Modern slavery statement

FOREWORD FROM OUR CEO

At TPXimpact, we unequivocally condemn modern slavery as a grave human rights violation. This FY25 statement declares our resolute commitment to its eradication. With over 19,000 UK cases in 2024, vigilance is crucial. We've strengthened policies to prevent risks across our operations and supply chains.

FY25 saw our Modern Slavery Assessment Tool (MSAT) score rise from 70% to 88% due to rigorous measures, including responsible recruitment and a strict 48-hour incident response. We aligned with the Walk Free Foundation, auditing 100% of our supply chain and reducing high-risk suppliers by 80%.

For FY26, we target a 95% MSAT score, with mandatory general and role-specific training. We'll continue meeting BCorp commitments. This Board-approved statement, aligned with UN Guiding Principles and SDGs, signifies our ongoing dedication to a more ethical, just world, free from modern slavery.

Björn Conway

CEO
7 October 2025

MODERN SLAVERY & HUMAN RIGHTS STATEMENT

Executive Summary

Modern Slavery (MS) is a grave violation of human rights that affects millions of people around the world. There were 19,125 cases reported to the UK Home Office through the National Referral Mechanism in 2024 (published March 2025). These numbers are continuing to grow with a 13% increase on the previous year. We recognise that every company, no matter the industry, is at risk of being involved in MS through its own operations and its supply chain.

At TPXimpact, we are fully committed to preventing slavery and human trafficking in all forms throughout our operations and supply chain. We also ask our employees to be aware of identifiers of MS outside of their roles as employees. We are publishing this statement in accordance with Section 54 of the Modern Slavery Act 2015 (MS Act) for the financial year ending 31 March 2025 (FY25), but also to demonstrate transparency to our stakeholders on this important issue. This statement sets out the actions that we have taken, are taking, and plan to implement to manage and reduce the risks of MS within our supply chain.

We have ensured that our policies now encompass specific measures to prevent, detect, and address modern slavery within our operations and supply chains, including responsible recruitment practices. These policies demonstrate how we engage with workers and suppliers, utilise audits or worker voice mechanisms, and respond to any identified incidents within a strict 48-hour timeframe, providing remedy and compensation where necessary. As a result of these measures, we are pleased to report an increase in our score from 70% in FY24 to 88% in FY25 on the UK Government’s Modern Slavery Assessment Tool (MSAT).

Organisational Structure and Supply Chains

TPXimpact was founded as an impact-driven business. We are proud of the work that we have done to ensure that as the business grows, it does so responsibly, with the best interests of our People, Planet, and Community in mind. It is our objective as a business to drive fundamental change in approaches to product and service development, delivery and technology. With experts spanning the public sector, health, not for profit, education and the commercial sector, we're transforming the organisations, technology, and services people rely on. The business now operates through 3 units:

• TPXimpact
• manifesto
• Keep IT Simple

At TPXimpact, we are committed to aligning our approach with the United Nations Guiding Principles on Business and Human Rights. We are also guided by other internationally recognised frameworks, such as:

• The International Labour Organisation’s Declaration of Fundamental Principles and Rights at Work;
• The International Bill of Human Rights, which includes the UN Declaration of Human Rights

In line with the Modern Slavery Act (MSA), we are publishing our annual Modern Slavery & Human Rights Statement. This statement highlights the steps we've taken to identify and address modern slavery and human trafficking within our operations, supply chain, and customer base. It also shares the actions we've implemented to support survivors of modern slavery and outlines the improvements we plan to make in the year ahead.

We are dedicated to supporting the UN Sustainable Development Goals (SDGs), with a particular focus on:

Assessing and Managing Risk

FY25 marked a transformative year for our modern slavery audits. Here is what we have achieved this year:

• Aligned our methodology with the Walk Free Foundation, which significantly enhanced our processes and enabled us to eliminate risks from our supply chain each quarter.
• Audited 100% of our supply chain and ensured collaboration with suppliers to uphold the highest standards.
• Reported an increase in our MSAT score to 88%, by working closely with our high-risk suppliers to ensure we reduced risk where possible.
• Published our modern slavery statement on the government modern slavery register, making it publicly available to view.

Throughout FY25, our high-level assessment consistently identified fewer at risk suppliers by Q4, this is down to remediation actions implemented in previous quarters recategorising them to low risk. This resulted in a 36% reduction in the number of suppliers recorded as potential risks from Q1 to Q4. 

In our detailed assessment, the number of high-risk and medium-risk suppliers identified has steadily decreased over the year. This demonstrates the effectiveness of our efforts with the MS audit in successfully mitigating the risk of modern slavery within our supply chain.

Specifically, high-risk suppliers have decreased by 80% from Q1 to Q4, largely due to our ability to mitigate the initial risk and recategorise them as low risk. Similarly, medium-risk suppliers have decreased by 69% over the same period. We will continue to collaborate with the remaining suppliers and aim to further reduce the identified risks in our supply chain as we progress into FY26.

Due Diligence

In FY25, we identified a high-risk supplier and, as part of our due diligence process, a representative from the supplier completed our self-assessment questionnaire. Unfortunately, they were unable to provide sufficient evidence to demonstrate compliance with the Modern Slavery Act 2015. Due to the nature of the supplier, we need to carefully ensure our employee welfare is taken into account whilst also managing the risk. As a result, we are continuing to work closely with them to ensure they meet the necessary standards and fully comply with the Act.

Policies

TPXimpact operates the following policies for identifying and preventing slavery and human

trafficking in our operations. These are shared to all employees via the internal website:

● Modern Slavery and Human Rights Policy - As a company we stand against MS and give our employees the tools and training to spot and report potential suspicions of slavery/human trafficking.

● Salient Human Rights Issues - As part of our commitment to B Corp standards, this document identifies and addresses the most significant human rights risks and impacts associated with an organisation's operations, products, services, or supply chains.

● Whistleblowing Policy - We encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of whistle-blowers.

● Equality, Diversity & Dignity Policy - Any behaviour which is inconsistent with treating others with dignity and respect is prohibited. In particular, this policy prohibits discrimination, harassment, third party harassment and bullying.

● Flexible Working Policy - We allow our own employees flexibility in how, where, and when they work.

● Talent & Recruitment Policy - We treat all applicants equally and undertake rigorous background checks on applicants before an offer is submitted. We confirm that we have never engaged in any form of debt bondage and this policy now specifically calls this out, ensuring the fair and respectful treatment of all individuals.

● ESG Policy - We prohibit any type of work which, by its nature or the conditions in which it is carried out, is likely to compromise health, safety or morality and any behaviour contrary to dignity at work.

● Commercial and Procurement Policy - This details what background checksTPXimpact will undertake on all companies in our supply chain. This requires all clients and suppliers to comply with the MS legislation.

Awareness & Training

TPXimpact has raised awareness of MS issues by:

● Including our Modern Slavery and Human Rights Statement in the employee handbook.

● Providing a company-wide awareness campaign to identify ‘red flags’ for potential cases of modern slavery or human trafficking, both internally and externally to the business, along with practical steps to report suspicions.

● Carrying out external training sessions on modern slavery and joined multiple external discussions to raise awareness around the issue.

● Including modern slavery awareness training in the onboarding process for all new employees.

● Delivering enhanced modern slavery training to all employees directly involved in supplier onboarding. This training is available to all employees as an optional development programme.

● Including Modern Slavery basic training as part of the annual compliance training for all employees.

● Two members of our Commercial & Procurement team completing Chartered Institute for Procurement & Supply (CIPS) ethical procurement and supply chain training.

Monitoring and Evaluation

TPXimpact has defined four key areas to combat MS and human trafficking in our organisation and supply chain. In the financial year to 31 March 2024, we developed the following commitments and set out status updates below on those commitments as at June 2025:

Ongoing improvement

In the financial year to 31 March 2026, we make the following commitments:

This statement covers 1 April 2024 to 31 March 2025 and has been approved by the Board of TPXimpact Holdings plc. The next statement is due to be published by 30 September 2026.

Björn Conway
Chief Executive Officer
TPXimpact