The Southern Co-operative Limited (“Southern Co-op”) has always prided itself on its ethical and sustainable approach to business and longstanding commitment to local communities. It’s part of our co-operative difference. We wholeheartedly endorse the need to take continuing steps to eradicate modern slavery and human trafficking and have a zero-tolerance approach to any form of this within our operations, workplace and communities. We are committed to raising awareness of these abhorrent activities and encourage others to do likewise.
The Modern Slavery Act 2015 was brought into force to tackle widespread problems with slavery, servitude, forced or compulsory labour and human trafficking which unacceptably still exist in the UK. One of the areas the legislation has dealt with is promoting transparency and accountability across businesses. To this end, this is our ninth Modern Slavery Statement which sets out the progress we have made in the last year to the end of January 2025 to raise awareness and understanding of the existence of human trafficking and modern slavery and ensure that they have no part in our workplace or in the production or manufacture of the products we sell and the goods and services we use in our supply chain and the franchise partnerships we operate.
Our business and supply chains
We’re an independent co-op with a turnover of over £540 million, operating across the south of England running convenience food stores, funeral homes, bereavement services, crematoria and natural burial grounds. We also have franchise partners who trade under our ‘Welcome’ brand and a Starbucks coffee franchise. We have over 4,500 colleagues and a purpose of working together for the benefit of our communities.
Our core business is operated by Southern Co-op which has a number of smaller subsidiaries in its group*. These subsidiaries run distinct businesses which make up Southern Co-op’s portfolio, including our various end of life services, as well as coffee operations and our Welcome franchising arm. Southern Co-op and Cobra Coffee Limited, its subsidiary, are each required to publish a statutory statement. This Modern Slavery Statement sets out the attitude and work of the entire group in relation to our fight against modern slavery and similar abhorrent practices.
In relation to our food business, approximately 90% of the products we sell in store are supplied by The Co-operative Group Limited, the separate, independent co-operative based in Manchester, via a joint buying arrangement managed by Federal Retail and Trading Services Limited which represents a number of independent retail co-operatives. We directly manage over 1,000 other suppliers who provide the range of services we require in our business from cleaning services; stationery and security to IT support; software and hardware; company cars to facilities management and end of life products; to Local Flavours; our range of local food and drink stocked in all of our food stores.
.
Our policies and strategy
Chaired by our Central Services Director supported by our Head of Legal and Contracting, with a permanent membership comprising our HR Director and Communications Manager, our Modern Slavery Working Group has continued to oversee our policies, processes, training and reporting generally to ensure our business and supply chains continue to be safeguarded from the abhorrent practice of modern slavery and that we are transparent and effective in this. Its senior membership underlines the significance of this issue and demonstrates our commitment to tackling it in a meaningful way involving all areas of our business.
This year the Working Group followed the new Southern Co-op Anti Modern Slavery Strategy launched in 2024. This strategy was designed with the specialist help of a consultant who has been helping us in our fight against modern slavery. It reflects the objectives in Our Plan by setting out our commitment to eliminate the risks of modern slavery within Southern Co-op and our supply chains and goes well beyond our strict statutory obligations in this area.
Our purpose of “working together for the benefit of our communities”, as set out in our corporate strategy: “Our Plan”, remains our central theme, underpinning everything we do as we continue to strive towards promoting a fairer and more sustainable way of doing business. Running through our core, this commitment is reflected in every decision we make whichever of our stakeholders that decision affects. By acting responsibly and standing up for what we believe in, we can encourage others to do the same; therefore, supporting communities and the environment to give society and our planet, a chance to sustain itself and thrive locally, nationally and globally.
Our Plan is aligned with the UN’s Sustainable Development Goals (SDGs), with one of our prioritised goals being the drive towards responsible consumption and production (SDG 12). We continue to work with our suppliers to raise ethical standards and ensure people are treated fairly. Our Plan underlines our fundamental ethos of a “Fair, fresh approach, for all” which is at the heart and soul of our brand. This reflects our attitude towards such unacceptable practices as modern slavery and human trafficking and encourages a business wide culture of driving out inequality and unfairness, both internally and externally – it reinforces our co-operative values and is part of our co-operative difference.
Our anti modern slavery aims are to:
The Working Group achieved some good progress against its strategic objectives this year. The new Anti-Modern Slavery Policy has been adopted, published and trained internally. Our Whistleblowing Policy, having been relaunched in 2023, with a simple straightforward process for reporting concerns which include those relating to the potential existence of modern slavery continues to see some activity which proves its existence is known. We hope this promotes a culture of openness, creating an environment where people feel empowered to speak out where they see something wrong. We are pleased to report though that thankfully, yet again this year, the reports received through this process have not related to modern slavery in our business or supply chain and have been dealt with instead through other relevant channels.
In accordance with the Immigration, Asylum and Nationality Act 2006, which aims to safeguard workers from exploitation and mistreatment, our robust recruitment procedures continue to ensure checks on eligibility to work in the UK are carried out for all employees. We have also taken steps to extend this within our franchise partnership “Welcome” sharing all policies and procedures in both a contractual and operational support basis.
Our suppliers
Our main supplier to our food business, The Co-operative Group Limited, has a strong, proactive anti-slavery policy consistent with its ethical trading stance, as set out in its Modern Slavery Statement and its annual Sustainability Report showing how it does business responsibly. It has a longstanding Sound Sourcing Code of Conduct based on the Ethical Trading Initiative Base Code. All its suppliers are expected to share the principles set out in that Code. As a result, we are confident that it has taken and continues to take considerable steps to minimise the risk of modern slavery within its operations and ensure its commitment in this area is applied across its business and supply chains.
We recognise that the UK is not immune from these issues, and we have maintained our vigilance in ensuring that all new contracts we enter into with our suppliers who are primarily based in this country contain appropriate safeguards. We have added a comprehensive supplier contract management system that requires compliance with our Anti Modern Slavery Policy, identifies, using a risk-based approach high risk areas which are subject to specific audit checks. We have also entered into such contracts with all of our suppliers who provide goods for our Local Flavours range. Our tailored approach to auditing these, mostly small-scale suppliers, which includes checks on the risk of the existence of modern slavery and human trafficking has, we are pleased to report not revealed any instances of modern slavery during the year across our supply chain operations. We are committed to continuing this extended audit process to ensure we are fully aware of any risks in our supply chain and can take action, as appropriate.
We continue to review appropriate wider audit solutions for our supplies of goods and services not for retail which would specifically help to identify ethical risks such as potential modern slavery within our supply chains; however we feel our current risk based approach and local supplier monitoring is appropriate at this time, albeit this is continually reviewed by our working party.
In 2024 we underwent an internal audit conducted by KPMG in relation to our third-party supply chain risk management. This assessed our processes in relation to pre on boarding due diligence and ongoing relationship management particularly in relation to environmental, social and governance considerations. It identified a number of potential actions, and we are pleased to highlight our new contracting supplier onboarding system ensures all these actions are completed to ensure diligence in our supply chain.
Our procurement strategy which was launched in 2019 remains integral to our fight against modern slavery. A cornerstone of this strategy is to ensure we uphold high ethical standards when choosing our business partners. We have developed a bespoke tool, “Our Decision-Making Compass”, designed to bring a more specific ethical lens to our decision making and it has been applied to many strategic projects and decisions in the last year. This has meant we have specifically considered stakeholders’ interests, the impact of our actions and activities on our communities, members, colleagues and suppliers and on the environment. By applying our Compass, we can ensure we work with partners who have a similar approach so that the values and principles we apply to the way we do business are upheld across our supply chain. With a view to raising general awareness of this ethical approach, training on the Compass has been delivered this year to the business in areas who might not otherwise be required to apply it according to our internal policies. This has been carried out with the intent of ensuring a culture which promotes our co-op difference and ethical way of doing business.
The contract framework and contracting system forms the basis on our procurement strategy lead by our Central Services Director who joined in 2024 who has over 20 years leadership commercial experience in contracting with a focus on prudent; ethical and sustainable purchasing. Continual training to the Leadership Team and all relevant colleagues with a responsibility for engaging with suppliers for goods and services not for retail is in place. This highlighted the Compass and its significance in the way we do business and encouraged a business wide application of its underlying principles of responsible business in our approach to contracting.
Further work has been carried out in relation to risk assessing our not for retail goods and services supplier base and this work is ongoing with a view to identifying the highest risk suppliers and engaging with them to ensure no modern slavery exists in their supply chains with specific auditing where risk dictates.
For our Starbucks business, which is operated under licence, we are required under our contractual arrangements to use Starbucks’s nominated suppliers. Starbucks has a longstanding commitment towards promoting ethical sourcing of all its products. It will not make use of any form of forced or compulsory labour at any time for any purpose. It has a range of ethical sourcing programmes, some of which are externally accredited. With the help of external consultants, it is working towards compliance with these ethical programmes across its supply chain with a target of ensuring 100% of the tea, coffee and cocoa is purchased in accordance with its policies. Please see the Starbucks website for further details of their work in this area. This year we have published a separate Modern Slavery Statement relating to our Starbucks licensed business which is operated by one of our wholly owned subsidiaries, Cobra Coffee Limited.
We are members of Business in the Community (“BITC”) which promotes responsible business, including through the application of the UN’s SDGs. BITC defines responsible businesses as a healthy business; one that puts the creation of healthy communities and a healthy environment at the heart of its strategy to achieve long-term value for its stakeholders. Our prior participation in the Responsible Business Tracker helped us identify further opportunities for us to strengthen our management and, where appropriate, mitigation of social, ethical and environmental issues within our business and value chain and we continue to monitor our progress by seeking to implement the specific recommendations.
The Working Group received reports from the Central Services Director, who is a member of the FRTS Ethics & Sustainability Group and Co-op Strategic Leaders Forum which both convene senior leaders from Co-ops UK, the umbrella organisation for co-operatives, Co-op Group and other independent societies to discuss ethical and sustainability related food and supply chain issues and shared campaigning opportunities, respectively. These groups provide an opportunity for knowledge sharing across societies on a range of topics including modern slavery and the potential for collaborative working and action.
The Working Group remains responsible for overseeing the implementation and monitoring the efficacy of these processes in protecting the business and its supply chains from modern slavery.
Training
Awareness raising has continued this year through the re-launch of the contract framework which has reminded the business of our ethical approach to contracting. We also ran a series of articles which were posted on our intranet during the week around Anti Modern Slavery Day in October 2024. Positive feedback was received from colleagues across Head Office.
Assessment of effectiveness
It is important we assess whether the steps we are taking are achieving our goal of defending our organisation from incidences of modern slavery. With the benefit of enhanced governance and oversight as a result of the procedures and processes put in place last year, we can again confirm that we have not been made aware of any breaches of the Modern Slavery Act 2015 within our business or supply chains in 2024. We remain alert to the risks and dangers and are committed to maintain confidence in our ability to prevent modern slavery and human trafficking in all its forms within our sphere of influence. We will report again on our progress towards this aim next year.
Approval for this Modern Slavery Statement
This statement was approved by the Board of Directors of The Southern Co-operative Limited on 28 July 2025.
JANET PARASKEVA, CHAIR OF THE BOARD OF DIRECTORS
List of subsidiaries covered by this Modern Slavery Statement
*Mutual Associates Limited
Southern Co-operative Funerals Limited
Mutual Services (Portsmouth) Limited
Co-operative Franchising Limited
Cobra Coffee Limited
Cobra Coffee South West Limited
Southern Co-operative Properties Limited
Southern Co-operative Retailers Limited
Co-operative Independent Living Limited
Southern Co-operative Dairies Limited
South of England Funeral Partners Limited
Sussex Woodlands Limited
East Devon Crematorium Limited and Natural Burial Grounds Limited.
