Although we understand that the scope of the Modern Slavery Act 2015 is limited to companies carrying on business in the UK with a turnover of at least £36m, as an organisation committed to the welfare and protection of children, we have prepared this statement to reflect our zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and acting to prevent and tackle modern slavery and human trafficking throughout our own organisation as well as in our supply chain and partner organisations.

The policies and processes we have implemented to reflect our zero-tolerance approach to modern slavery and human trafficking include the following:

• Being committed to the welfare and protection of children, we have a comprehensive Child Safeguarding and Protection Policy and require that our grantees also have their own safeguarding policies. We often work with our grantees and partner organisations to help them develop their own safeguarding procedures and encourage them to regularly report and investigate any issues that may arise.
• We check that all our staff have appropriate right to work documents and have a staff Code of Ethics and an Equal Opportunities Policy that includes commitments to treat all our staff with respect, fairness and good faith (including in respect of remuneration) and provide conditions of employment that safeguard their rights, welfare and wellbeing in the work place.
• Our staff employ our shared values and behaviours in their work including honesty. Our Whistleblowing Policy, along with our Health & Safety Policy are also designed to give staff the confidence to raise serious concerns, including where the health and safety of an individual is being endangered.
• We ensure that adequate information and training is provided to all our employees and contractors relating to equal opportunities and respect for all.  We will provide training for all our staff, with a focus on types of modern slavery and human trafficking and how to identify them.
• We use suppliers and consultants to support the operations of our organisation in the UK and internationally.  The key areas in which we engage suppliers are:
  • facilities management
  • construction and design
  • information technology
  • finance
  • legal and investments
  • travel
  • learning and development
  • payroll, pension and insurances services
  • hotel accommodation
• We also deal with many organisations through our grants and charitable investments. The majority of these are international organisations, who do not explicitly consider modern slavery in their policies and processes as this is not a legal requirement for them.
• We adopt a risk-based approach to the organisations that we fund or suppliers that we engage.  Before working with a supplier or funding an organisation, we may carry out a modern slavery and human trafficking risk assessment, where we believe the risk of modern slavery may arise.  Based on that assessment we may request further information to satisfy ourselves that the organisation is taking appropriate actions to prevent modern slavery and human trafficking in its operations.
• Notwithstanding our due diligence, where we provide funding to an organisation or contract with a supplier using one of our template standard form contracts, we require them to confirm that slavery and human trafficking is not taking place in their business or supply chain.  These organisations are also required to implement appropriate due diligence procedures in their own businesses to identify and prevent modern slavery and human trafficking in their supply chains.  Our contracts require contract counterparties to report serious incidents and to cooperate with us in discharging any legal obligations in respect of such incidents.  We reserve the right to terminate the contracts where they fail to do so.
• Due diligence and monitoring are ongoing to improve supplier vetting and to minimise further a range of risks, including slavery and human trafficking.
• We assess high risk vendors and require them to have Modern Slavery processes and policies in place in order to mitigate modern slavery risks within our supply chain.

Our Legal and Finance teams have responsibility for our approach to modern slavery. We intend to continually review our processes to ensure they are appropriate and effective in identifying and addressing modern slavery and human trafficking in our business.

Our policies are monitored by a relevant policy owner within our organisation.  We will continue to review our policies to ensure that they are effective and appropriate.

This statement has been presented and approved by CIFF’s Board of Trustees on 8 December 2022.