Slavery and Human Trafficking Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes many forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

Imosphere takes a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all of our business dealings and relationships, as well as implementing and enforcing effective systems and controls to ensure modern slavery does not exist anywhere in our own business or in any of our supply chains. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Our employees are alert to the risks and are expected to report their concerns, and management are expected to act upon them.

We are also committed to ensuring transparency in our own operations and in our approach to combating modern slavery throughout our supply chains, in accordance with our disclosure obligations under the Modern Slavery Act.

Our policies on slavery and human trafficking

Overall risk for the Imosphere related to Modern Slavery Act compliance is deemed to be low, for the following reasons:

  • The Group is UK based and operates in the field of Care and Support Tools and Health Research and Analytics;

  • Our supply chain is limited to goods and services which are required to support an organisation of this nature (e.g. support services and computer hardware / software);

  • We have a commitment to seeing UK standards in our supply chain and our due diligence and governance programme supports this aim:

  • The Group’s expenditure with third parties is subject to a detailed due diligence assessment that includes modern slavery evaluation and on-going oversight to assure compliance remains throughout the term of the relationship:

  • Whistleblowing policy - The Company encourages all its workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation;

  • Employee code of conduct - The Company’s code makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour.

Due diligence processes

  • We expect all suppliers to comply with our values. To demonstrate this commitment all suppliers are asked to confirm their compliance with the requirements of the Modern Slavery Act 2015 before we commence working with them. This is included in our mandatory due diligence checks which are carried out on all new suppliers to the business and in our supplier health check which is undertaken in relation to our strategic and critical suppliers and key outsourcers. We also include obligations to comply with Modern Slavery legislation within our standard form contracts;

  • We endeavour to establish and build professional relationships with our suppliers and clearly state our expectations of business behaviour;

  • Where non-UK based suppliers are used, our point of contact is preferably with a UK company or branch and we expect these entities to have suitable anti- slavery and human trafficking policies and processes in operation throughout any group structure.

As a customer focused business, we are aware that the risk of modern slavery extends beyond the supply chain and can potentially directly impact our customers’ lives. We have robust due diligence processes in place in relation to onboarding customers and throughout the relationship supported by suspicious activity reporting. We do not consider that we operate in high-risk sectors or locations because we are solely UK based and focus on the financial planning needs of society’s most trusted professions.

Our staff - risk assessment

We regularly evaluate the nature and extent of our exposure to the risk of modern slavery occurring within our staff by:

  • Making sure our hiring managers and those responsible for recruitment know and understand the legal requirements around appropriate right-to work checks.

  • We ensure that all recruitment agencies we engage with are registered and speak to them to make sure they’re undertaking appropriate due diligence.

  • Our Employee Code of Conduct makes clear that we expect our own people, whether permanent or temporary, to be treated with respect and dignity at work and we believe employment should always be chosen.

  • Our recruitment process is managed centrally to ensure there is no forced, bonded, or involuntary labour.

  • Imosphere are committed to paying our employees a fair wage, and regularly review our salaries in line with Market bench marking.

  • Employees are free to leave employment after the giving of reasonable notice.

  • All employees are required to register a mobile number of both them and an emergency contact and regular Employee Notifications are sent to the individual.

  • Whilst individuals are working from home, managers regularly conduct online meetings via Microsoft Teams with individuals.


Our employees receive mandatory induction and computer-based learning to ensure that they are familiar with and benefit from policies which educate on the standards, conduct expected of them and risks to be aware of and the reporting processes available to them including the risk of Modern Slavery occurring within our suppliers, clients and colleagues.