Modern Slavery Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group's slavery and human trafficking statement for the financial year ending December 2017 and has been approved by the Board of Impellam Group plc (“Impellam”)

Our vision is to be the world’s most trusted staffing company, trusted by our people, our customers, our suppliers and investors in equal measure. This vision, together with our shared signature practices, gives clear guidance on the behaviours and actions we expect from all the people and organisations that work with Impellam. We choose to engage and partner with like-minded organisations because they recognise people should be treated with dignity and respect.

Impellam do not believe there is any place in today’s world for slavery or human trafficking. We are committed to continually improving our practices to combat slavery and human trafficking and to encourage the same high standards from our supply chain and other business partners.

Impellam is a global provider of staffing and recruitment services to a wide range of clients covering a broad range of industry sectors. We have over 3,200 employees globally across more than 168 locations across the UK, North America, Asia Pacific and mainland Europe. The Group had a global annual turnover in 2017 of £2.2bn and has its registered office in Luton, Bedfordshire.

Impellam purchases a wide range of products and services from its supply chain, including IT hardware, software and telecommunications; vehicles; office furniture, equipment and supplies; utilities; travel services; and training services.
Impellam’s Supplier Code of Conduct reflects our responsibility to act ethically and with integrity in all our business relationships, including our commitment to combating human trafficking and slavery. We believe our highest areas of potential risk are within our supply chain, and in the provision of agency labour.
In order to mitigate and manage our risk the following activities have been undertaken in 2017:-

• Our Modern Slavery policy was issued to all employees, who acknowledged and confirmed they had read and understood the same.
• We published mandatory Modern Slavery training to all existing employees, and this will be refreshed annually.
• We have advised employees on how they can report any concerns they may have associated with Modern Slavery and reminded all employees of our confidential whistleblowing helpline if they wish to make an anonymous report.
• All new starters were required to complete Modern Slavery training within one month of joining.
• Our suppliers were asked to sign our Supplier Code of Conduct as part of their contractual relationship with Impellam and its businesses.
• Our significant suppliers completed an ethical questionnaire. Due to our large number of suppliers, we take a risk-based approach and undertake audits on those where we consider the exposure to be greatest. If a problem is identified we will work together with the supplier to address any areas of concern, and if necessary will remove them as a supplier.
• All our branches received at least one compliance audit during which pre-employment checks, including eligibility to work, references, qualifications and proof of national insurance numbers, were reviewed.
• We also performed random checks within our UK businesses to identify where agency workers may be sharing bank accounts, addresses or telephone numbers as this can be an indication of illegal or unethical behaviour.
• We have not used or accepted forced, bonded or involuntary prison labour or child labour; nor will we hold onto our workers’ identity papers or knowingly work with businesses that do.
• No breaches of the Modern Slavery Act were reported during 2017.

We review our policies and procedures regularly, not only to ensure they remain relevant, but also to assess our progress.

This statement applies to Impellam Group plc and all its subsidiaries.

Julia Robertson 
Group CEO 
Impellam Group plc 
Date: 8 March 2018