STATEMENT ON MODERN SLAVERY FY 2017-18
CONTEXT: OVERVIEW OF CIMA AND THE MODERN SLAVERY ACT
The Chartered Institute of Management Accountants® (CIMA), founded in 1919, is the world’s leading and largest professional body of management accountants, with members and students operating in 184 countries and territories, working at the heart of business.
CIMA members and students work in industry, commerce, the public sector and not-for-profit organizations. CIMA works closely with employers and sponsors leading-edge research, constantly updating its qualification, professional experience requirements and continuing professional development to ensure it remains the employers’ choice when recruiting financially-trained business leaders.
In 2017, members of CIMA and AICPA formed the Association of International Certified Professional Accountants to unite and strengthen the accounting profession globally.
Representing an influential network of more than 667,000 members and students in management and public accounting, the Association prepares accountants for today’s challenges and tomorrow’s opportunities.
CIMA has 17 offices across the globe with a diverse range of suppliers. As CIMA expands its operations globally, it takes great responsibility to ensure that its supply chains are vetted accordingly in respect of modern slavery. The measures implemented to safeguard CIMA’s legal position is outlined in section 4.
The Modern Slavery Act 2015
The Modern Slavery Act came into force on 26 March 2015. The Act clarifies the existing offences of slavery and human trafficking and introduces tougher penalties.
The Act includes a new requirement for commercial organisations such as CIMA to publish a statement each financial year setting out the steps we have taken to ensure that no slavery or trafficking is taking place in our business and supply chain.
The term ‘modern slavery’ describes exploitation so severe that people are not able to leave their place of work. ‘Slavery’ refers to the condition of treating another person as if they were property, something to be bought, sold, traded or even destroyed.
Victims may be ‘owned’ by their employers, and controlled through means including massive recruitment debts that they are unable to pay off, and threats of harm if they try to leave. The significant characteristic of all forms of slavery is that they involve one person depriving another person of their freedom.
Situations that may present a particular risk of modern slavery include:
- Where workers have fewer protections through inadequate laws and regulations, weak or non-existent enforcement, and poor business and government accountability;
- Where there are high levels of poverty among workers;
- Where there is widespread discrimination against certain types of workers (e.g. women and ethnic groups);
- Where there is widespread use of migrant workers;
- In conflict zones, and;
- In some specific high risk industries (typically industries involving raw materials).
The risk of modern slavery affects almost every industry globally. As well as the potential for legal sanction, companies that fail to take effective action may also suffer severe reputational damage and loss of market share. CIMA takes this risk very seriously.
MEASURES TO ADDRESS MODERN SLAVERY IN CIMA’S SUPPLY CHAINS
CIMA has undertaken the following measures in order to manage the associated risks of modern slavery in its supply chain:
CIMA has adopted the following policy on modern slavery:
“CIMA is committed to upholding the highest ethical and professional standards, and to maintaining public confidence in management accounting. As part of that commitment, we will use our best endeavours to identify and mitigate the risks of modern slavery and human trafficking by:
- Never supporting or dealing with any business knowingly involved in slavery or human trafficking;
- Ensuring our suppliers and business partners understand our expectations of what is acceptable business behaviour, including this policy;
- Where necessary asking our suppliers and business partners to adopt suitable anti-slavery and human trafficking policies and procedures; and
- Encouraging the reporting of concerns and provide appropriate protection for whistle blowers.
CIMA’s leadership team will ensure that staff are aware of this policy statement and that any further steps are implemented to prevent slavery and human trafficking within CIMA and its supply chains. This policy will be reviewed annually”
Staff are made aware of the Modern Slavery Policy and encourage to report any concerns they have to the Senior Leadership Team.
All supplier policies dealing with modern slavery will be vetted during any procurement processes to ensure that they align with CIMA’s own policy.
CIMA will ensure that its contractual arrangements with new or existing suppliers support its modern slavery policy.
CIMA will continue to encourage whistleblowing to identify breaches of policy and contractual provisions in respect of modern slavery. Reporting systems are in place to ensure that whistle-blowers identities are protected and that they have HR, Procurement and Senior Leadership support.
Supply Chain Assessment and Reviews
CIMA will seek to identify vulnerabilities through supply chain assessment and reviews. While it is impractical for CIMA to audit and monitor each and every supplier in its entire supply chain at all levels, CIMA will identify key vulnerabilities and will take a risk management approach to ethical procurement and contracting. CIMA will ensure that its tender processes assist in assessing supplier compliance with the law.
For situations where corrective action is required, CIMA management will seek to address any issues with the appropriate level of management within the supplier. As a last resort, it may be necessary to terminate a relationship with a supplier.
REPORT ON THE 2017-18 FINANCIAL YEAR CIMA is not aware of any breach of the Modern Slavery Act 2015 in the context of its business operations or amongst its current supply chain during the financial year 2017-18.
Gail Stirling, Executive Vice President, Professional Standards and Governance.