Modern Slavery Statement

Aim And Introduction

The Company acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015.

Modern slavery can take various forms, such as servitude, forced or compulsory labour and human trafficking. Modern Slavery is a global issue and the Company has put in place steps that are aimed at ensuring there is no slavery or human trafficking in its own business and its supply chains. The Company understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Company does not enter into business with any other company, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Company is obtained by means of slavery or human trafficking. The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom (and in many cases exceeds those minimums in relation to its employees.)

All employees are checked for their eligibility to work in the UK by our HR department which performs the required right to work checks of all employees.

Policies And Control

The Company expects the same high standards from all its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery and expects that its suppliers will in turn hold their own suppliers to the same standards.

The Company’s policies that demonstrate commitment to its zero-tolerance approach to Modern Slavery are:

  • Equal Opportunities Policy
  • Anti-bribery and Corruption Policy
  • Grievance Policy and Procedure
  • Whistleblowing Policy

If you require a copy of any of these policies, please contact us.

Due Diligence Process

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour.

However, the Company accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe, and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

We will not support or deal with any business knowingly involved in slavery or human trafficking. We work with reputable recruitment companies and expect them to implement effective anti-slavery policies.

The Company implements the following:

  • Right to Work and Identity checks (via an IDVT or Home Office Share Code check)
  • Ensuring compliance with National Minimum Wage or National Living Wage legislation
  • Compliance with statutory payments for holiday, sickness, maternity, paternity, and other benefits
  • The Company follows a client/new business onboarding process that includes the following:
    • Check of website domain
    • Credit checks
    • Company and VAT number checks
    • Ensuring that Company accounts have been filed
    • Anti-money laundering checks

Training

Line managers are responsible for ensuring that those reporting to them understand and comply with this Statement.

All ICS staff are provided with annual Modern Slavery training, to ensure they know their responsibilities, the ways in which to report any suspicions, and why there is legislation in place to protect people.

This Statement applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.

Responsibility

The Board of Directors has overall responsibility for ensuring that this Statement complies with the Company’s legal and ethical obligations.

The Board of Directors are also responsible for investigating allegations of modern slavery in the Company’s business or supply chains.

The Managing Director has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems, policies and procedures to ensure they are effective in preventing or reducing the risk of modern slavery.

This statement confirms that the information is accurate at the time of publishing.

John Lyon – Managing Director

Last Review Date: June 2024