ICPTBT01 - Ethics, Bribery & Modern Slavery Awareness

Company: ICP

Audience: Self-Employed Subcontractors

Duration: 5–10 minutes

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1. Why We’re Talking About This

ICP expects everyone working on our projects to act honestly and fairly.

Even though you are self-employed and not an employee, this talk explains the standards we expect while you are working on ICP sites.

We have zero tolerance for:

• Bribery or corruption

• Forced labour or human trafficking

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2. Bribery – What You Need to Know

Bribery means offering, giving, asking for, or accepting something to gain an unfair advantage.

On site, this could include:

• Cash or gifts to influence decisions

• Paying someone to skip checks or inspections

• Favouritism in return for money or benefits

  
  

What’s OK:

• Normal site hospitality (tea, coffee, basic lunch)

  
  

What’s NOT OK:

• Cash payments

• Gifts or expensive hospitality linked to ICP work

• “Favours” to get work, access, or approvals

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3. Modern Slavery – What to Look Out For

Modern slavery includes:

• Forced or bonded labour

• Workers being threatened, controlled, or unpaid

• People forced to work to repay debts

• No control over ID, pay, or working conditions

  
  

Warning signs:

• Workers afraid to speak

• Someone else controlling pay or documents

• Poor or unsafe living conditions

• Workers not free to leave

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4. What ICP Expects From You

While working for ICP, you must:

• Act honestly and lawfully

• Not offer or accept bribes

• Treat others fairly and with respect

• Report concerns about bribery or slavery

• Comply with UK law, including the Bribery Act and Modern Slavery Act 2015

Failure to follow these standards may result in removal from site or termination of contract.

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5. Reporting Concerns

If you see or suspect:

• Bribery

• Corruption

• Forced labour or exploitation

Report it to ICP management. Concerns will be taken seriously and handled fairly.

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6. Key Message

✔ Act honestly 

✔ Don’t offer or accept bribes 

✔ Look out for exploitation 

✔ Speak up if something doesn’t feel right

These standards protect you, ICP, and everyone on site.