Modern Slavery Policy

Modern Slavery and Human Trafficking Statement
Financial Year Ending 31 March 2025

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps ICE Creates Ltd (“ICE”) has taken during the financial year ending 31 March 2025 to prevent modern slavery and human trafficking in our operations and supply chain.

1. Introduction

ICE is committed to acting ethically, with integrity and transparency in all business dealings. We have zero tolerance for modern slavery or human trafficking, and we expect the same high standards from our employees, suppliers, and business partners.

2. Organisational Structure and Supply Chain

ICE is a behaviour change organisation creating positive impact through person-centred design, communications, insight, and innovation. Our operations are based in the UK, and our supply chain may involve multiple tiers and international suppliers in areas such as technology, marketing, training, consultancy, and operational support.

3. Policies and Governance

We have implemented robust policies and procedures to ensure modern slavery risks are prevented, detected, and addressed:

• Anti-Slavery and Human Trafficking Policy– setting out our zero-tolerance stance.
• Ethical Recruitment Policy– ensuring fair and transparent hiring practices.
• Supplier Code of Conduct– requiring suppliers to uphold human rights and labour standards.
• Whistleblowing Policy– enabling staff, suppliers, and partners to raise concerns confidentially.

These policies are reviewed annually and are approved by the Board.

4. Due Diligence and Risk Assessment

Our due diligence processes include:

• Assessing suppliers based on geographic, sector, and product/service risk factors.
• Incorporating anti-slavery clauses into supplier contracts.
• Requiring suppliers to confirm compliance with the Modern Slavery Act 2015.
• Investigating and acting upon any allegations or suspicions of non-compliance.

In 2024/25, we prioritised high-risk categories for enhanced review, including any overseas suppliers in manufacturing or outsourced services.

5. Supplier Engagement

We work collaboratively with our suppliers to raise awareness of modern slavery risks and to promote best practice. We provide guidance to suppliers on developing their own anti-slavery measures and encourage them to cascade requirements through their own supply chains.

6. Training and Awareness

All employees receive training on:

• Recognising the signs of modern slavery.
• How to report concerns internally or externally.
• Understanding ICE’s policies and legal obligations.

Training completion rates are monitored annually, with a 100% completion target for all employees and managers.

7. Monitoring, KPIs, and Continuous Improvement

We measure our effectiveness using key performance indicators (KPIs), including:

• % of Tier 1 suppliers assessed for modern slavery risk.
• % of staff trained in modern slavery awareness.
• Number of reported incidents and corrective actions taken.
• Results of supplier audits or assessments.

ICE is committed to continuous improvement, updating our processes annually and in response to emerging risks, industry standards, or legal requirements.

8. Approval and Publication

This statement has been approved by the Board of Directors of ICE Creates Ltd and is signed by the CEO. It will be reviewed and updated annually and made available to all stakeholders.

Signed:
Name: Colin Stuart Jackson
Chief Executive Officer
Date: 4^th October 2024