Modern slavery statement

Executive Summary

Modern Slavery (MS) is a grave violation of human rights that affects millions of people around the world. There were 17,004 cases reported to the UK Home Office through the National Referral Mechanism in 2023 (published March 2024). These numbers are continuing to grow with a 0.49% 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 and manifesto, 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 2024 (FY24), 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.

Following a review of our policies and practices, we are pleased to have seen an increase in our score from 43% in FY23 to 70% in FY24 on the UK Government’s Modern Slavery Assessment Tool (MSAT).

Our business 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

Risk assessment

We carried out our annual risk assessment on 95% of our total spend in FY24. This represents any supplier where we have spent £10k or more in that financial year. As with last year, we have identified low, medium or high risk suppliers using an internal auditing scale based on the Walk Free Global Slavery Index and the Government's Guidance for tackling MS in the Supply Chain. 

The results of our audit can be seen below with 98% of suppliers covered by the audit being deemed as low risk, 2% (8 suppliers) as medium risk and none as high risk.

FY24 Supply Chain Audit Results

• 376 suppliers made up 96% of our spend in FY24.
• 8 of these suppliers were given a medium risk level (requires enquiry into MS policies).
• 0 of these suppliers were given a high risk level.

Following the assessment, we initiated assurance testing and conversations with those medium risk suppliers to determine what they are doing to reduce the risk in their supply chain.

We have sought attestation of compliance with the MS legislation and below is a breakdown of these results:

• 3 Suppliers have provided copies of their MS Policy.
• 2 Suppliers are BCorp certified*.
• 1 Supplier has provided confirmation of their adherence to the MS legislation.
• 1 Supplier is still to respond and we continue to request the information.
• 1 Supplier does not have a MS policy, so we are now in discussions to ensure we have assurance and evidence that they comply with at least the minimum requirements of the legislation.

*BCorp certified companies must implement human rights due diligence to ensure all people in their operations are treated with dignity and their rights respected.

Policies

manifesto and TPXImpact operates the following policies for identifying and preventing slavery and human trafficking in our operations:

• Modern Slavery 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.
• 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. 
• 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 checks TPXimpact will undertake on all companies in our supply chain. This requires all clients and suppliers to comply with the MS legislation.

Awareness & Training

manifesto and TPXimpact has raised awareness of modern slavery issues by:

• Including our Modern Slavery Statement in the employee handbook.
• Providing a company-wide awareness campaign to identify ‘red flags’ for potential cases of modern slavery or human trafficking, internal to the business and external, along with practical steps to report suspicions of modern slavery.
• Including modern slavery awareness training in the onboarding process for all new employees. Training accredited by the Institute of Occupational Health and Safety(IOSH), Continuing Professional Development Certifications Service (CPD), and International Institute of Risk and Safety Management (IIRSM) has been delivered to all employees directly involved in supplier onboarding. This training is available to all employees as an optional development programme.

Measuring how we're performing

manifesto and TPXimpact has defined four key areas to combat modern slavery and human trafficking in our organisation and supply chain. In the financial year to 31 March 2023, we developed the following commitments:

Commitment	Action	Timeline	KPI	July 2024 update
All employees have appropriate knowledge of the Modern Slavery Act 2015.	Awareness campaigns targeting all employees. All new starters will undergo comprehensive modern slavery training. All staff directly involved in supplier onboarding will receive comprehensive modern slavery training. Our modern slavery statement and policy will be available to all employees in the employee handbook.	December 2023	Percentage of employees who have completed mandatory training/awareness programmes.	100%. All employees receive training as part of their onboarding process and we have a published MS Policy.
All key suppliers and subcontractors should share our values and commitment to preventing modern slavery.	Reach out to all suppliers in the medium/high risk categories.	December 2023	Percentage of key suppliers and subcontractors in the medium to high risk categories,  who return attestations that they are compliant with the Modern Slavery Act 2015.	Complete We have no high risk subcontractors. For medium risk subcontractors where there is no specific contractual commitment on MS in place, we have received/sought assurance that those suppliers have a dedicated policy/statement.
Ensuring our contracts specifically call out modern slavery and human rights requirements.	Any new contracts being drafted have the commitments included. Review of existing contracts, specifically for medium/high risk suppliers.	December 2023	Percentage of TPXimpact contracts contain modern slavery and human rights requirements.	On track for delivery by September 2024 In April 2024, our Commercial and Procurement policy was launched and the procurement arm of the Commercial & Procurement team was established
We will improve our MSAT score	Use the MSAT tool and its outcomes, and improvement suggestions to guide improvements within our modern slavery processes.	Continuous	MSAT score (current score: 43%)	Our MSAT score is now 70%

Ongoing improvement

In the financial year to 31 March 2025, we make the following commitments: 

• Ensure actions for current KPIs are completed by September 2024. 

• Increase MSAT score to at least 90% by March 2025.

• Review the 5% of our supply chain we have not reviewed. We want to ensure we are not missing risk by concentrating on high spend only.

• Review our company policies against the MSAT requirements, including to explicitly call out debt bondage not being acceptable. This is something as a company we would never accept, but we have not explicitly stated this in our policies.

• Implement due diligence checks on all new suppliers to ensure that our supply chain is compliant with legislation and aligned to our values. Work with the Operations team to get attestations from subcontractors, as these are not noted as high or medium risk, but we recognise that these third parties represent us more directly on customer-facing accounts.

This statement covers 6 April 2022 to 31 March 2023 and has been approved by the Board of TPXimpact Holdings plc on 26 September 2023. The next statement is due to be published by 30 September 2024.

Isabel Kelly
Non-Executive Director, TPXimpact
26 September 2023