Notice of upcoming maintenance: Modern slavery statement
1. Background and Overview
1.1 This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps the Chartered Insurance Institute (CII) has taken, and continues to take, to prevent modern slavery within our operations and supply chains.
1.2 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 Hong Kong and the United Arab Emirates, as illustrated in the organisational chart.
2. Suppliers
2.1 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. Our core activities include membership, professional standards, qualifications, assessments, and continuing professional development.
2.2 The CII confirms that it engages with third-party providers to deliver examination services in several international locations. These include centers operated by PSI in Pakistan, Saudi Arabia, Türkiye, the United Arab Emirates, and Kuwait. Each of these centers is managed under contracts between companies registered in England, which contain enforceable obligations requiring compliance with all applicable laws, including those relevant to modern slavery and human rights.
2.3 While the CII does operate in countries outside the UK, it does not source goods or services directly from most of the top 10 countries identified as having the highest prevalence of modern slavery, according to the Global Slavery Index (https://www.globalslaveryindex.org/2018/findings/global-findings/). The only exception is the United Arab Emirates, where the CII maintains a regional office. In this location, goods and services procured are limited to essential office operations, including rental of premises, broadband, cleaning services, beverages, and local insurance policies. These suppliers are subject to procurement due diligence and are contractually required to comply with all applicable local and international laws, including those relating to modern slavery. The CII continues to assess risk in higher-prevalence jurisdictions through legal and procurement oversight processes, ensuring its ethical and regulatory standards are upheld.
2.4 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 in the process of finalizing 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.
2.5 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.
2.6 The CII’s core values underpin the way in which the CII conduct business. This extends to the procurement of suppliers.
The CII’s core values underpin the way in which the CII conduct business. This extends to the procurement of suppliers.
3. Our Commitment to Preventing Modern Slavery
3.1 All of our employees and members, irrespective of where they work, are bound by the CII’s code of ethics (https://www.cii.co.uk/media/9223937/cii_code_of_ethics.pdf), 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.
3.2 To support compliance with modern slavery legislation, the CII requires that all members of staff complete training which includes awareness of modern slavery obligations, both at induction and through annual refresher learning. In addition, the CII provides access to a dedicated modern slavery e-learning unit on its online platform, Assess, which is accessible to all employees and available for members to purchase.
3.3 Beyond training, the CII is committed to undertaking appropriate due diligence in its recruitment, procurement, and supplier management processes to help ensure that modern slavery does not occur within our organisation or supply chain.
4. Risk Management
4.1 The risks associated with Modern Slavery are effectively managed by the following:-
- Robust contractual processes to ensure alignment between legal obligations and supplier terms.
- Significant procurement of services from UK based suppliers, under legal obligations to meet key criteria including minimum wage payments, enforceable employment
- Recording of key overarching risks (including legal compliance and supply chain risk – of which Modern Slavery forms part) in dedicated Risk Management Software, able to document the risks, mitigations, controls, approach and appetite, with clear executive Allowing trends, themes and impacts to be recorded and assessed in real time.
- Oversight of risk management by an Executive Director and Head of Risk, with responsibility for identifying and enacting improvements to our risk management regime, including in respect of our supply chain risk.
- Annual review of the CII’s Modern Slavery statement by the Audit and Risk.
5. Key Performance Indicators
5.1 As part of our broader commitment to ethical business practices and in support of our responsibilities under the Modern Slavery Act 2015, the CII has embedded enhanced controls into its processes. These controls are designed not only to protect the organisation from commercial risk but to proactively reduce the likelihood of engaging, directly or indirectly with any parties involved in exploitative labour practices.
5.2 The CII’s Legal Team has developed the Legal Engagement Guidelines to assist all departments in identifying when legal input may be required. The aim of these guidelines is to support sound decision-making across a wide range of legal and compliance issues. In addition to this, every new CII employee is required to attend a compulsory Legal Induction session, delivered by the in-house Legal Team. This induction provides essential guidance on legal compliance, ethical obligations and includes specific reference to the CII’s policies. The session also outlines employees’ responsibilities when engaging with suppliers or partners and highlights the processes for escalating concerns or seeking advice.
5.3 Along with the above, the CII has developed and published a “Contract Risk Management Policy” which is designed to protect the CII from mistakenly entering into a contract, as well as providing information and guidance to those CII employees considering entering into a contract on the risks to be taken into account.
5.4 The CII’s Contract Risk Management Policy is a key component of our approach to managing modern slavery risk. The policy ensures that:
- All new supplier relationships are subject to appropriate legal and risk review;
- Contracts are approved only by authorised individuals who have followed internal governance processes;
- There is clarity around each party’s obligations, helping to reduce the risk of entering into relationships that could involve unethical or unlawful practices, including forced or child labour.
5.5 To support the above, the Legal team have also 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.
5.6 In addition to contract controls, the CII also adheres to its International Sanctions Guidance Policy, which is closely aligned with our anti-bribery and corruption principles. The guidance outlines key considerations before entering into agreements with suppliers or partners based in foreign jurisdictions.
5.7 This policy acts as an early warning and filtering mechanism, identifying countries or entities where legal, ethical, or political risks, including human rights and modern slavery concerns, are more likely to exist. In practice, this means:
- The CII does not conduct business in countries where full sanctions are in place (e.g. North Korea, Iran, Syria), as listed in HSBC’s sanctions lists and OFSI guidelines.
- Where partial sanctions or broader risks apply (e.g. reputational, political instability, poor human rights records), a due diligence process is triggered.
- Individuals seeking to engage in business in or with such jurisdictions are required to complete a detailed questionnaire covering areas such as sanctions, corruption, human rights, political climate, financial restrictions and staff safety.
- If any responses to the questionnaire raise concern (i.e. a “YES” answer), the completed form must be submitted to the CII Legal Team for further investigation and approval before any engagement can proceed.
5.8 To support the consistent application of these guidelines, the CII has a legal case management system that tracks and monitors all legal support requests. This system enables the Legal Team to identify emerging trends or instances where internal processes, such as the Legal Engagement Guidelines or other relevant policies, have not been followed. Where potential legal or compliance risks are identified, including those related to the Modern Slavery Act, the Legal Team is able to intervene promptly and take appropriate corrective action.
6. Ownership and Accountability
6.1 The CII’s executive leadership team has overall accountability for ensuring that the CII complies with the Modern Slavery Act
6.2 The General Counsel is responsible for ensuring that the CII complies with its Modern Slavery Act requirements.
6.3 This statement was approved by the CII Board on 25 September 2025 and has been signed by Liam Russell, General Counsel, on 25 September 2025.
6.4 If you have any queries on the CII’s compliance with the Modern Slavery Act 2015, please e- mail Legal@cii.co.uk
Liam Russell, General Counsel