The Institution of Civil Engineers supports the Modern Slavery Act and opposes modern slavery and human trafficking. It is committed to ensuring that such practices have no place within its supply chain or other activities.
The ICE is a professional membership body and registered charity for civil engineers. At 31 December 2019 membership stood at just over 95,000. The ICE was established by Royal Charter and is a registered charity in England and Wales and in Scotland. It supports its members and its charitable activities through an extensive network of regional offices, branches, partnerships and agreements of co-operation.
The purpose of the ICE is to promote and advance civil engineering around the world. It seeks to lead the global infrastructure debate as well as to provide professionally qualified civil engineers who are then supported in their lifelong learning.
In common with many charities it has a trading subsidiary Thomas Telford Ltd which operates in the fields of publishing, training, recruitment and venue management and hospitality. ICE also owns the entire share capital of The Institution of Civil Engineers (Hong Kong) Ltd. ICE has a branch in Dubai and Thomas Telford Limited has a branch in Hong Kong.
Across our group we have over 300 employees in the United Kingdom, Hong Kong and Dubai.
Our supply chains include IT services, publishing and printing services, catering staff and supplies, travel and accommodation, training providers and consultants, building maintenance, professional services, and marketing and PR services.
We have reviewed the risks that these supply chains may present with a particular focus on those suppliers with which ICE has had the largest expenditure in 2018 and 2019. Suppliers representing over 50% of the value of purchases were reviewed.
Where they were required to issue a statement under the Modern Slavery Act, this was obtained and reviewed. Many of the UK based suppliers are small consultancies or owner managed businesses within the publishing field and suppliers deemed to have a low risk with regard to modern slavery. Overseas based suppliers were considered, with the www.globalslaveryindex.org ratings being used to classify the country risk as low, medium or high.
Most of our overseas engagements were with legal and professional firms and deemed to be low risk. Other services based abroad included long standing relationships for IT support and office rentals. It is acknowledged that these may present higher risk which are considered when managing the supplier relationship.
The group spends a significant amount of travel and accommodation in support of its global activities. We have a travel portal from one consolidator through which most of the travel is booked. We obtained and reviewed their modern slavery policy and sought reassurance around their procedures to ensure that hotels offered through the site were held accountable for their practices around staffing and their supply chain.
ICE operates processes to ensure that all employees are eligible to work in the jurisdiction in which they are employed, thereby helping to safeguard against human trafficking or individuals being forced to work against their will.
Our whistleblowing policies encourage all staff to report any unethical practices without fear of reprisal.
We will complete the review of our existing supply chain for those suppliers with an average annual expenditure of £10,000 or higher.
We will create a process for onboarding new suppliers and will ask them to commit to a zero tolerance approach to modern slavery. We will draft an initial supplier code of conduct incorporating issues including bribery and corruption, modern slavery and data protection and seek to embed this throughout our supply chain.
Alongside this process we will ensure that staff are briefed as to the importance of ensuring that new suppliers are operating to the highest standards in this regard. We will consider what would be the appropriate method of training for staff involved in procurement.
The ICE recognises the need to continually review and assess the risks of slavery or human trafficking. We accept that there may be gaps in the visibility of supply chains and limitations in the tools used to identify risks and that addressing these is a complex task.
ICE will retain focus on the issue of modern slavery and continue its journey to develop an effective framework to eliminate such practices from our supply chain.
This statement constitutes the first annual statement of the ICE in relation to the Modern Slavery Act and relates to the financial year ending 31 December 2019. It was approved by the Trustee Board on 24 March 2020.