Modern Slavery

Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and reflects our actions and commitments in 2024 to understand, assess, and mitigate potential modern slavery risks related to our business. It also sets out the steps we take to ensure that there is no slavery or human trafficking in our own business and supply chains.

Impetus remains committed to the prevention of slavery and human trafficking. We continue to uphold a zero tolerance stance on modern slavery and require all our key suppliers, grantees, and other partners to adhere strictly to the Modern Slavery Act 2015, as well as to our own internal policies, ensuring our shared commitment to combating these abuses.

Organisational Structure

Impetus, a UK-registered charity established in June 2013, aims to transform the lives of disadvantaged young people by ensuring they receive the support they need to succeed in school, work, and life. We identify, fund, and collaborate closely with charities and other organisations, providing both financial support and advisory expertise to help them grow stronger.

While our supply chain remains limited due to the nature of our work, which focuses on providing grants and conducting research, we continue to engage with a restricted range of UK and international suppliers. These include IT services, consultancy, and investment management firms.

We remain vigilant in our due diligence processes to ensure that none of our partners or suppliers are involved in slavery or human trafficking.

Policies

Impetus continues to be an equal-opportunity employer and is committed to ensuring a safe, non-discriminatory, and supportive working environment for all staff. Our key policies aimed at promoting ethical business conduct include:

Recruitment and compensation policy: Ensures fairness, equity, and transparency in our recruitment and compensation practices, with specific measures to prevent modern slavery in our workforce.

Safeguarding policy: Ensures that children and adults at risk are protected from any form of exploitation, including modern slavery, and that there are reporting mechanisms in place for any concerns.

Whistleblowing and complaints policies: Provide secure and confidential channels for employees, suppliers, and partners to raise concerns about unethical practices, including those related to modern slavery.

Due Diligence and Risk Assessments

Our approach to reducing the risk of modern slavery is embedded in our processes, which include:

  • Carrying out proportionate checks on organisations we work with, according to their size and potential risk factors.
  • Regularly monitoring our business and supply chains for any potential modern slavery risks and responding appropriately when risks are identified.
  • Ensuring our procurement processes are robust and compliant with the Modern Slavery Act 2015, with all suppliers and grantees committing to these standards.

Over the past year, we have reviewed our policies, supplier agreements, and procurement procedures to further enhance our due diligence practices. This review included reassessing our key suppliers' and grantees' compliance with modern slavery standards.

Moving forward, we will continue to conduct appropriate and proportionate due diligence checks on all major suppliers and grantees and require them to agree to terms and conditions regarding modern slavery. Impetus do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with the terms and conditions of our agreements by any of our suppliers, we will require that supplier to remedy the non-compliance.

Risk assessment

Our supply chain remains predominantly UK based, consisting largely of academic institutions, UK registered charities and organisations, independent consultants, and IT service providers. As a result, we continue to assess our overall risk of exposure to modern slavery and human trafficking as low.

We remain committed to regularly reviewing this assessment to ensure ongoing vigilance. This statement is available to all staff, who are made aware of it through their onboarding process and during annual reviews.

Next steps

In the coming financial year, Impetus will:

  • Ensure staff remain aware of our commitments to combatting modern slavery through a refreshed code of conduct, our whistleblowing policies, and procurement processes.
  • Continue to perform due diligence on new suppliers and grantees, ensuring their compliance with the Modern Slavery Act 2015.
  • Continue to require all new suppliers and grantees to agree to our updated terms and conditions in relation to the Modern Slavery Act.
  • Conduct an annual review of our supply chain to assess and manage any risks related to slavery and human trafficking.

Approval

This statement has been reviewed and approved by the Impetus Resources and Audit Committee.

Impetus Resources and Audit Committee

13 November 2024