Modern slavery statement
The Chartered Insurance Institute (“CII”) is a Chartered Body, incorporated under a Royal Charter, with its principal office based in the UK. The CII also has offices based in India, Hong Kong and the United Arab Emirates, as illustrated in the organisational chart below, however it should be noted that the CII has made the decision to wind down its Indian entity which we expect to be completed in the next 12 to 18 months. The CII has a global membership base. This statement is made to provide clarity on the CII’s compliance with its obligations pursuant to Section 54 of the Modern Slavery Act 2015.
The CII is a professional body providing membership and qualifications for individuals working within the insurance and financial services industry. The CII is a global organisation, which provides its goods and services internationally. The CII can confirm that other than an examination centre based in Pakistan, which is provided by a third party supplier subject to a contract which obliges that party to comply with all applicable laws (including the Modern Slavery Act), it does not source any goods or services directly from any of the top 10 countries with the highest prevalence of modern slavery.
The CII does not have a specific supplier code of conduct concerning business relationships. However, the CII ensures that its key suppliers are under enforceable contractual requirements to comply with all applicable laws. The CII is also currently developing a procurement policy which will govern the selection process of suppliers providing goods, works and services in order to meet both our ethical and sustainability targets.
In circumstances where a new relationship between the CII and a key supplier is formed, the contractual process is run through the CII’s in-house Legal department to ensure that all identifiable risks are considered and addressed appropriately before entering into a contractual relationship with a new key supplier. This includes ensuring that an obligation is put on any supplier that they will comply with all applicable laws, of which the Modern Slavery Act 2015 would form part.
The CII’s core values underpin the way in which the CII conduct business. This extends to the procurement of suppliers.
All of our employees and members, irrespective of where they work, are bound by the CII’s code of ethics, that ensures the highest level of professional and ethical standards are adhered to. A key principle within the CII’s code of ethics is to comply with all relevant laws and regulations. This includes not only acting within the law, but also within the spirit of the law, which would include an obligation to comply with modern slavery legislation.
Our policies reflect our commitment to diversity and inclusion, and to support our employees, members and the wider community, by providing policies covering whistleblowing, making complaints against CII members and internally through the use of Equality and Inclusion Impact Assessments.
The CII also adopts a Recruitment and Selection Policy that ensures that the best possible candidate is selected for the job whilst recognising the value of diversity and equality in a modern society.
The CII requires that all members of staff complete Equality and Diversity e-learning on induction into the CII, and annually as a refresher. The CII also provides access to a modern slavery unit on its online platform, Assess, which is accessible to all members or staff and also for members to purchase.
The CII has employed a Risk Manager to focus on assessing and managing the CII’s risk exposure, and to ensure that risk assessment strategies are effective.
Key Performance Indicators
The CII’s Legal Team has created “Legal Engagement Guidelines” which, amongst other things, provide guidance to staff on contract processes, including when a contract is required and who has authority to enter into them based on the type and value of the contract. Additionally, they have carried out training sessions on commercial contracts, covering what a contract is, how they are formed, and the risks involved with entering into a contract. These training sessions are available for all CII staff to view on demand.
The CII has also implemented new technology in the form of a legal case management system to support the monitoring of legal support requests. This allows the Legal Team to quickly identify trends and issues where correct processes have not been followed (i.e., in accordance with the legal engagement or other guidelines) in terms of contractual or other legal risks associated with the Modern Slavery Act, and take action to address these appropriately.
Ownership and Accountability
The CII’s executive management team has overall accountability for ensuring that the CII complies with the Modern Slavery Act 2015. The Legal Director and Chief Operating Officer are responsible for ensuring that the CII complies with its Modern Slavery Act requirements.
This statement was approved by the CII Board on 30th June 2022 and has been signed by John Bissell, Chief Operating Officer, on 30th June 2022.
If you have any queries on the CII’s compliance with the Modern Slavery Act 2015, please e-mail Legal@cii.co.uk.
John Bissell, Chief Operating Officer