Statement on modern slavery FY 2021
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Statement on modern slavery FY 2021

Overview Of The Association of International Certified Professional Accountants (The Association) and The Modern Slavery Act UK 2015

About The Association

The Association of International Certified Professional Accountants (the Association) is the most influential body of professional accountants, combining the strengths of the American Institute of CPAs (AICPA) and The Chartered Institute of Management Accountants (CIMA) to power opportunity, trust and prosperity for people, businesses, and economies worldwide. In 2017, members of CIMA and AICPA formed the Association to unite and strengthen the accounting profession globally. The Association represents 696,000 members and students across 192 countries and territories in public and management accounting and advocates for the public interest and business sustainability on current and emerging issues. With broad reach, rigor and resources, the Association advances the reputation, employability, and quality of CPAs, CGMAs and accounting and finance professionals globally.

The Modern Slavery Act 2015 (UK)

The Modern Slavery Act came into force on 26 March 2015. The Act clarifies the existing offences of slavery and human trafficking and introduces tougher penalties.

Section 54 of The Act requires commercial organizations in any sector with a global annual turnover of £36m or more who do business in the UK to publish a statement each financial year setting out the steps we have taken to ensure that no slavery or trafficking is taking place in our business and supply chain.

The term ‘modern slavery’ describes exploitation so severe that people are not able to leave their place of work. ‘Slavery’ refers to the condition of treating another person as if they were property, something to be bought, sold, traded, or even destroyed. Victims may be ‘owned’ by their employers and controlled through means including massive recruitment debts that they are unable to pay off, and threats of harm if they try to leave. The significant characteristic of all forms of slavery is that they involve one person depriving another person of their freedom.

Due to the nature of our business and the products and services we source and sell, we consider the risk of slavery and human trafficking in our business and supply chains to be very low. However, we aim to periodically review the effectiveness of the relevant policies and procedures that we have in place.

Despite the level of risk, we have implemented multiple layers of protections to help identify and mitigate the risk of slavery and human trafficking occurring in our business and supply chains.

Situations that may present a particular risk of modern slavery include:

  • Where workers have fewer protections through inadequate laws and regulations, weak or non-existent enforcement, and poor business and government accountability;

  • Where there are high levels of poverty among workers;

  • Where there is widespread discrimination against certain types of workers (e.g., women and ethnic groups);

  • Where there is widespread use of migrant workers;

  • In conflict zones, and;

  • In some specific high-risk industries (typically industries involving raw materials).

The risk of modern slavery affects almost every industry globally. As well as the potential for legal sanction, companies that fail to take effective action may also suffer severe reputational damage and loss of market share. The Association takes this risk very seriously.

Measures to address modern slavery in The Association’s supply chains

The Association will undertake the following measures in the calendar year 2022 to manage the associated risks of modern slavery in its supply chain:

Association Policy

The Association has adopted the following policy on modern slavery:

“The Association is committed to upholding the highest ethical and professional standards, and to maintaining public confidence in public and management accounting. As part of that commitment, we will use our best endeavours to identify and mitigate the risks of modern slavery and human trafficking by:

  • Never supporting or dealing with any business knowingly involved in slavery or human trafficking;

  • Ensuring our suppliers and business partners understand our expectations of what is acceptable business behavior, including this policy; and

  • Where necessary asking our suppliers and business partners to adopt suitable anti-slavery and human trafficking policies and procedures.

The Association’s leadership team will ensure that staff are aware of this policy statement and that any further steps are implemented to prevent slavery and human trafficking within The Association and its supply chains. This policy will be reviewed annually”

Staff are made aware of the Modern Slavery Policy and encouraged to report any concerns they have to the Senior Leadership Team.


During the new supplier process, suppliers will be directed to the Association's Statement to ensure that they are aware of and adhere to The Act.

The Association is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of its business. This statement reflects its commitment to acting ethically and with integrity in all its business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in its supply chains.

The Association requires that each of its suppliers complies with all laws, rulings, and regulations in the jurisdictions where they do business. This includes laws related to equal opportunities and non-discrimination, and laws prohibiting human trafficking and slavery. The Association's staff are encouraged to report to management if they suspect that any supplier is engaging in unethical behaviour.

Contract Provisions

The Association will ensure that its contractual arrangements with new or existing suppliers support its modern slavery policy.

Due Diligence Processes

As part of the Association's initiative to identify and mitigate risk, it has in place systems to:

  • Identify and assess potential risk areas in its supply chains.

  • Mitigate the risk of slavery and human trafficking occurring in its supply chains.

  • Monitor potential risk areas in its supply chains.

  • Protect whistle-blowers.

As part of the review and ongoing development of the Association's supplier relationships, it continues to specifically assess the slavery and human trafficking risks arising from each such relationship and identifies appropriate steps to address any risks identified. Such steps may include placing appropriate contractual obligations on suppliers, working with the supplier to make improvements/corrective action plans, or ceasing to work with a supplier entirely.

The Association uses the following key performance indicators to measure how effective it has been at ensuring that slavery and human trafficking is not taking place in any part of its business or supply chains:

  • The percentage of suppliers and sub-contractors vetted for ethical labour practices.

  • The number of inspections of direct suppliers and sub-contractors in its supply chains in the past year.

  • The number of reported breaches in the past year.

  • Percentage of staff receiving training on identifying and addressing the risk of slavery and human trafficking in its business and supply chains.


The Association will continue to encourage whistleblowing to identify breaches of policy and contractual provisions in respect of modern slavery. Reporting systems are in place to ensure that whistle-blowers' identities are protected and that they have HR, Procurement and Senior Leadership support.

Supply Chain Assessment and Reviews

The Association will seek to identify vulnerabilities through supply chain assessment and reviews. While it is impractical for the Association to audit and monitor each supplier in its entire supply chain at all levels, it will identify key vulnerabilities and will take a risk management approach to ethical procurement and contracting. The Association will ensure that its tender processes assist in assessing supplier compliance with the law.

Training and Awareness

The Association's internal policies and procedures aim to ensure that its members understand and comply with all laws, rulings, and regulations in its area of business.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in its supply chains and business, the Association provides annual ethics and compliance training to its employees. Managers are required to be trained annually on all laws affecting their global businesses and that includes laws prohibiting human trafficking and slavery.

Report on the 2021 Financial Year

The Association is not aware of any breaches of the Modern Slavery Act 2015 in the context of its business operations or amongst its current supply chain during the financial year 2021 following the close of the financial year.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Association's slavery and human trafficking statement for the financial year ending 12/31/21. It was approved by the board on 11/17/20.

Elisabeth Pinekenstein, January 13, 2022