Sustainability

A commitment to safeguarding the environment and operating in a sustainable manner is a key deliverable of ICG strategy. A continuous focus on improving operational efficiencies results in lower inputs and wastage levels, and maximises asset lives all of which ultimately improves our environmental performance.

In recognising that small changes can deliver cumulatively large efficiencies over time, ICG has developed a Group-wide environmental framework, the objective of which is to facilitate the continuous improvement of the environmental effects of the Group’s activities in a unified and structured manner. The key to this is to leverage the information and knowledge gathered as part of our regulatory compliance obligations to drive awareness of individual actions in reducing our operating footprint.

On a wider societal level the Group plays a pivotal role in Ireland’s traded goods logistical chain while Irish Ferries’ passenger services contribute significantly to the tourism industries of Ireland, the UK and France.

The Group’s principal activity is the operation of ships and provision of related services. While transport by sea is one of the most efficient modes of transport, these activities still have an unavoidable impact on the environment. This report provides a summary of the principal initiatives implemented by the Group to minimise this impact over four key areas; emissions, waste and resource use, employee health and safety, and diversity and inclusion.

Our Purpose

Our purpose is to achieve continued success in our chosen markets, delivering a safe, reliable, timely, good value and high-quality experience to our customers in a way that minimises our impact on the environment.

The successful delivery of the Group’s customer value proposition is underpinned by a commitment to minimising our environmental impact and enhancing the sustainability of all Group activities.

Sustainable success for the Group means operating in harmony with the environment and contributing to a prosperous future for all our stakeholders. In working towards this vision, the Group endorses the United Nations (UN) Sustainable Development Goals (SDGs). The SDGs were first adopted by UN member states in 2015 as an urgent call to address 17 global environmental and socioeconomic issues with the ambition to meet 169 related targets by 2030. While not all SDGs can be tackled by the Group, we have prioritised five areas where we can positively contribute and are committed to in our sustainability initiatives.

In addition to our commitment to the SDGs, we continue to review established Environmental, Social, and Corporate Governance (ESG) and sustainability reporting frameworks as part of our commitment to enhanced disclosure and transparency, and our process to set meaningful KPIs for the business. Our review of various frameworks includes the requirements set out by Sustainability Accounting Standings Board (SASB) and the Taskforce on Climate-related Financial Disclosures (TCFD). We include within this report many of the reporting metrics set out in these frameworks and intend to further enhance our reporting during 2021 for our Annual Report in 2022.

Sustainability and Governance

During 2020, we commenced a rigorous review of our approach to oversight and governance of sustainability, which is central to the development of an effective strategy. That review has already led to the allocation of additional resources to assist with the implementation of the Group’s sustainability programme and enhancing the Group’s disclosure. While sustainability is a key focus for the Group, the review will include an in-depth evaluation of the terms of reference of the Board’s sub-Committees, our reporting framework and engagement with stakeholders.

The Voyage Ahead

The Group plays a major role in Ireland’s international logistics chain while Irish Ferries’ passenger services contribute significantly to the tourism industries of Ireland, the UK and France. With consideration for these societal roles, the Group acknowledges a responsibility to ensure our services are delivered in a manner which protects our shared environment and reflects the values of wider society.

While the Group has focused on sustainability initiatives for many years, our approach has needed to evolve to manage our ESG responsibilities in a combined, systematic way, resulting in the development and evolution of our Group-wide environmental framework. Our current ESG maturity level and the stages involved in the voyage ahead are outlined below:

Timeline

Maturity

Prior to 2020

Fragmented

  • Sustainability measures were managed within the relevant departments.
  • Sustainability measures focused on regulatory and compliance activities,such as IMO 2020.
  • No overall policy encompassing all areas of sustainability.

2020–2021

Organised

  • Enhanced understanding of the full range of Group activities that carry an ESG impact.
  • Sustainability is a key component of Group strategy.
  • Review of sustainability reporting frameworks.
  • Focus on data collection, identifying baselines and developing KPIs across all ESG areas.
  • Design of sustainability management programmes such as ‘Green Voyages’.

2022–2025

Effective

  • Further sustainability targets to be set across our ESG areas.
  • Sustainability programmes within our operations to be fully implemented and effective.
  • Enhanced reporting of ESG metrics in line with emerging reporting standards.

After 2025

Influential

  • Progress towards the IMO’s CO2 reduction targets of 40 per cent by 2030, towards helping to achieve UN SDGs for 2030 and towards further targets set by the Group.
  • Sustainability embedded in the ICG culture and in all key decisions made.
  • Looking beyond our own operations to assess and positively influence the ESG activities of all entities that conduct business with the Group.

Emissions

The Group strives to achieve continuous improvement in reducing its greenhouse gas emissions through investments in efficient systems, plant and equipment and adopting well researched techniques.

The Group complies with the provisions of MARPOL (The International Convention for the Prevention of Pollution from Ships) Annex VI – Prevention of Air Pollution from Ships. This is the main international treaty addressing air pollution prevention requirements for ships and imposes limits on nitrogen oxide (NOx) emissions from both main propulsion and auxiliary engines and limits on the sulphur content of marine fuels.

In 2020, new limits on sulphur content of fuel oils came into effect, adding to the already imposed 0.10% content sulphur limit when operating within the Sulphur Emissions Control Area (SECA). A 0.50% content sulphur limit was implemented from 1 January 2020 when vessels are operating in all other areas. These requirements have resulted in a significant global reduction in overall sulphur oxide (SOx) emissions from the shipping sector which will improve the air quality and the health of populations. To achieve these goals, the Group committed approximately €25 million to install exhaust gas cleaning systems (EGCS) in our owned and operated fleet. As at 31 December 2020, ECGS are fully installed on

  • W.B. Yeats
  • Ulysses
  • Elbcarrier
  • Elbfeeder
  • Elbtrader
  • CT Rotterdam

Following the completion of installation work on board the Ulysses, the Isle of Inishmore was scheduled to begin EGCS installation work in March 2020. However, due to the advent of Covid-19 it was postponed because of the associated project risks and health risks of undertaking the work during a pandemic. A decision to retro-fit EGCS on the Isle of Inishmore has been deferred further due to schedule requirements. In conjunction with the original equipment manufacturer, propulsion engine components on board the Isle of Inishmore are being developed for methanol consumption which we hope may ultimately help towards achieving our greenhouse gas reduction targets.

The Dublin Swift by design consumes marine gas oil which has a delivered sulphur content of less than 0.1% thus already in compliance and bettering the new regulatory requirement in its geographic area of operation. We continue to engage with our stakeholders, including our fuel suppliers and engine manufacturers to ensure we are positioned to become an early adopter, once a pathway to alternative fuels, including biofuels, becomes clearer.

CO2 emissions and fuel consumption

All vessels owned and operated by the Group report annual CO2 emissions, fuel consumption, transport work and average energy efficiency under the EU Monitoring, Reporting and Verification guidelines (MRV). Since MRV data has only been reportable from 2018, our insights from MRV results to date have been limited. We continue to evaluate the reporting methodologies across our activities to ensure we manage our consumption and efficiencies most effectively going forward.

Number of sailings

Total CO2 (mt)

kgCO2/nm

gCO2 per transport work(gCO2/nm.mt)

Group company

2020

2019

2020

2019

2020

2019

2020

2019

Irish Ferries

4,501

4,934

240,068

259,687

632.52

644.45

72.83

76.95

Eucon

522

616

94,660

106,450

257.94

265.04

43.44

44.53

Total CO2 and fuel consumption on sailings

2020 (mt)

2019 (mt)

Total fuel from sailings

107,300

122,000

Total CO2 emissions from sailings

334,676

366,137

Note: the 2020 aggregated data above is preliminary and subject to ship MRV audits.

While the Group is committed to a continued reduction in emissions and ongoing efficiency improvements to reduce fuel consumption per sailing, the decline in 2020 from 2019 also reflects the impact of Covid-19 where lower passenger and cargo volumes had a positive impact on reducing overall emissions levels and allowed practices that minimised fuel consumption to be employed.

Refrigeration and air conditioning emissions

All owned vessels are fully compliant with the EU Fluorinated Gases (F-gas) Regulation restricting the usage of certain hydrofluorocarbons (HFCs) and imposing bans on certain other HFCs with the highest global warming potential. The F-gas Regulation seeks to phase-down the use of HFCs by cutting F-gas emissions by two-thirds by 2030 compared with 2014 levels. This phase-down process is aligned with the Kigali Amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer which was ratified by the EU in 2018. The Group has targeted a zero-leak environment by 2022.

Efficient operations

Under IMO requirements each vessel has developed a Ship Energy Efficiency Management Plan (SEEMP). The SEEMP contains a multitude of measures intended to improve the energy and environmental efficiency of a ship in a cost-effective manner. While all plans are vessel-specific, they each follow a Plan-Do-Check-Act iterative cycle for improvement.

Key SEEMP measures, all of which improve the fleet environmental performance include;

  • Speed optimisation for sea conditions
  • Fuel efficiency maximisation
  • Minimisation of hull resistance through sailing parameter optimisation
  • Engine performance management
  • Refrigeration gas consumption
  • Boiler performance management
  • Bunker management

In 2020, we introduced the Green Voyage programme to improve the operational efficiency of our ferries. For each vessel a standard operational profile was identified and takes into account factors such as;

  • Efficient port operations
  • Navigational routing
  • Trim of vessel
  • Weather conditions
  • Speed management

An individual voyage is classed as a Green Voyage when it is conducted using reduced levels of machinery such as main engines, propeller shafts and generators than its standard operating profile, resulting in a reduction in fuel consumption and related emissions. Over sustained periods, increased numbers of Green Voyages shall also lead to reductions in planned maintenance due to reduced machine running hours, thereby improving schedule integrity.

The Group intended to use voyage data in 2020 as a baseline to monitor performance in subsequent years, however, due to Covid-19 and its impact on both passenger and freight volumes, baselining has been postponed until normal levels of activity resume. Nonetheless, the programme provided an excellent tool for managing the challenges faced during the year in ensuring that fuel consumption was minimised and machinery was operated at its most efficient.

A project is currently underway to integrate the Green Voyage programme within our new fleet performance management solution, ECO Insight. Following a trial period, ECO Insight was rolled out across the fleet in the final quarter of 2020. It provides real time analysis of vessel KPIs and impacting factors including fuel consumption, speed, operating configuration, weather conditions and more which allows for improved ship-to-shore communications and for joint decisions on efficiencies to be made promptly.

Efficient design

The efficiency characteristics of our fleet commence at the design phase with incremental improvements made over the life of a vessel. When commissioning new vessels, the Group is committed to the application of innovative design features intended to minimise environmental impact. By law, all new ships from 2013 onwards require an Energy Efficiency Design Index (EEDI) whereby new ship designs must meet an efficiency reference level.

The W.B. Yeats has a required EEDI of 18.5g of CO2 per tonne-mile, which represents a 10 per cent efficiency improvement above baseline. Any new vessels built will fall under the subsequent EEDI phases. For example, phase two which applies to vessels built between 2021-2025 are required to have a design efficiency of at least 20 per cent above baseline, which would be a 10 per cent improvement in efficiency over the W.B. Yeats. An additional increase to 30 per cent above baseline will be effective from 2025 onwards.

To assist further with its goal to reduce carbon intensity by 40 per cent within the decade, the IMO in November 2020 approved amendments to MARPOL Annex VI to introduce an Energy Efficiency Design Index for existing ships (EEXI). Like the EEDI, EEXI will provide a specific rating to an existing ship design, expressed in CO2 per ship’s capacity mile. Expected to be implemented by 2023, the Group is actively working on proposals to ensure compliance and reduce emissions across the fleet in the forthcoming years.

In opting for EGCS, the Group performed a thorough assessment of alternatives, including a conversion to Liquified Natural Gas (LNG) fuels and found the EGCS option to be the safest and most environmentally friendly solution. In addition to managing sulphur emissions, studies have shown that EGCS can remove 60 to 90 per cent of particulate matter (PM or black carbon), including a portion of small and ultrafine PM, resulting in fewer particles released in the atmosphere compared to consuming 0.5% fuel oils or marine gas oil.

At our Dublin Terminal, we added two additional electrically powered rubber-tyred gantries (RTGs) to the fleet in 2020 to bring the total number of electric RTGs to four. The advantages over fuel powered RTGs are; greater efficiency due to zero idling, lower emissions and noise levels. The increased electrification and automation of our container stacks also help improve the level of occupational safety in the port.

The £40m re-investment project by Belfast Harbour Commissioners (BHC) is well underway which included the delivery of eight new electrically operated RTGs. In December 2019, six RTGs were delivered with a further two delivered in June 2020. Of the eight RTGs, five are commissioned and in use with the remaining three to be commissioned during 2021.

The W.B. Yeats, Ulysses and certain container vessels in our fleet are fitted with EGCS. EGCS utilises seawater in a process to remove sulphur and other particulate matter from the engine exhaust gases prior to release into the environment. Before releasing the cleansed exhausted gases into the atmosphere, the removed sulphur can be discharged to the sea in the form of sulphites along with the treated wash water. Sulphites are substances naturally occurring on the seabed.

The W.B. Yeats and Ulysses are fitted with the latest energy efficient propeller blades. These incorporate rotating propeller caps which decrease propeller resistance and increase thrust. This increases overall propulsion efficiency and reduces fuel consumption.

Waste and Resource Use

Ballast Water Management

The intake and discharge of ballast water (seawater) is an integral part of vessel stability management. However, poor management of ballast water systems can damage local biodiversity through transference of non-native marine species.

The Group has implemented a Ballast Water and Sediments Management Plan across its fleet for the enhanced management of ballast water to help prevent the spread of non-native marine species by transference. The W.B. Yeats has already been designed with ballast water treatment systems. In 2021, the Group will install ballast water treatment units onboard Ulysses, Epsilon and Thetis D along with engineering and procurement for the installation on the Isle of Inishmore and the remaining container vessels in early 2022. Pending completion of these upgrades, the operating protocol is that all ballast water is loaded and discharged at the same location to avoid species transfer.

Water conservation

All fresh water used on board our vessels is of potable standard. As this is both a scarce resource and an increasing cost, the Group seeks to reduce consumption on board vessels through water saving devices such as flow controllers without interrupting our guests’ comfort. Water conservation is covered within our environmental awareness guidelines for crews.

Paint

A key factor that affects vessel performance besides the optimal engineered design of the hull is the maintained condition of the hull itself. Central to this is maintaining a smooth underwater hull surface to reduce resistance when moving through the water. Once in service a vessel’s hull is exposed to corrosion and fouling, which studies indicate can adversely affect fuel consumption by up to 4 per cent. To maintain maximum efficiency as part of ongoing maintenance our vessels utilise modern silicon-based non-toxic paints which avoid the release of harmful agents into the sea. These assist in preventing corrosion thereby ensuring maximum hull life, reducing fouling between drydocking periods and lowering the risk of damage to local biodiversity.

Hazardous materials

There has been increased onus on the use of non-hazardous materials in designing and operating ships. From 31 December 2020, ships above 500 gross tonnes that fly the flag of an EU/EEA member state, or third-party vessels calling at European ports, must carry an Inventory of Hazardous Materials (IHM) certificate on board to demonstrate the control of hazardous materials on ships in compliance with both the EU Ship Recycling Regulation (SRR) and the Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships.

All vessels underwent thorough survey and inspection during the year to ensure IHM certification was in place as required.

Oil waste

The disposal of waste at sea is strictly prohibited by regulation and all vessels have a waste disposal plan which includes procedures for minimising, collecting, storing, processing and disposing of waste in line with MARPOL requirements. All vessels use oil recovery systems to recover spent oils which are then sent for recycling to processors with regulatory approvals. Group personnel perform periodic inspections at the treatment facilities of our service providers to ensure high standards are maintained by our recycling and resource recovery partners.

Responsible consumption

Single-use plastic is a significant threat to ocean life and to the wider planet. It is estimated there are over 150 million tonnes of plastic in the world’s oceans and each year one million birds and over 100,000 sea mammals die from ingesting or becoming entangled in plastic waste.

We made a commitment in 2019 to remove single-use plastics and other non-compostable consumables from our restaurants. In 2020, we joined the pledge by the UK Chamber of Shipping to remove all single-use plastics from our vessels and not just from our restaurants. We worked closely with our partners to identify and remove all single-use plastic items from our procurement templates and replace with compostable substitutes or alternatives. Among the single-use plastics replaced were;

  • Plastic beverage bottles
  • Food wrappers
  • Plastic bottle caps
  • Plastic straws
  • Plastic carrier bags
  • Plastic containers and lids
  • Cotton buds
  • Plastic packaging (from food, household items, laundry items etc.)
  • Plastic ropes / coverings
  • Plastic cartons and condiment sachets
  • Plastic cutlery
  • Plastic cups and plates

Each crew and office department have designated waste management champions. Their responsibilities are to ensure vessels and office areas are compliant with agreed procedures, to perform checks at waste segregation areas and to improve awareness of responsible consumption methods within their respective areas. During 2020, there was some temporary reintroduction of single-use materials as preventative measures for Covid-19, such as takeaway meals for freight drivers, but we are striving to ensure that compostable and recyclable materials are used as much as possible.

We minimise the number of deliveries to our vessels through containerised provisioning. Our supply chain partner also offers procurement of any new items requested on board our vessels to other customers, ensuring consistent warehouse supply and efficient use of delivery vehicles.

Office waste

While reliable comparisons on total waste volumes cannot be made between 2020 and prior years due to the number of staff working from home in 2020, our ratio of recycled waste to overall waste improved by 72 per cent on 2019.

Responsible cleaning and hygiene

Our cleaning products used for hospitality services are innovative, safe and environmentally friendly. Our cleaning chemicals supplier is a global leader in water, hygiene and infection prevention solutions.

We work with one of Ireland’s leading laundries whom we are satisfied is accredited as complying with a high environmental standard with a commitment to minimum use of harmful detergents and a recycling program.

In our cabin accommodation we use ozone sanitary systems which have high oxidant power to eliminate odours and harmful bacteria and viruses while significantly reducing the use of chemical products.

Our tissues and napkins are ergonomically packaged to remove all unnecessary waste.

To protect our passengers and crew from Covid-19, all communal spaces on board our vessels are rapidly sanitised after each sailing using electrolysed water systems. These non-toxic and environmentally friendly systems use unique electrolysis cells to generate hypochlorous acid (HOCI) in solution through salt and water. The HOCI molecule is electrically neutral with high oxidation potential and has been shown in studies to work well against viruses including norovirus and human coronaviruses.

Employee Health and Safety

The protection and well-being of our staff, crews and other personnel who act on behalf of the Group is our main priority. Having a strong safety culture is critical for operating large ships and active container yards.

Training

We work closely with our technical managers who ensure crews receive appropriate health and safety training throughout the year. Prior to joining our crews, seafarers are required to have appropriate certification and registrations with the relevant flag authority. Among the training courses undertaken in 2020 were;

  • STCW mandatory seafarer basic safety training for ship officers and crew.
  • Crowd control training for ship officers and crew.
  • Crisis control training for ship officers.
  • Passenger safety, car deck safety and hull integrity training for deck and engine crew.
  • Food safety training for ship pursers and hospitality crew.
  • Firefighting training for crew with advanced training for deck and engine officers.
  • Lifesaving equipment training for crew with advanced training for deck and engine officers.
  • Lifeboat and rescue training for crew with advanced training for deck and engine officers.
  • Medical care training for ship pursers and chefs.
  • Human Element, Leadership and Management training for ship officers.
  • Security Team and Conflict Management Training for ship officers, pursers and selected crew.

Safety induction training is required for all individuals, including workers, drivers and guests before entering our container terminals. On-site dedicated health and safety officers are also deployed.

657
fully dedicated training
days for Irish Ferries
crew in 2020

Safety Inspection

Compliance with policy and procedures, both ashore and afloat, is monitored by regular and detailed audits. Audits are conducted by trained and experienced auditors in an open yet focused manner that drives compliance and improvement. Senior management monitor safety and audit performance across the Group, identifying and addressing safety trends and opportunities for improvement where they may arise.

In addition to the Group’s own internal verification procedures, our activities are subject to regular routine inspection by national and international statutory bodies. They, like us, set high standards to ensure the safety and well-being of all personnel, passengers and cargoes; standards that we as a Group are ready to meet and exceed.

On land: As a minimum, all the Group’s activities are conducted in strict compliance with the various statutory health and safety standards and international maritime regulations that apply. In accordance with the Safety, Health and Welfare at Work Act 2005 and its equivalents in other jurisdictions, the Group has in place safety policies and safety statements that guide our activities. We have in place a system of hazard identification and risk assessment that ensures all necessary steps are taken to minimise and mitigate safety risks. Agreed procedures ensure that activities and operations are conducted in a consistent and safe manner. By fostering a culture of employee competence and participation we empower our employees to continuously improve the efficiency and safety of our activities, contributing to a safe environment for all.

At sea: The Group ensures that all its vessels are designed, operated and maintained in compliance with the International Convention for the Safety of Life at Sea (SOLAS). This Convention is administered by the UN’s International Maritime Organisation and is subject to continuous international review and updating, ensuring vessel safety standards keep pace with societal expectations and technological advances.

The safety and security of crews, passengers and cargoes is critical to our business, and is always the primary consideration. The Group’s vessels are certified in accordance with the International Safety Management (ISM) Code, the international standard for the safe management and operation of ships and for pollution prevention.

The Group also operates in full compliance with the International Ship and Port Facility Security (ISPS) Code on board all vessels and at all locations. The onboard management of vessels was performed by experienced third-party ship managers on behalf of the Group. While the focus is on accident prevention where incidents do occur, effective internal and external reporting and investigation systems are employed to identify the cause of such incidents and put in place actions to prevent recurrence. Due to the highly regulated environment in which we operate, incidents may be subject to external investigation by the appropriate regulatory authority. The Group will always assist the authorities in any such matters.

2020

2019

2018

Exposure hours ‘000

LTIF

Exposure hours ‘000

LTIF

Exposure hours ‘000

LTIF

ICG employees

595

0.0

595

1.7

595

1.7

Key contractors

2,091

6.7

2,979

5.7

3,192

3.4

Total

2,686

5.2

3,574

5.0

3,787

3.2

2020

2019

2018

LTIF on land

6.3

6.3

5.4

LTIF at sea

4.7

4.6

2.5

Lost Time Injury Frequency

Lost Time Injury Frequency (LTIF) measures the number of recordable workplace incidents resulting in lost days over a year per million hours worked. The Group has a targeted LTIF for its activities on land of <5 and <3.5 for its activities at sea by 2023.

Covid-19

Significant efforts were made throughout 2020 and 2021 to protect staff, key contractors and customers from the risk of infection from Covid-19 while maintaining essential travel and freight services within the markets we serve.

On land, we;

  • Appointed Lead Worker Representatives.
  • Purchased additional laptops, mobile phones and equipment to enable office staff to work from home.
  • Introduced mandatory security awareness training for staff working remotely.
  • Spread out office workspaces to ensure social distancing was maintained.
  • Required the wearing of facemasks when moving within our buildings.
  • Installed sanitisers throughout our buildings.
  • Displayed signage throughout our buildings.
  • Enhanced daily cleaning procedures within all our buildings.
  • Conducted regular deep cleaning of all our buildings.
  • Implemented procedures to be followed in the event of a suspected case within our offices.
  • Circulated guidance to staff on an ongoing basis as new information emerged.
  • Closed our gym facility in line with the imposed restriction levels.
  • Operated our staff canteen services on a takeaway basis.
  • Conducted our meetings virtually.

At sea;

  • All crew were required to take Polymerase Chain Reaction (PCR) tests three days before onboarding.
  • All crew were required to take rapid antigen tests immediately on boarding our vessels.
  • Crew and passenger cabin management techniques were deployed.
  • Passenger numbers were monitored on board to ensure social distancing on board vessels.
  • Cleaning and sanitation procedures were enhanced.
  • Fogging machines for rapid sanitation were deployed.
  • The wearing of facemasks for all crew was required outside of cabins.
  • The wearing of facemasks was required for all passengers, drivers and visitors.
  • Form completion and temperature checks were required for all ship visits and inspections.
  • Detailed social distancing procedures were implemented to socially distance all crew.
  • Crew recreation arrangements were adjusted to ensure separation between crew from different departments and from different shift hours.
  • Procedures were implemented to be followed in the event of a suspected case onboard.
  • Arrangements were secured with shoreside hotels for immediate isolation of crew upon arriving at ports with a suspected case.
  • Signage and announcements were enhanced to passengers and drivers.
  • Sneeze guards and screens were erected at all customer contact points.
  • Crew changes were staggered to limit exposure to crew on board.

Anti-slavery and human trafficking

The Group imposes strict obligations on the entities responsible for the technical and crewing management on board its vessels, the applicable contractors it employs and its management teams to comply with all applicable laws, including those relating to labour and employment practices. The Group requires a due diligence process to be conducted prior to the appointment of a contractor together with in-contract reviews.

Within its day to day operations, the Group has in place a range of measures to help ensure modern slavery and human trafficking are not taking place in its business or its supply chains. Measures adopted include;

  • Provision of guidance to employees to support immigration and border agency initiatives to reduce human trafficking, which augments general observation for unusual behaviour in our ports and on board our vessels. Awareness of this issue is promulgated across all Group businesses.
  • Working with other companies and organisations to share knowledge, learning and best practice and co-operating with a series of law-enforcement projects that help to combat human trafficking and modern slavery.
  • Regular updates to management and committees on modern slavery so that Directors and key individuals understand their role and accountability for the prevention of modern slavery occurring in our businesses and supply chains.
  • Actively monitoring our initiatives in preventing modern slavery and human trafficking by reference to reports and alerts from staff, the public and communication with law enforcement agencies.

Anti-bribery and corruption

The Group’s gifts and entertainment policy applies to all staff, vendors, contractors and others who may be assigned to perform work or services for the Group. All forms of bribery or business courtesies that may create the appearance of a bribe are strictly forbidden. Limits and pre-approval requirements are imposed on the quantum and frequency of business courtesies received by staff.

Whistleblowing

The Group’s whistleblowing policy provides a safe and secure mechanism to be followed where an employee wishes to raise in good faith a genuine concern about possible malpractices including, but not limited to;

  • Fraudulent acts of any concern.
  • Corruption, bribery or blackmail.
  • Theft of money, property, intellectual property or any other assets of the Group.
  • Misuse of Group resources or employee privileges.
  • Falsification of any customer, supplier or other account.
  • Collusion with any customer, supplier or other party not in the best interests of the Group.
  • Failure to comply with a legal or regulatory obligation.
  • Endangering the health and safety of an individual.
  • Misrepresentation or concealment of material facts relating to any of the above.

All persons covered by the policy are protected from victimisation, harassment or disciplinary action as a result of any disclosure, where the disclosure is made in good faith and not made maliciously or for personal gain. Where disclosures are made in the public interest, staff will have statutory protection in Ireland under the Protected Disclosures Act 2014.

In 2020 there were no (2019: nil) reported matters through the Group’s whistleblowing channels.

Sustainable tourism and economic growth

For Irish Ferries passenger services, work is conducted in collaboration with the following tourism bodies;

  • Tourism Ireland
  • Visit Wales
  • Cotentin Tourism
  • Normandy Tourism

Co-operative campaigns are devised to promote sustainable tourism to address the areas and times of year requiring the most support which helps reduce seasonality difficulties in the least visited areas and attractions.

Where possible we seek to increase the use of local suppliers and showcase local produce in supporting artisan producers. Typical examples include our fish supplier, a large, family-owned fishmonger based in the fishing town of Howth in North County Dublin who supply locally sourced seafood utilising sustainable fishing methods.

We source all our fruit and vegetables through Irish distributors who guarantee to deliver the freshest produce from farms all around Ireland. When in season, Irish produce will always be selected before imported goods. All our beef is Irish produced and our Irish dairy, cheddar cheese and eggs are Origin Green certified, meaning the farms and producers we source from are independently monitored and verified under Ireland’s pioneering food and drink sustainability program. Our breakfast meats are sourced in Kilkenny and Cork.

We are a strong promotor of Irish beverages, not only the larger brands but also smaller producers of craft beers and spirits. In line with the demands of our guests we now offer a wide variety of plant-based food and drink options in all our cafes and restaurants. Our coffees are provided by a Dublin-based roaster using the world’s first purpose-built carbon neutral roastery in Dublin and coffees and teas served on board are fair trade certified.

Diversity and Inclusion

The Group believes that a diverse workforce where all people are respected, valued and treated equally helps create a buoyant culture of openness, acceptance and support. A strong corporate culture founded on diversity, respect and equality ultimately leads to better informed and well-rounded decision making and strengthens our ability to retain and attract talented individuals.

The ICG Equal Opportunities and Dignity at Work Policy reinforces these beliefs and covers;

  • Communication procedures for all discriminatory or harassment complaints by employees or non employees.
  • Investigation procedures for reported cases of discrimination or harassment.
  • Post-investigation procedures including disciplinary action in line with the Group’s disciplinary policy and regular checks to ensure the behaviour under investigation has ceased.
  • A commitment to offering the same development and training opportunities to all employees.
  • Assurances to conduct interviews objectively without discrimination against any candidate.
  • Assurances to conduct performance appraisals and feedback in a sensitive, non-discriminatory manner.

In 2020 there were no (2019: nil) reported instances of discrimination or harassment against Group staff.

Our Gender Profile

At 31 December

2020

At 31 December

2019

Total staff

288

307

Female

109

115

% Female

38%

37%

Management staff

64

64

Female

13

13

% Female

20%

20%

The Group’s gender ratio is characteristic of its industry sector but remains imbalanced in comparison to wider society. The Group has committed to empowering women and improving its gender profile over time by;

  • Ensuring our flexible work plans to facilitate parental duties do not preclude staff from career advancement opportunities.
  • Improving the Group’s female representation at Board level. In January 2021, Lesley Williams was appointed as a non-executive Director. Lesley brings valuable ESG expertise to the Group.
  • Actively seeking out a greater pool of female candidates during recruitment processes across departments.
  • Conveying the importance of diversity and equal opportunity to our key third-party contractors.