Slavery and Human Trafficking Statement

Modern Slavery Act Statement

Per the (UK) Modern Slavery Act 2015 all bodies organisation, irrespective of where they are incorporated, who (1) carry on a business, or part of a business, in the United Kingdom supplying goods or services, and (2) have a consolidated global turnover (or equivalent) of above £36 million (or Euro equivalent) per annum, are required to prepare and publish an annual “Slavery and Human Trafficking Statement”.

This statement must set out the measures an organisation has taken during its financial year to ensure that slavery or human trafficking is not taking place in any of its supply chains or within itself.

Progressive Building Society has been serving our members since 1914, and we are proudly the only wholly Northern Irish building society currently in existence. The Society is the twelfth largest in the UK, with assets in excess of £2.1 billion, serving over 90,000 members and employing over 180 staff.

The policy of the Progressive Building Society is to conduct our business in an honest and ethical manner, and to comply with all applicable legislation. We strive to ensure that neither modern slavery nor human trafficking supports our supply chain or our businesses; this objective is implicit in our policies and procedures. We aim for a zero-tolerance approach to violations of anti-slavery and human trafficking laws.

We are committed to acting professionally and with integrity in all its business dealings and relationships.

During 2024, there have been  no significant changes to the Society’s structure, ownership of capital structure.

We provide competitive savings and mortgage products to our members, jobs and career development for employees and social and economic benefits for local communities. We do not rely on seasonal workers and much of our staff population is for professional and technical roles.

The Society’s supply chains

The Society does not manufacture or supply any goods. The Society’s suppliers support our functions and the provision of financial services to customers.

The Society’s suppliers are subject to screening and due diligence checks before entering into a contract, as well as regular risk assessment and ongoing monitoring..

We have internal procedures to ensure appropriate procurement processes are completed when selecting suppliers which are competitively priced, with prompt payment and good planning to ensure that all activities carried out by the Society are in keeping with contractual obligations and applicable laws.

Approach to Slavery and Human Trafficking

The Society has zero tolerance of slavery and human trafficking both within its own operations and its supply chains. The Society is committed to taking all reasonable steps to ensure that there is no modern slavery or human trafficking in supply chains or in any part of our business.

Due to the nature of the Society’s business and supply chains, following careful consideration, the Society considers the risk of the presence of slavery or human trafficking in its supply chain to be low. However, the Society is not complacent in relation to these issues.

Contracting

As a provider of financial services, the Society is not considered to be in an industry with a high inherent risk of modern-day slavery. However, in delivering our services we procure products, goods, services and works from suppliers with extended supply chains, of which some may present a higher risk.  A risk-based approach to supplier due diligence has been implemented to ensure there are sufficient controls and monitoring in place.

The Society sees its approach to procurement and regular supplier relationship management including regular due diligence reviews as an effective measure to enforce a zero-tolerance approach to slavery and human trafficking.

A whistleblowing process operated across the Society for suppliers and colleagues whereby concerns can be raised and escalated as applicable. Members can raise concerns directly via any of our Branches.

Employment procedures

The Society has robust procedures in place pertaining to our employment practices.

• Robust recruitment processes in line with Northern Ireland employment law, including “right to work” document checks, contracts of employment, and checks to ensure all employees are above minimum working age.
• Market-related pay and reward, which is reviewed annually and linked to professional benchmarks.
• At induction and throughout the term of employment, employees have access to relevant policies including the Society’s Code of Conduct, Anti bribery and corruption Policy, Whistleblowing Policy and the Society’s employment handbook

Training Staff

All employees are recruited in accordance with our legal obligations. Relevant background screening checks are performed to monitor adherence to this.

The Society provides all staff with training that is relevant to them and their role. The Society also utilises an online training platform to provide staff with ongoing training and relevant policies which they will need to review in accordance with their roles.

We continue to consider, on an ongoing basis, ways to further enhance awareness on the issues of slavery and human trafficking and of our Anti-Slavery and Human Trafficking Policy among relevant employees and partners.

Employee Code of Conduct

We expect all colleagues to be treated fairly and with respect. Our Employee Code of Conduct applies to all staff including contractors. Employees are requested to attest to the Code of Conduct upon joining and at regular intervals throughout their employment with the Society.

Support mechanisms are in place for colleagues should any personal support be required linked to modern slavery or human trafficking concerns. This includes an employee confidential whistleblowing reporting tool and comprehensive wellbeing programme.

Supplier Oversight

The Society operates a programme of supplier relationship management and audit activities. Where any concerns arise, a full assessment would be made, and appropriate actions taken to address those concerns.

It is the responsibility for supplier relationship owners to conduct appropriate due diligence across the Society’s suppliers. This has taken place throughout 2024 and no concerns or issues have been identified. In addition, no concerns have been raised from our suppliers or via our whistleblowing process in 2024.

We conduct regular Financial Crime Risk Assessments, in line with our regulatory and legal obligations including screening controls which support the identification, reporting and escalation of modern slavery and human trafficking, no concerns have been raised in 2024.

We are committed to protecting our Members and to ensure that the opportunity for fraud, bribery or any other financial impropriety is reduced to the lowest possible risk. We have policies and procedures to manage the risk of fraud, bribery and other financial impropriety, including arrangements for prevention and detection, as well as arrangements for reporting and investigation.

Next Steps

The Society annually reviews its approach to preventing modern slavery and human trafficking and . This helps us engage with suppliers to identify any ethical trading issues and incidents of slavery or human trafficking and take appropriate action. We will continue to develop and implement the measures mentioned above in respect of our supply chain.

Our approach to modern slavery and human trafficking risk will continue to evolve and we will continue to mitigate these risks through the provisions mentioned above during 2025 and beyond.

The Progressive Building Society shall take responsibility for this statement and its objectives, and this statement will be reviewed and updated as appropriate.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Society’s slavery and human trafficking statement for the financial year ending 31 December 2024.

This statement has been approved by the Society Personnel and Renumeration Committee on behalf of the Board of Directors in February 2025.