UCB Home Loans Corporation Limited - Modern Slavery Statement for the financial year 2017/2018

Introduction

This statement is made in accordance with section 54 of the Modern Slavery Act 2015 (the Act) and outlines the steps taken to ensure there is no slavery or human trafficking taking place within our business or supply chains.

About UCB Home Loans Corporation Limited and its business and supply chains

UCB Home Loans Corporation Limited (UCB) is a wholly owned subsidiary of Nationwide Building Society (Nationwide).

UCB is a specialist lender of Nationwide, providing Buy to Let and residential mortgages. Nationwide no longer offers new mortgages through UCB.

As a member of Nationwide’s group, UCB relies on its parent, Nationwide, for the infrastructure and resources it needs to carry on its business. This includes providing or acquiring all the goods and services, IT and other technology UCB needs to run its business. It also includes providing UCB staff. Nationwide does this for each member of the Nationwide group. UCB does not source the supply of goods and services for itself but relies on Nationwide’s activities for the wider group. UCB’s supply chains are, effectively, Nationwide’s supply chains.

You can find out more about UCB and the structure of the Nationwide group in Nationwide’s Annual Report and Accounts.

Policies

As a member of the wider Nationwide group, UCB is subject to, and benefits from, Nationwide’s policies on slavery and human trafficking. These include Nationwide’s Code of Conduct for all employees, temporary workers and contractors (including those supporting UCB’s business) and the Third Party Code of Practice which all of Nationwide’s suppliers are asked to commit to (including those who provide services to UCB). Further details of these policies are set out in Nationwide’s Slavery and Human Trafficking Statement.

Due diligence

Slavery and human trafficking are crimes and any financial benefit the activities generate are proceeds of crime. Nationwide carries out a range of activities to detect, discourage and prevent anyone using financial systems to launder proceeds whether they do business with Nationwide or any member of Nationwide’s group, including UCB. Nationwide also conducts due diligence when procuring new services to ensure suppliers can comply with the requirements of the Act and Nationwide’s Third Party Code of Practice. UCB relies on the activities that Nationwide carries out, and you can find further details of these in Nationwide’s Slavery and Human Trafficking Statement.

Risk

UCB, as part of the wider Nationwide group, doesn’t work in an industry that’s at high risk of modern slavery and 99% of the suppliers to the Nationwide group are based in countries with a low risk of modern slavery (Global Survey Index). We know that some of suppliers to the Nationwide group work in higher-risk industries and countries, which is why our responsibilities are important to us. Nationwide uses a number of tools to manage risk, ensure the approach to tackling modern slavery is effective, monitor industry developments and to champion innovation within the Nationwide group, including UCB.

Training

Nationwide ensures that relevant training is provided to all colleagues across the whole group, including those who work in UCB. For this reason, UCB does not provide its own training.

Further information

UCB relies on the steps of its parent, Nationwide, who will take on its behalf and on behalf of all of the Nationwide group in tackling the risk of modern slavery taking place in its business or supply chains. Nationwide’s Slavery and Human Trafficking Statement describes those steps in more detail. The Statement is published on Nationwide’s website and you can download it here:

Download our Slavery and Human Trafficking Statement 2018

This statement was approved by the Board of Directors of UCB and is signed by:

Henry Jordan