Modern Slavery

Introduction

This Modern Slavery and Human Trafficking Statement is made pursuant to Section 54(1), Part 6 of the Modern Slavery Act 2015 and outlines the steps taken by Impetus in the period ending October 31, 2025, to prevent modern slavery and human trafficking in our operations and supply chains.

Impetus remains firmly committed to the prevention of slavery and human trafficking. We uphold a zero-tolerance approach and require all suppliers, grantees, and partners to comply with the Modern Slavery Act 2015 and our internal policies. In 2025, we also adopted an Ethics and Due Diligence Policy for donors, which strengthens our ability to assess ethical risks across all funding relationships.

Organisational Structure

Impetus is a UK-registered charity, established in June 2013, dedicated to transforming the lives of disadvantaged young people. We provide financial support and strategic guidance to charities and organisations working in education, employment, and youth development.

Our supply chain remains limited due to the nature of our work, which focuses on grant-making and research. We engage with a select group of UK and international suppliers, including IT service providers, consultants, and investment managers. We continue to monitor these relationships closely to ensure compliance with anti-slavery standards.

Policies

Impetus maintains a suite of policies that promote ethical conduct and safeguard against exploitation:

  • Recruitment and Compensation Policy: Ensures fairness and transparency in hiring and pay practices, with safeguards against forced labour.
  • Safeguarding Policy: Protects children and vulnerable adults from exploitation, including modern slavery, and provides clear reporting mechanisms.
  • Whistleblowing and Complaints Policies: Offer confidential channels for reporting unethical behaviour, including concerns related to slavery or trafficking.
  • Ethics and Due Diligence Policy for Donors: Introduced in 2025, this policy ensures that donor relationships are ethically sound, legally compliant, and aligned with Impetus’ values.

Due Diligence and Risk Assessments

Our approach to mitigating modern slavery risks includes:

  • Conducting proportionate checks on suppliers and grantees based on size, location, and risk profile.
  • Monitoring our supply chain for potential risks and responding promptly to any concerns.
  • Ensuring procurement processes are compliant with the Modern Slavery Act 2015 and that all partners commit to these standards.

In 2025, we enhanced our due diligence practices by integrating donor assessments into our ethical review process. While we have not yet adopted Level 2 reporting standards as outlined in recent UK government guidance, we intend to begin exploring these areas in the coming year to strengthen transparency and accountability.

Risk assessment

Our supply chain remains UK-based, comprising academic institutions, registered charities, independent consultants, and IT providers. We continue to assess our exposure to modern slavery as low but remain vigilant and committed to regular reviews.

This statement is shared with all staff during onboarding and annual policy reviews to ensure awareness and accountability.

Next steps

In the coming year, Impetus will:

  • Continue to raise staff awareness through refreshed policies and training.
  • Apply our Ethics and Due Diligence Policy to applicable donor relationships.
  • Aim to require all new suppliers and grantees to agree to updated terms and conditions regarding modern slavery.
  • Conduct an annual review of our supply chain and donor base to assess and manage risks.
  • Begin exploring Level 2 reporting areas, including the potential for case studies, remediation actions, and enhanced disclosures, in line with evolving best practice.

Approval

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

Impetus Resources and Audit Committee

12 November 2025