1. Introduction
This statement describes the approach taken by ICE Creates Ltd (ICE) to prevent modern slavery and human trafficking in its operations and supply chains during the financial year from 1 April 2026 to 31 March 2027. Because the financial year is still in progress, the statement records arrangements and activity evidenced up to 10 October 2026 and identifies further actions for completion or review before the year closes.
ICE has a zero-tolerance approach to modern slavery, human trafficking, forced labour, servitude, child exploitation and other forms of labour abuse. ICE is committed to acting ethically, responsibly and with integrity and expects equivalent standards from employees, suppliers, contractors, subcontractors and partners.
ICE’s current governance documents state that ICE falls below the turnover threshold for mandatory publication under section 54 of the Modern Slavery Act 2015. ICE nevertheless publishes this statement voluntarily to support transparency, responsible procurement and the expectations of NHS, local-authority and other public-sector clients.
2. Our organisation
ICE is a UK-based behaviour-change organisation delivering person-centred design, communications, insight, innovation, consultancy, engagement and community-focused services. ICE supports public-sector organisations, partners and communities, including work intended to improve wellbeing, resilience and positive social outcomes.
Operational activities are primarily UK-based. The nature of ICE’s work means modern-slavery risk is generally more likely to arise through recruitment, labour providers, subcontracting and the supply chain than through ICE’s office-based activities. ICE therefore applies proportionate controls to employment, procurement, contracting and supplier oversight.
3. Our supply chains
ICE’s supply chain includes technology, marketing, training, consultancy and operational-support services. Some suppliers or their own supply chains may operate internationally, creating differing geographic, sector and service risks.
ICE’s public-sector contracts may require compliance with the Modern Slavery Act 2015, implementation of due-diligence procedures for subcontractors and supply-chain participants, accurate responses to client questionnaires, traceability records and employee training. ICE incorporates these obligations into its approach where they apply.
4. Policies and governance
ICE’s approach is supported by the following policies and controls:
Ultimate accountability rests with the Board of Directors and senior leadership. Managers are responsible for applying the controls relevant to their functions, while employees, contractors, suppliers and partners are expected to report concerns promptly.
5. Risk assessment and due diligence
ICE applies a risk-based approach to modern-slavery due diligence. Supplier risk may be considered by reference to geography, sector, product or service, labour model, use of subcontracting, recruitment arrangements and other relevant warning signs.
Controls used or available during supplier onboarding and review include:
Due diligence is proportionate to risk. Identifying higher risk does not automatically require immediate termination. ICE will consider the welfare and rights of affected people and the effectiveness of corrective action, remediation, monitoring or disengagement.
6. Recruitment and labour standards
ICE’s Recruitment and Selection Policy requires fair, transparent, inclusive, lawful and safer recruitment. Recruitment decisions must not be influenced by unlawful discrimination, favouritism, bribery or unmanaged conflicts of interest. ICE verifies right to work, applies proportionate identity and suitability checks and expects agencies and suppliers to meet contractual recruitment, safeguarding, data-protection and assurance requirements.
ICE does not tolerate the withholding of identity documents, recruitment-related coercion, debt bondage, forced labour, threats, restriction of movement or other exploitative practices. Concerns arising through direct recruitment, labour providers or delivery partners must be escalated immediately.
7. Training and awareness
ICE’s policy and action-plan framework requires modern-slavery awareness proportionate to role and risk. Awareness covers the meaning of modern slavery and human trafficking, indicators of exploitation, higher-risk supplier categories, reporting and whistleblowing routes, safeguarding escalation and procurement and contract responsibilities.
Relevant personnel involved in procurement, HR, contract management, safeguarding, community delivery and supplier oversight are expected to receive enhanced awareness. ICE’s policy sets a target of 100% completion for employee and manager modern-slavery awareness training. Completion performance for the full 2026/27 financial year will be confirmed after the reporting period closes rather than estimated in this current-year statement.
8. Reporting and remediation
Employees, contractors, suppliers and partners are expected to report suspected modern slavery or exploitation immediately. Concerns may be raised through line management, HR, the Safeguarding Lead, the Finance and Operations Director, the relevant Contract Manager or ICE’s Whistleblowing Policy.
ICE will treat concerns seriously and may investigate, protect evidence, involve specialist support, notify a client or competent authority, suspend relevant activity, require corrective action or reconsider a supplier relationship. Remediation will prioritise the welfare, safety and rights of affected individuals. Immediate termination will not be treated as the only possible response where another proportionate course better protects potential victims.
9. Measuring effectiveness
ICE monitors the effectiveness of its arrangements using evidence such as:
This statement does not insert unsupported performance figures. Year-end results should be added only when verified records are available and before final publication for the completed reporting period.
10. Priorities for the remainder of 2026/27
Before finalising the full-year statement, ICE will seek to:
11. Approval and publication
This draft current-year statement is intended for approval by the Board of Directors of ICE Creates Ltd and signature by the Chief Executive Officer. Once approved, it should be published in an accessible location on ICE’s website and made available to employees, suppliers, clients and other stakeholders.
Government guidance encourages organisations publishing an annual modern-slavery statement to make the statement available on their website and to add their most recent statement to the government modern-slavery statement registry. ICE will determine the appropriate publication route following Board approval.
12. Board approval
Signed:
Name: Colin Stuart Jackson
Position: Chief Executive Officer
Date: March 2026
