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Modern slavery statement


Modern Slavery is a grave violation of human rights that affects millions of people around the world. There were nearly 17,000 cases reported to the UK Home Office through the National Referral Mechanism in 2022 (published March 2023). This is a 33% increase on the previous year, and the highest annual number since the NRM began in 2009 evidencing this a real problem not just globally but also in the UK. We recognise that every company, no matter the industry, is at risk of being involved in modern slavery 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 modern slavery outside of their roles as employees. We are publishing this statement in accordance with the Modern Slavery Act 2015 Section 54 for the financial year 2022/23, but more to demonstrate transparency to our investors, employees, clients and the public. This statement, our second as TPXimpact Holdings PLC, sets out the actions that we are taking to map the risks of modern slavery within our supply chain, and to implement steps to prevent slavery.

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 operates through 7 units*:

  • The Consulting business unit
  • manifesto
  • The Data & Insights business unit
  • RedCortex
  • KITS (Keep IT Simple)
  • Questers
  • TPXimpact Norway

We establish a relationship of trust and integrity with all our suppliers and subcontractors, which is built on mutually beneficial factors. We have not been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, we would act immediately to report the allegation to the authorities.

* Please note that this statement and its data relates to the period ending 31 March 2023 when TPXimpact Holdings PLC (the Group) still owned Questers Resourcing Limited and Questers Bulgaria EOOD (together, Questers). The Group disposed of Questers on 15 September 2023 so at the date of this statement being issued, the Group now operates through 6 units.

Risk assessment

Due to the nature of our operations, our business does not carry a high level of modern slavery risk, however as noted earlier in this statement, we recognise that there is always an element of risk. Therefore, we have conducted our annual risk assessment of the capacity of the organisation to manage and prevent the risks of modern slavery based on the Global Slavery Index and the UK Government’s Modern Slavery Assessment Tool (MSAT) framework. As part of the assessment, we have mapped our supply chain by taking into account the following for the top 96% of our supply chain by spend:

  • The risk profile of individual countries based on the Global Slavery Index.
  • The business services rendered by the suppliers falling under high risk services (e.g. cleaning service suppliers within personnel services) as defined by PPN 02/23 - Tackling Modern Slavery in Government Supply Chains - Guidance.
  • The presence of vulnerable demographic groups.

The results of our audit can be seen below with 96.1% of suppliers involved in the audit being deemed as low risk. 3.3% were considered a medium risk and 0.6% were considered a high risk.

FY23 Supply Chain Modern Slavery Audit Results

  • 512 suppliers made up 96% of our spend in FY23, including Questers, which has subsequently been sold,  and therefore were included within the audit.
  • 17 of these suppliers were given a medium risk level (requires enquiry into modern slavery policies).
  • 3 of these suppliers were given a high risk level** (requires an in-depth audit).

Following the assessment we have started to conduct assurance testing and are having conversations with the suppliers who are noted as high risk to determine what they are doing to reduce the risk in their supply chain.

**We can confirm that following the disposal of Questers, two of the three high risk suppliers in the analysis above were removed from the Group’s supply chain.


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

  • Modern Slavery Policy - As a company we stand against modern slavery 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.

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:





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. 

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.

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.

We will improve our MSAT score

Use the MSAT tool and its outcomes, and improvement suggestions to guide improvements within our modern slavery processes.


MSAT score (current score: 43%)

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