Transparency in Supply Chains (TISC): Modern Slavery Act Statement
The IET runs its activities with integrity. Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part. The IET is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain and to improving our practices to combat slavery and human trafficking.
The Modern Slavery Act 2015 requires UK organisations with an annual turnover of £36m or more to report on the steps they are taking to ensure that modern slavery is not taking place in its supply chains and publish with a link via the home page on its website. This includes the IET.
The IET
The IET is one of the world’s largest engineering institutions with members all over the world. It is a body incorporated by Royal Charter and is registered with the Charity Commission in England and Wales (Charity no 211014), and the Office of the Scottish Charity Regulator (Charity no SC038698). The IET has two active wholly owned non-charitable trading subsidiary undertakings registered in England and Wales, IET Services Ltd (company registration no 909719), and IEE Conventions Limited (company registration no 3566585), and has four significant international subsidiaries to support its charitable activities overseas, IET USA, Inc, Institution of Engineering and Technology, IET Services (India) Private Limited, and IET Engineering & Technology (Beijing) Consultancy Ltd.
The IET’s charitable objects and purposes are as set out in section 3 of its Royal Charter. The IET is working to engineer a better world by inspiring, informing and influencing our members, engineers and technicians and all those impacted by the work of engineers. It does this through various channels including publications, events, conferences, networking and advice. As at the date this statement was approved, the IET has over 156,000 members in 143 countries .
The IET has offices in the UK, China, Hong Kong, India and the USA. In 2023, it had a global income of approximately £66.4m and in 2023 employed an average of 608 people worldwide. Its activities are supported by over 4,000 volunteers worldwide. The IET recognises the risks of modern slavery are higher in some parts of the world in which it operates membership and other activities and takes these risks very seriously. The IET works with its subsidiaries and international partners to ensure that modern slavery is not present in their operations and activities.
The IET’s Supply Chain
In order to deliver its activities, the IET works with a range of suppliers, including publishing services, software services, catering and facilities management, and professional services.
Policies
The IET has an Anti-Slavery Policy in place and offers guidance on whistleblowing on its website at http://c6wz.36837a.com/membership/professionalism-and-ethics/professional-ethics-resources/whistleblowing-guidance-for-employers/ as well as having a staff policy on whistleblowing.
The IET also has a comprehensive Procurement Manual in place which sets out a procurement framework designed to ensure that modern slavery is not present within the IET’s business.
The IET’s Rules of Conduct for Members embed ethical behaviour across IET’s membership and oblige members to observe the provisions of the Statement of Ethical Principles published by the Engineering Council and the Royal Academy of Engineering.
Actions to minimise risk of Slavery
The IET takes a multifaceted approach, which includes:
During 2020 and ongoing into 2023, the IET requested, via our procurement policy and forms, that all contracts must include anti-slavery statements. In 2023 a project to review all standard templates was started, and is ongoing, and all the templates reviews that have been completed contain the appropriate anti-slavery statement.
In 2023 the IET embarked on a new relationship with Redactive who are now responsible for delivering E&T magazine and associated content. During the tender and contract signing a comprehensive due diligence process was completed and the contract contains Anti-Slavery commitments. Site visits were carried out and the relationship ongoing requires some close working between the IET and Redcative to deliver on its purpose.
Futures Place, our main office based in Stevenage remains an area of focus, including for cleaning and catering services. Operatives are on site so any unusual work practises would be visible. Catering and cleaning are also generally consistent, allowing individuals to become known to facilities colleagues over time and relationship developed.
In December 2023 the IET started a process to review the Right to Work checks for all UK employees, to be completed in January 2024
We have Modern Slavery provisions included in our operating manuals for both India and China offices.
Technology contracts are split into strategic, operational and commodity as classes of importance. They are reviewed on a regular basis and on their renewal cycle – all our key contracts have modern slavery clauses in them.
With regards to countries which may be considered higher risk, for IT, the key locations are Bulgaria for Ontotext and India for NEC Software and River Valley Technologies (RVT). All have UK offices / are part of larger international corporations. It is considered that the likelihood of risk is very low with these 3 suppliers and there was no impact in 2023.
As part of ongoing due diligence, regular meetings with suppliers in Bulgaria and India are held to ground truth the situation with regard to our key strategic suppliers – we look to visit at least once a year. For example in 2023 NEC Software were visited twice to discuss matters with their senior management, RVT visited in December and we have regular account manager contact. These regular meetings will continue into 2024+.
Our recruitment practices help prevent the risk of modern slavery within our organisation. Our employment agreements and policies are managed locally, based on global templates and principles but adapted for the relevant local context and applicable law.
Some of the other recruitment measures which the IET has in place include:
- Conducting vetting checks of prospective recruits before extending an offer of employment and a police (where appropriate) and reference check prior to start date (double-stage process);
- Conducting regular salary reviews to ensure that staff are paid a living wage in the countries it operates in, and benchmarking salaries to ensure that they remain competitive in the sector;
- Checking, but not withholding, identity documents and rights to work documentation;
- Providing information on workers’ rights in a language they can understand;
- Not allowing fines levied to be passed onto employees, for workers to be charged finders’ fees, and not deducting accommodation or transport costs from staff salaries.
Continuous review and risk mitigation
The IET Anti-Slavery Policy sets out the IET’s principal risk areas. The IET recognises the need to continually assess the risks of slavery or human trafficking. The IET also recognises that there may be gaps in visibility of supply chains and limitations in the tools used to identify risks. Addressing these is a complex task and is under continuous review to develop an effective framework. The IET recognises the need for modern slavery training across the organisation to widen awareness, particularly for those staff members who are involved in managing recruitment and our supply chains and during 2022 rolled out an eLearning module to all IET staff on Modern Slavery and this continued with a second roll-out of eLearning in 2023 and 99% of staff have completed this training within the last two years, across all global offices.
To date, the IET has not found any instances of modern slavery in its operations or supply chain.
This statement was approved by the Board of Trustees on 5 February 2024.