The UK Modern Slavery Act (‘MSA’) requires companies operating in the UK to
publish a modern slavery and human trafficking statement. This statement constitutes

ImpactVest LTD's modern slavery and human trafficking statement for the financial year
ending 31 December 2022 and applies to ImpactVest LTD and its subsidiaries and affiliates
(collectively, ‘ImpactVest’).

ImpactVest does not tolerate modern slavery and seeks to prevent any form of slavery or
human trafficking in its business and supply chains. We are committed to acting
responsibly and with integrity across all areas of our business.
ImpactVest LTD, as investment adviser to ImpactVest funds, also fully recognises the
importance of engaging with portfolio companies, in which the ImpactVest funds invest, on this
important subject and continued to do so throughout 2022.

About ImpactVest LTD
ImpactVest is a growing international private equity firm, founded in 2020.
ImpactVest LTD provides investment advice to the managers of the ImpactVest funds and has
its principal place of business in the UK. It is pending authorisation by the UK Financial
Conduct Authority. Other entities within ImpactVest operate out of offices in Paris.

Our Policies and Processes
ImpactVest is a responsible employer and is committed to creating a diverse and inclusive
working environment, where employees are equipped with the skills and resources to
identify modern slavery issues that may arise in its business or supply chains.
ImpactVest has a number of policies in place to mitigate the risk of modern slavery across its
business including an Employee Code of Conduct, an Equality Policy and a Whistleblowing
Policy, all of which apply to staff globally and are periodically communicated within ImpactVest.

The objectives of these policies are supported by the fostering of a speak-up culture within ImpactVest which is championed by senior leadership and outlined in firm-wide communications.

 

Supply Chain Management and Responsible Procurement Risk Assessment

As a financial services business, ImpactVest’s commercial supply chains are direct and involve the provision of business and professional services. We continue to consider the risk of modern slavery and human trafficking arising from these services to be low. We have, nevertheless, undertaken the following: • Assessed the risk arising from the provision of ancillary services to ImpactVest which predominantly relate to the premises in which ImpactVeststaff work; • Reviewed our material suppliers and assessed the risk of slavery or human trafficking in relation to the goods and services supplied. We determined materiality by reference to the nature and the geography of the services supplied and the related costs. This risk assessment identified catering and cleaning as services where a risk of modern slavery would more likely be present (compared to providers of office equipment, computer hard/software or travel booking services which comprise the majority of ongoing services provided to us in addition to business and professional advisory services). Our contracted suppliers of catering and cleaning are publicly listed companies and subject themselves to the MSA. We concluded that the statements published by these suppliers indicate that sufficient controls are in place to mitigate risks associated with modern slavery. New material suppliers are subject to a risk assessment and appropriate background checks.

 

Responsible Investment

Responsible investing by ImpactVest funds has long been an area of focus and is set out in ImpactVests Impact Investment policy, which is published on our website. The portfolio companies, in which the ImpactVest funds invest, do not fall within the remit of our MSA statement. However, ImpactVest LTD, as adviser to the ImpactVest funds, takes a number of steps designed to ensure that the ImpactVest funds invest responsibly and in line with ImpactVests impact investment policy. We have communicated with each company, in which the ImpactVest funds have invested, which are subject to the MSA, to ensure that a statement has been published in respect of the last financial year and is representative of an ongoing process to counter modern slavery and human trafficking. ImpactVest takes a risk-based approach with regards to portfolio companies, in which the ImpactVest funds have invested, which operate and are based outside of the UK and therefore are not subject to the MSA. ImpactVest has communicated to portfolio companies deemed ‘higher risk’, that ImpactVest expects all portfolio companies, irrespective of jurisdiction, to meet the objectives outlined in the MSA. In line with the spirit of the UN Guiding Principles on Business and Human Rights, we are committed to using our influence and ability to effect change within ImpactVest's portfolio if modern slavery issues or risks are identified. Prior to any investment by ImpactVest funds, we carry out due diligence on all aspects of the business including the supply chain. Once the investment has completed, we undertake a more detailed impact assessment – requiring all new portfolio companies to complete a comprehensive impact questionnaire. The ESG assessment includes questions on: whistleblowing policies and processes, labour conditions, migrant workers, supply chain standards and modern slavery.

 

ESG and Impact Procedures

As part of ImpactVest’s overall approach to responsible investing, we seek to ensure that the Boards of the portfolio companies, in which the ImpactVest funds invest, take responsibility for ESG topics, including modern slavery, by:

• Undertaking an ESG assessment and implementing appropriate policies and processes to address any risk;

• Complying with the UK MSA reporting requirements and other similar requirements in other relevant jurisdictions; and

• Reporting on a social KPI, which monitors reported workplace grievances within portfolio companies, and allows identification of any modern slavery-related complaints.

 

Future Developments in ImpactVest's ESG and Impact Procedures

ImpactVest is committed to improving its approach to MSA as its portfolio grows and market standards evolve. ImpactVest has committed to increasing its monitoring and reporting obligations with respect to issues relating to modern slavery . ImpactVest is committed to periodically updating the integration of impact into its investment process, including how modern slavery risks are assessed and managed during due diligence, portfolio management and exit.

 

Awareness / Training

ImpactVest is committed to ensuring suitable awareness of modern slavery and human trafficking considerations amongst its management and staff. Periodically, ImpactVest takes steps to educate and raise awareness of the MSA and its implications with its (i) Executive Committee, (ii) Impact Steering Committee and (iii) all staff. In addition, further updates are provided through internal and portfolio company updates, periodic training, preinvestment due diligence procedures and our portfolio company monitoring process. This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2022.

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Verify the most current ImpactVest Modern Slavery Statement here: https://modern-slavery-statement-registry.service.gov.uk/