This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and sets out our actions to understand potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business and supply chains
Impetus is committed to preventing slavery and human trafficking violations. We have zero-tolerance towards slavery and require our major suppliers, grantees and other partners to comply with the Modern Slavery Act 2015 and our commitment to preventing slavery and human trafficking.
Impetus was established in June 2013 as a UK registered Charity, to transform the lives of young people from disadvantaged backgrounds by ensuring they get the right support to succeed in school, in work and in life. We find, fund and build the most promising charities working with these young people, providing core funding and working shoulder-to-shoulder with their leaders to help them become stronger organisations.
Due to the nature of our work our supply chain is very limited. We provide grants to our portfolio charity partners, research and influence the public and government on the issues that matter. We also procure goods and services (IT services, consultancy services, investment fund managers, etc) from a restricted range of UK and overseas suppliers.
Impetus undertakes due diligence in respect of its major partners and suppliers, both new and existing. We will not knowingly support or deal with any organization involved in slavery or human trafficking.
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Impetus is an equal opportunity employer and we are committed to ensuring a safe, non-discriminatory and supportive working environment for our staff. We have policies in place to ensure that all our staff are legally entitled to work in the UK, to protect them while they are in our employment and to ensure that we are conducting business in an ethical and transparent manner.
These include the following:
- Recruitment and compensation policy - seeks to prevent modern slavery existing within our own organisation and ensures fairness, equity and transparency in how we select and compensate employees.
- Safeguarding policy - seeks to prevent modern day slavery by ensuring children are not neglected in any way and are protected and mechanisms are in place to report any form of abuse.
- Whistleblowing and complaints policies – seeks to prevent modern slavery by ensuring all individuals including staff, suppliers, partners, grantees or contacts know how to securely express a concern they have regarding the Impetus’s conduct or that of our employees.
Due Diligence and Risk Assessments
Our due diligence and monitoring processes and procedures aim to reduce the risk of slavery and human trafficking through:
- Ensuring appropriate checks are done on organisations we work and do business with that is proportionate to their size and risk environment.
- Regularly monitoring potential risks of slavery and human trafficking in our business and supply chains and appropriately responding to those risks.
- Embedding procurement procedures - seeks to prevent modern slavery and procedures to ensure suppliers and grantees are compliant with the Modern Slavery Act 2015.
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have reviewed our procurement, grantmaking policies and procedures to enhance our due diligence practices, conducted a review of our major existing suppliers and grantees to understand their commitment to preventing slavery and human trafficking, and updated all grant and service agreement terms and conditions to ensure a commitment to complying with the Modern Slavery Act 2015 is included.
Additionally, we will conduct appropriate and proportionate due diligence checks related to slavery and human trafficking on all new major suppliers and grantees and will ensure they agree to terms and conditions that require them to comply with the Modern Slavery Act 2015 and, where applicable, review their own Modern Slaver Statement.
We 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.
The majority of our supply chain is based in the UK and we consider them low-risk organisations that include, for example, academic organisations, charities registered in the UK, independent consultants, and IT service providers. We therefore consider the Impetus’s operating environment to be at low-risk to being involved in slavery and human trafficking.
We will continue to monitor this assessment of our environment and will do so through an annual review of the organisations we work and do business with. This policy is available to all staff, who are made aware of it through their onboarding process and during annual reviews to the Statement.
In the next financial year and on an ongoing basis, we intend to take the following steps to tackle slavery and human trafficking by:
- Ensuring staff are aware of the commitments to combatting slavery and human trafficking through our codes of conduct, whistleblowing, complaints and procurement policies.
- Conducting due diligence on new major suppliers and grantees that include checks on their compliance with Modern Slavery Act 2015 that are proportionate to their size and risk environment.
- Ensuring all new suppliers and grantees agree to our terms and conditions related to Modern Slavery Act 2015.
- Annually reviewing our supply chain to monitor and assess our own risk environment as it relates to slavery and human trafficking.
The statement was approved by the Impetus’s Resources and Audit Committee.
Chief Executive Officer
18 October 2021