This statement was made on or about 1 April 2026 pursuant to section 54(1) of the Modern Slavery Act 2015 (UK), the Modern Slavery Act 2018 (Cth) and the Modern Slavery Act 2018 (NSW) and constitutes the slavery and human trafficking statement of Impellam Group Limited (“Impellam”) for the financial year ending 31 December 2025. It has been approved by the directors of Impellam Group Limited.
Impellam does not believe there is any place in today’s world for slavery or human trafficking. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our business or supply chains.
Our Business
Impellam is an international workforce and STEM talent solutions group operating across North America, the UK & Europe and APAC, providing managed services, services procurement, professional services and specialist recruitment solutions. Our supply chains include recruitment agencies, umbrella companies, consultancies, statement of work providers, payroll providers and other workforce solutions suppliers.
Policies and Training
During 2025, Impellam continued to operate a suite of policies designed to prevent modern slavery and related exploitation, including:
• Code of Business Conduct
• Supplier Code of Conduct
• Whistleblowing Policy
• Bribery and Corruption Policy
All employees continue to receive mandatory onboarding and annual refresher training through our learning platform, covering modern slavery awareness, whistleblowing, fraud, bribery and corruption, and ethical business conduct. These policies remained under active review during 2025 following compliance, audit and operational feedback across the Group.
Supply Chain Risk and Due Diligence
Impellam recognises that its highest modern slavery risks sit within its extended workforce supply chain rather than its direct workforce, particularly where labour is supplied through third parties, including recruitment agencies, umbrella companies, payroll providers, statement of work suppliers and subcontracted service providers operating across multiple jurisdictions.
Key risk indicators include:
• complexity of labour supply chains;
• use of contingent and agency labour;
• reliance on third-party payroll and employment models; and
• regulatory divergence across jurisdictions.
These risks are assessed on an ongoing basis with reference to industry guidance, internal audit findings, supplier due diligence outcomes and incidents escalated through compliance and legal functions.
Supplier Due Diligence and Questionnaires
During 2025:
• The Modern Slavery Ethical Trade and Human Rights Questionnaire continued to be issued to suppliers, with follow-up engagement and corrective action communications developed where gaps were identified.
• Priority corrective areas communicated to suppliers included modern slavery policies, supplier codes of conduct, worker training, grievance mechanisms and whistleblowing arrangements.
• Training and supplier engagement activity was expanded to support improved understanding of questionnaire expectations and compliance standards across the supply chain.
Supplier Audits and Monitoring
Impellam continued to conduct compliance audits across managed service accounts and supplier populations during 2025, including audits focused on worker documentation, right to work checks, payroll practices and supplier controls. Audit outcomes and remediation activity were monitored through internal quality and compliance processes.
Umbrella Companies and Payroll Controls
In 2025, Impellam significantly strengthened its approach to umbrella company risk management:
• All umbrella companies used by Impellam are required to hold FCSA accreditation, and active monitoring of accreditation status was undertaken during the year.
• Where umbrella providers lost accreditation or raised compliance concerns, workers were transitioned to alternative approved providers in line with Group escalation processes.
• Payslip audits and payroll anomaly checks continued, including electronic monitoring for duplicate bank details, addresses and excessive working hours, with escalation to compliance and legal teams where required.
Impellam also actively prepared for forthcoming UK regulatory changes affecting umbrella companies, including enhanced due diligence, audit and supply-chain accountability requirements.
Raising Concerns and Incident Management
Impellam encourages the reporting of any concerns relating to modern slavery, fraud or exploitation through internal reporting channels and its whistleblowing framework.
During 2025:
• Potential modern slavery concerns raised within the supply chain were investigated in collaboration with compliance, legal and operational teams.
• Where appropriate, suppliers were suspended during investigations, customers were informed, and matters were assessed to determine whether issues related to modern slavery or other compliance breaches such as right-to-work fraud.
In actual or suspected cases of modern slavery, fraud or exploitation, Impellam determines each appropriate remediation action on a case-by-case basis. In addition to the foregoing actions taken in 2025, other corrective measures Impellam considers (and which remain available to Impellam at all times) include, without limitation and as applicable, further stakeholder training and support, fee repayment (including the enforcement of fee repayment within the supply chain) to affected workers, formal reporting and confirmation of remediation implementation measures, termination of contractual relationships and/or referral of violations to relevant authorities.
Assessing Effectiveness
Impellam recognises that modern slavery risk management is an evolving process and will continue to refine its approach in line with regulatory guidance and industry practice.
Impellam continuously assesses the effectiveness of its actions to address modern slavery risks through a combination of qualitative and quantitative measures, including:
• tracking completion and quality of our actions and outcomes, including supplier due diligence and questionnaires;
• review of audit findings, remediation actions and repeat issues;
• monitoring incidents, escalations and outcomes over time;
• internal governance reviews involving compliance, legal and operational teams; and
• engagement with suppliers, customers and industry bodies to test the practical operation of controls.
These assessments are used to inform enhancements to policies, training, supplier engagement and audit focus areas in subsequent reporting periods and to ensure alignment of expectations and compliance understanding with all relevant stakeholders.
Impact and ESG Integration
Modern slavery risk management forms part of Impellam’s wider ESG and sustainability framework. During 2025, Impellam continued to report on social impact, ethical supply chain practices and sustainability initiatives through its ESG and Impact reporting.
Approval
In preparing this statement, Impellam consulted with relevant entities it owns or controls, including group legal, compliance and operational teams across jurisdictions, to identify risks, review actions taken and ensure consistency of approach across the Group. This statement was approved by the Board of Impellam Group Limited, the principal governing body of the reporting entity, and is signed by a responsible member of the principal governing body.
This statement applies to Impellam Group Limited and its subsidiaries globally, including those incorporated in the UK and Australia in Australia, those subsidiaries include Comensura Pty Ltd (ABN 30 120 725 902) and Impellam APAC Pty Ltd (ABN 52 641 149 840).
The Group had a global annual turnover in 2025 of £1.9.bn and has its registered office in Luton, Bedfordshire.
No modern slavery incidents or suspected incidents were reported to the regional legal teams during 2025.
Signed for an on behalf of Impellam Group Limited and all its subsidiaries globally.
Signed for and on behalf of Impellam Group Limited
Joanne Weston Group Finance Director