Modern Slavery Policy

This statement is made pursuant to the Modern Slavery Act 2015 and sets out the policy that CIBT has taken and continues to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. CIBT has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Business

CIBT is a global mobility company providing specialist visa and immigration services worldwide. Our corporate head office is in McLean, Virginia, USA. We have offices in London’s Union Street – we have offices globally and our network of in-country partners are regulated by the standards of legal practice in their country of operation, with standards that typically uphold and dictate exemplary ethical behaviour and conduct concerning the rights of and thereby the protection of human beings in any area that may considered as slavery.

Values

CIBT is committed to providing quality services to all its clients and ensuring that quality relationships with all its suppliers and related third parties are in place.

Supply Chain and due diligence

CIBT has a zero-tolerance policy for any modern slavery risks that it identifies. CIBT clearly communicates its expectations to suppliers to ensure adherence of its values and ethical standards, it has in place appropriate policies and processes within its businesses to make sure that the services it provides are provided to the highest standards and it requires compliance with its principles when dealing with all third parties.

Our Policies

We enforce a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These policies include:

  1. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility verifications to work in the country of hire.
  2. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, anonymously and without fear of reprisals.
  3. Internal compliance training. We have a robust and mandatory compliance training package in place for all employees working on global immigration matters.
Our Next Steps:

As part of our efforts to improve on the effectiveness of our systems, we will evaluate additional steps during the course of 2021, including exploring opportunities to expand our whistleblowing policy externally and tracking attendance on specific and mandatory training modules around forced labour and human trafficking for all CIBT employees.

Our Performance Indicators

CIBT carries out audits and, where issues are identified, it works with the third party to ensure improvements are made. These audits include meetings with workers and the management and document reviews.

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

This Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes CIBT’s slavery and human trafficking statement for the previous financial year 2020.

Approval for This Statement

This statement was approved by:
Name: Eric Scheinerman, CEO
Date: 01 August 2021