern slavery risk is maintained through senior management governance and Board approval of this statement. Where no modern slavery incidents are identified, this is considered in the context of the Society’s risk profile and ongoing assurance activity rather than as an indication that risk does not exist.

Training

We provide regular training to all our colleagues to ensure that a good level of understanding of the risks of modern slavery and human trafficking is maintained.

Further Steps

The Society has conducted a review of the effectiveness of our policies and processes to prevent modern slavery and human trafficking in our business and extended supply chain. Following this review, we intend to take the following further steps:

• The Society remains committed to doing all that is reasonably can to contribute toward helping eradicate modern slavery and human trafficking and will keep policies and procedures under review.
• Conduct an annual review of modern slavery risk within the Society’s supply chain, informed by third‑party due diligence outcomes, supplier risk profiling and emerging external guidance.
• Maintain clear escalation and remediation routes where potential modern slavery risks or concerns are identified, including increased monitoring, corrective action or reconsideration of supplier relationships where necessary.