Icon Modern Slavery and Human Trafficking Statement
The Modern Slavery Act 2015 came into effect on 29th October 2015. Icon is proud of the integrity measures it takes in this regard which stand alongside our other policies such as those promoting Equality and Diversity and our business values and ethics, and those aimed at eliminating bribery or attempted bribery.
The statement sets down Icon commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains.
We all have a duty to be alert to risks, however small. All staff are expected to report their concerns and management to act upon them.
Organisational structure and supply chains
This statement covers the business activities of Icon which are as follows:
Icon Exhibitions and Display Limited design and install top quality exhibition stands for clients in the UK and around the world. We also provide fit outs for shops, offices, receptions, transforming space into exactly what the client wants in order to promote the image of their business.
As a service provider our direct supply chain is minimal, so therefore risk assessment regarding the potential for Icon being an unwitting party to modern slavery and human trafficking is limited to labour trafficking. This risk assessment involves awareness of the Directors and employees using observation to detect any evidence of:
- the recruitment, harbouring, transportation, provision, or obtaining of a person for labour or services through;
- the use of force, fraud or coercion for the purposes of;
- subjection to involuntary servitude, peonage, debt bondage, or slavery.
Staff Recruitment and Training
Icon do not regard any of our activities to be high risk activities regarding modern slavery or human trafficking in either our United Kingdom or worldwide operations. No employment or contracting to supply labour takes place other than in the UK, which is regarded internationally as a low-risk country (according to risk analytics company Verisk Maplecroft).
Nevertheless Icon is committed to ensuring a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, and requires all staff to complete an online training and familiarisation pack within 6 months of their date of engagement.
The Company will only recruit staff after ensuring that they are legally permitted to work in the UK and will seek to verify that they are working willingly for us and not because they are forced or compelled to do so by anyone else.
We commit that we will pay wages in accordance with all UK laws, rules and regulations. We ensure that we benchmark pay to establish that our terms and conditions are fair and competitive and we are committed to equality of opportunity.
Icon conducts face to face training for all staff to emphasise the importance of acting in line with our own internal policies. This training will include our obligations under the Modern Slavery Act and the importance of ensuring that both we and those we conduct business with comply with this legislation.
In keeping with Icon commitment to act with integrity in all its business dealings, many of our existing policies are relevant in ensuring that there is no slavery or human trafficking in any part of its business or supply chains.
The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.
The following policies set down our approach to transparent, ethical and fair behaviour in addition to this policy regarding the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
- Whistle Blowing Policy – the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains;
- Code of conduct as contained in our Quality Management System (QMS) which sets down the actions and behaviour expected of employees when representing the Company;
- Bribery Policy
- Equal Opportunities Policy
Responsibility for the Company’s anti-slavery initiative is as follows:
- Policies: the Managing Director is responsible for creating and reviewing policies. The process by which policies are developed is by looking at best practice in association with external consultants and adapting to the needs of the Company;
- Due diligence: the management team are jointly and severally responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking;
- Overall: every staff member who has been trained is responsible for reporting suspicions they may have of modern slavery to their line manager.
Due Diligence Processes for Slavery and Human Trafficking
The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes:
- building long-standing relationships with suppliers;
- making clear our expectations of business partners;
- evaluating the modern slavery and human trafficking risks of each new supplier.
Icon reserves the right to invoke sanctions against suppliers that fail to improve their performance in line with industry best practice, including the termination of the business relationship.
The Company has a zero tolerance policy towards violations of the laws banning modern slavery. Icon contractual agreements permit the termination of any relationship with our suppliers without compensation for a single violation.
Icon will not support or deal with any business that we know, or suspect is involved in modern slavery.
We are developing KPI’s (key performance indicators) that will assist us in assessing the effectiveness of our measures to combat modern slavery. Currently the Company requires all staff to have completed training on modern slavery within 6 months of commencing employment and use of labour monitoring and payroll systems.
This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Board of Directors endorses this policy statement and is fully committed to its implementation.
The measures adopted by Icon are considered to be proportionate to its operations; the level of risk it faces and to be effective to uphold the aims of the Modern Slavery Act.