Modern Slavery & Human Trafficking Statement

 

Introduction

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that London Community Credit Union has taken and will continue to take to ensure that modern slavery or human trafficking is not taking place within our organisation or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. London Community Credit Union 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.

As part of the Community Finance Sector the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Organisational structure and supply chains

London Community Credit Union is a community credit union which only operates in the UK. This statement covers the activities of London Community Credit Union (LCCU).

LCCU operates across six London Boroughs: Tower Hamlets, Hackney, Newham, Islington, Haringey, Waltham Forest and the City of London.
London Community Credit Union (LCCU) is owned and managed by its members, through our board of directors, and belongs to the local community.

Our product range includes affordable loans, current accounts, flexible savings accounts, free life saving and loan protection insurance and online and telephone banking services.

The organisation has identified no activities as high risk.

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing policy – Speak Up Speak Out

The organisation encourages all its workers and directors to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, directors or others who have concerns can use the Speak Up Speak Out policy.

Employee Code of Conduct

The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour.

Supplier/Procurement Code of Conduct

The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. LCCU maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier.

Recruitment/Agency Workers Policy

The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include an online search to ensure that a particular organisation has never been convicted of offences relating to modern slavery.

Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.

Training

We regularly conduct staff and director training and will include relevant material to raise awareness across the entire organisation about how to spot the signs of modern slavery and report them.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain when no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

This statement has been approved by the organisation’s board of directors, who will review and update it annually.