Modern Slavery Statement

Impact Capital Group is committed to running our business responsibly and to the highest ethical standards.

We have zero-tolerance to slavery and human trafficking. Impact Capital Group policy prohibits all forms of forced or compulsory labour and requires vendors/suppliers to maintain and promote fundamental human rights, where employment decisions are based on free choice without any coerced or prison labour, no use of physical punishment or threats of violence or other forms of physical, sexual, psychological, financial or verbal abuse as a method of discipline or control.

In addition, our policy mandates the adherence to minimum employment age limits defined by law or regulation, and the prohibition of children performing work.

For Impact Capital Group the perceived risk is principally through our supply chain, either in procuring services to run our business or to deliver services to clients. Those suppliers operate in numerous sectors such as building and construction, facilities management, finance, technology, travel, and utilities. We also work with other professionals, advisers and consultants, and contractors.

In those parts of our business where we assess or believe the potential risks of modern slavery to be higher, we use several measures to reduce the risk. These include:

The use of contractual clauses in supplier contracts requiring adherence to our policy standards, including right of termination if a supplier does not adhere to policy standards or fails to notify Impact Capital Group regarding any breaches

Conducting due diligence on suppliers for red flags regarding slavery and human trafficking

The express requirement on suppliers to notify us of any breaches

To date, we have not been aware of any instances of slavery and human trafficking in our business or supply chain.

We maintain an external hotline where employees, clients and third parties can report suspected slavery or human trafficking in our business or supply chain.

In the event a report is received, we will act immediately and resolutely. This can include working with suppliers to remedy any breaches, but also instantly terminating contracts and reporting to law enforcement and other bodies as appropriate.

We routinely remind our staff (and where appropriate, suppliers) of their obligations under our Code of Conduct and Legal & Compliance policies including adherence to section 54 of the Modern Slavery Act.

The overall sponsor for this programme is Teodora Ilieva. The leadership at Impact Capital Group are tasked to monitor compliance with our policies in this area.

This statement (made on behalf of all of Impact Capital Group’s entities/subsidiaries with business interests in the United Kingdom) on slavery and human trafficking is made pursuant to section 54 of the Modern Slavery Act 2015.