This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by DHD Group during year ending 31 December 2020 to prevent modern slavery and human trafficking in its business and its supply chains.
The DHD Group has a zero tolerance approach to modern slavery of any kind within our operation. We all have a responsibility to be aware of the risks, however small in our business and wider supply chain. Colleagues are expected to report concerns, using appropriate reporting channels and management are expected to act upon them.
The DHD Group consists of DHD and 2 key subsidiary companies. Newcastle Financial Advisers Limited and Newcastle Strategic Solutions Limited. The Society is the United Kingdom’s 8th largest building society and the largest building society in the North East of England. The DHD Group has 30 branches and employs in excess of 1,000 staff across its branch network and head office sites.
The DHD Group like all mutual organisations exists and functions for the benefit of its members, and
so core to our vision is being a trusted provider of family savings, mortgages and financial advice
delivered with good customer outcomes and great customer service.
In addition, our subsidiary company Newcastle Strategic Solutions Limited is dedicated to the
provision of outsourcing for financial services and provides system development and on-going
operational support to both itself and the Society.
The DHD Group’s board of directors has overall responsibility for ensuring our Modern Slavery and Human Trafficking policy complies with our legal and ethical obligations, and that all those under our control comply with it. All our colleagues must observe our policy on Anti-Slavery and Human Trafficking and be aware that turning a blind eye is unacceptable.
As the provider of financial services, the DHD Group is not in an industry with a high risk of modern
day slavery and is not part of a supply chain, however in delivering our services, we procure goods
and services from suppliers who do operate supply chains some of which are global. We have adopted a
risk based approach to reviewing our supply chains which may carry a higher risk; these supply
chains and suppliers which supply goods and/or services to us include:-
• IT and electronics manufacture including the disposal, dismantling and recycling stages;
• Marketing and promotional merchandise;
• Cleaning staff;
• Colleague uniform ssupplier
• Corporate hospitality
We manage these risk areas through our procedures set out in our Anti-Slavery and Human Trafficking
policy and elsewhere and we have not identified any evidenced reason to believe that slavery or
human trafficking exists in the above currently.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or
in any part of our business. Our Anti-Slavery and Human Trafficking policy reflects our commitment to
acting ethically and with integrity in all our business relationships and to implementing and enforcing
effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in
our supply chains.
Colleagues are able to report any suspicion of modern slavery or human trafficking under our
Whistleblowing policy. This policy is to protect and support colleagues who make a non-malicious
allegation in the best interests of the DHD Group, providing a confidential contact point and responding
in an appropriate manner.
Wherever possible we will seek to perform critical functions in-house and will only outsource functions
where such arrangements will avoid undue conduct risk, operational risk, and reputational risk. Where we
outsource functions, we perform due diligence on all outsourcing partners to satisfy ourselves of the
robustness of outsourcing arrangements. This is fully documented under our Procurement & Supplier
Management policy.
We tell companies we do business with that we are not prepared to accept any form of exploitation. Our
Contracts policy advises that no agreements should be entered into by the Society which breach any law
or regulation. The Contracts Policy also provides that any material contract must be reviewed by our
Legal Services team prior to signature who will ensure there is a clause which obliges each party to
comply with all applicable laws or regulations, in force from time to time.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide regular training to all our colleagues.
Following a review of the effectiveness of the steps we have taken this year to ensure that there is no
slavery or human trafficking in our supply chains we intend to take the following further steps to
combat slavery and human trafficking:
• Continue to ensure all of our supplier contracts (both existing and new) contain an
anti-slavery clause, this clause, which flows down through all layers of our supply chain, prohibits
suppliers and their employees from engaging in slavery and human trafficking;
• Review of existing training for all colleagues;
• Continue to review, update and develop new Procurement & Supplier Management policies and
procedures (including risk assessment of suppliers) to address and incorporate provisions of the Act.