Modern Slavery

Slavery and Human Trafficking Statement for the financial year 2018/19

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that The Midcounties Co-operative has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.  We issued our first such statement two years ago.  This statement outlines the progress we have made in the last year.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour.  The Midcounties Co-operative 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.


Our business

Midcounties Co-operative is a consumer co-operative owned and controlled by its members.  We are part of the global co-operative movement and subscribe to co-operative values and principles that govern all co-operatives around the world.

We have four core values that underpin our Purpose and guide the way we work.

We operate a range of businesses in Food, Travel, Healthcare, Funeral, Childcare, Energy, Post Offices, Telecoms and Flexible Benefits.  Our heartlands are in Oxfordshire, Gloucestershire, Buckinghamshire, Shropshire, Staffordshire, the West Midlands, Wiltshire and Worcestershire. However, we also trade in the surrounding counties and our Energy, Telecoms, Childcare, Travel and Flexible Benefits businesses trade across the UK.


Our high-risk areas

Our principal high-risk areas are in our supply chain and contracted services. The main direct supplier high risk area is in our Funeral business where masonry stone is purchased from India. We have visited our supplier a number of times to gain reassurance on compliance with our Code of Business Conduct and are now undertaking a review to further improve our audit process. 

More broadly, we have taken steps to understand in greater detail the areas of our Society and supply chain in which there may be a greater risk.  Work has been ongoing throughout the year to review supplier terms and conditions/contracts to take into account ethics and modern slavery, and we have engaged with our suppliers to further understand and discuss risks associated with modern slavery, including hosting an event for suppliers to discuss issues and learn more about tackling modern slavery. We continue to carry out our process in which all first meetings/contact with suppliers include the issuing of the following documents from our Head of Procurement:

-       Ethical code of conduct

-       Signed copy of our Modern Slavery Statement

-       Standard letter seeking their confirmation of adherence to employment legislation.

As part of our due diligence processes and checks, all suppliers must return a signed copy of our Ethical Code of Conduct, to confirm their adherence to all related Midcounties’ polices, including Modern Slavery. 


Our policies

We operate a number of internal policies to ensure we are conducting business in an ethical and transparent manner.  These include:

  1. Modern Slavery and Human Trafficking Policy.  This policy sets out the Society’s stance on modern slavery and explains how colleagues can identify instances of modern slavery and where they can go for help.
  2. Recruitment policy.  We operate a robust recruitment policy; this includes conducting eligibility to work in the UK checks for all prospective colleagues to safeguard against human trafficking or individuals being forced to work against their will.
  3. Whistleblowing policy.  We operate a whistleblowing policy so that colleagues can raise concerns about inappropriate practices within our Society or supply chain without fear of reprisal.
  4. Code of business conduct.  This code explains how we behave as an organisation and how we expect our Colleagues and suppliers to act.

We have independent and confidential services such as Speak In Confidence, an anonymous conversation system allowing direct communication between colleagues and senior managers. We also have an Employee Assistance Programme, a free confidential helpline service, available to colleagues so they can talk to professionals on any personal, home or work-related issues.


Our Suppliers

The majority of the suppliers we work with transact with our Food Retail business. We are members of the buying group Federal Retail Trading Services (FRTS), which purchases on behalf of our Food Retail business. FRTS has its own Modern Slavery Statement and Sound Sourcing Code of Conduct (SSC) which can be found at  The SSC sets out the workplace and employment standards that we expect of all our suppliers.  It is based on the Ethical Trading Initiative Base Code and core international labour standards, and includes checks on forced labour and modern slavery. 

FRTS suppliers are identified for audit using a risk-based approach determined by their responses to Sedex (Supplier Ethical Data Exchange) questionnaires, worker profiles, country of origin and sector analyses.  Through this monitoring programme over 1,900 co-op own branded supplier sites are covered, comprising over half a million workers across six continents and 74 countries.

Training and capacity building of our suppliers through FRTS is also a key focus.  Through our ethical trade supplier engagement programme we continue to provide a variety of bespoke and interactive training opportunities for suppliers on an ongoing basis, as well as providing access to tools and collaborative initiatives to help suppliers address the underlying causes of human rights issues and to manage risks such as modern slavery. 

Outside of FRTS sourced products, our businesses follow our supplier ethical code of conduct. Supplier visits and follow up audits are carried out for suppliers identified as potentially ‘high risk’.

In addition, our Head of Procurement works closely with each business group to plan and deliver a robust purchasing and procurement strategy for ‘goods not for resale’ across the Society. This work includes ensuring our terms and conditions take account of ethics and modern slavery for our preferred suppliers.

During the year we worked with Business in the Community to develop and host a training session for suppliers to raise awareness of the issues around modern slavery. 



We have implemented training and awareness-raising activity in relation to modern slavery with our colleagues and members:

-       Managers across the Society have been briefed on our policies and processes and engaged in awareness-raising around Modern Slavery

-       Our specialist HR colleagues have received additional training on Modern Slavery in partnership with Business in the Community

-       Our Head of Procurement is examined each year on ethical procurement issues, including Modern Slavery, as part of her ongoing professional qualification

-       Colleague representatives have been engaged in awareness-raising and signposting of support agencies

-       Access to our Modern Slavery and Human Rights policy is available to all colleagues through our ‘Colleagues Connect’ website.  We introduced ‘Colleagues Connect’ this year to enable new ways of working and more open channels for our colleagues and to allow greater two-way feedback around important issues such as tackling Modern Slavery

-       We introduced a dedicated webpage on our website to raise awareness of Modern Slavery amongst our members, including hosting on this web page a theatre production in which we sponsored our community partner ‘Justice in Motion’ to raise awareness of Modern Slavery.     

We will continue to deliver training to raise awareness of Modern Slavery during the year. 



We have joined other businesses and co-operative societies across the UK in becoming a Bright Future business partner. Bright Future is an innovative scheme that provides employment opportunities for victims of Modern Slavery. Business partners such as ourselves work with local charities to match employers with slavery survivors who are then offered a four-week paid employment work placement, leading to a non-competitive job interview. 

We have engaged with 5 individuals as part of this programme to support and develop employability skills and opportunities and supported 3 individuals into employment with us.  We will continue to support Bright Future throughout the year and are members of the Bright Future Steering Group, leading the strategic direction of their work.  

To support employability skills further, colleagues from our HR team volunteered on a Careers Conversations programme in the West Midlands during the year working with Business in the Community.  This aimed to support survivors of Modern Slavery through language-focused employability work.  These events took place at Birmingham City University and helped the survivors identify careers and gain practical advice on how to develop relevant skills.


Our performance indicators

On a broader scale, our Society uses the United Nations Sustainable Development Goals to track our progress through Business in the Communities’ Responsible Business Tracker.   These 17 Development Goals form the 2030 Agenda for Sustainable Development – including decent work and reduced inequalities.

We can gauge the effectiveness of the steps we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if no reports are received from colleagues, the public, or law enforcement agencies to indicate that Modern Slavery practices have been identified.

We have received no reports of incidents relating to Modern Slavery to date.

We record the number of colleagues who have received Modern Slavery awareness training, and all our colleagues have access to our Modern Slavery and Human Trafficking Statement through our Colleagues Connect website.  Over 800 colleagues from across the Society have received awareness training around Modern Slavery. 


We will take appropriate action if we suspect or are advised of any instances of modern slavery or human trafficking within the Society or our supply chain.



An annual review of commitments made in this statement is undertaken by the Society to ensure due diligence, specifically looking at the following:

-       Suppliers: continue to ensure that whenever we engage a new direct supplier that they receive a copy of our Modern Slavery Statement and agree to adhere to our employment legislation

-       Training and capacity building of suppliers: through FRTS continue to provide a variety of bespoke and interactive training opportunities for suppliers on an ongoing basis, as well as providing access to tools and collaborative initiatives to help suppliers address the underlying causes of human rights issues, and to manage risks such as Modern Slavery. 

-       Training our colleagues: ensure all Managers across the Society have been briefed on our policies and processes, and specialist colleagues have received additional training

-       Employment: monitor the number of colleagues we support through the ‘Bright Future’ programme, supporting those who have been rescued from Modern Slavery back into the workplace

-       Policies: on-going monitoring of our policies in place to ensure that we continue to raise awareness around tackling Modern Slavery throughout our operations.

-       United Nations Sustainable Development Goals: monitoring our progress against the 17 goals through Business in the Communities’ Responsible Business Tracker.   


Approval for this statement

This statement was approved by the Board of Directors on 29 July 2019


Helen Wiseman