IfM Engage – Modern Slavery & Human Trafficking Statement

IfM Engage Ltd. (the “Company”) has published this statement under section 54(1) of the Modern Slavery Act 2015 (“Act”). As the Company does not meet the turnover threshold specified by the Secretary of State, it is not legally required to prepare a slavery and human trafficking statement under section 54(1) of the Act. However, the Company is committed to continuously improving its practices to combat slavery and human trafficking. Through this statement, the Company wishes to demonstrate the steps it has taken, and continues to take, to understand and minimise the potential risk of modern slavery in its supply chains.

As a subsidiary of the University of Cambridge, the Company adopts and adheres to the University’s overarching Anti-slavery and Anti-trafficking Policy. IfM Engage’s Modern Slavery & Human Trafficking Statement should be read in conjunction with the University’s policy, which provides a more detailed overview of the policies, procedures, and actions taken to prevent modern slavery across the University and its subsidiary undertakings.

About IfM Engage Ltd.

The Company is a wholly owned subsidiary of the University of Cambridge, embedded within the Institute for Manufacturing (IfM), Department of Engineering. Our services are delivered by industrial experts who tailor and combine insights and tools to bring meaningful change across businesses, governments, and academic institutions around the world. We work with and are trusted by some of the world’s leading multinationals, SMEs, and early-stage ventures. We also work with national and regional governments to help them create the appropriate conditions for science and technology to be successfully commercialised. Find out about us here.

Our Commitment to the Principles of the Modern Slavery Act 2015

The Company is committed to the principles of the Act and the abolition of modern slavery and human trafficking. We endeavour to uphold the highest ethical standards in all our business activities and relationships. We have a zero-tolerance approach to modern slavery and human trafficking and are committed to acting with integrity and transparency in all our business dealings. We are dedicated to making sure that our supply chains, in the UK or abroad, do not knowingly support or enable slavery, servitude, and forced or compulsory labour.

As an equal opportunities employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves. Our Public Interest Disclosure Policy, which is made available to the staff through the Staff Handbook, has a mechanism that allows staff to ‘whistleblow’ in case of any serious and confidential allegations against the company.

Our Supply Chain

Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chains. Our supply chains are limited, and we procure goods and services from a restricted range of UK and overseas suppliers. Our supply chains include our Third-Party Associates (“TPAs”), who are independent experts who are highly experienced in delivering projects using a range of IfM tools and approaches, and are affiliated with the Company.

Our Policies in Relation to the Modern Slavery Act 2015

The following policies are available to all staff through the Staff Handbook:

• Business Ethics and Integrity Policy
• Public Interest Disclosure Policy
• Harassment and Bullying Policy
• Equal Opportunities Policy
• Conflict of Interest Policy
• Immigration Policy

Embedding the Principles

We will continue to embed the principles through:

• providing mandatory training to all staff and TPAs on the Modern Slavery Act 2015, and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking;
• ensuring staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK;
• ensuring that consideration of the modern slavery risks and prevention is added to our policy review process as an employer and procurer of goods and services;
• making sure our procurement strategies and contract terms and conditions include references to modern slavery and human trafficking;
• continuing to take action to embed a zero-tolerance policy towards modern slavery;
• ensuring that staff involved in recruitment or deployment receive training on ethical employment practices.

Due Diligence and Risk Management

In line with the University of Cambridge’s approach, we have in place due diligence processes to identify and manage risks related to modern slavery in our supply chains. We require our TPAs to adhere to their terms of reference, which obligate them to ensure that their operations and supply chains are trafficking and slavery free, so as to address multi-level supply chains. Our risk management processes include due diligence during onboarding processes, robust contractual obligations, and continuous monitoring.

Reporting Concerns

We encourage anyone with concerns about modern slavery in any part of our business or supply chains to report them. We are committed to ensuring that any concerns can be raised in confidence and without fear of retaliation.

In case of any concerns or complaints relating to Modern Slavery, please reach out to Kate Wilsher, COO and Board Member, at kew54@cam.ac.uk.

Incident Response Process

The following process outlines the mandatory steps to be taken upon receiving a report or identifying a potential case of modern slavery or human trafficking within the Company’s operations or supply chains. The primary objectives are to ensure a victim-centric approach by ensuring safety and to respond in a timely, effective, and legally compliant manner. The Company shall handle all reports and investigations with strict confidentiality and comply with UK law, including the Modern Slavery Act 2015 and data protection legislation, while doing so.

In handling the response process, the COO shall be the first point of contact for all reports; responsible for initial assessment, logging, and escalation. In doing so, the COO shall be supported by the Modern Slavery Incident Response Team (“MSIRT”), comprising Kate Wilsher (COO), Clare Lumsden (CFO), Anna Rowntree (Project and Operations Manager), and Mitali Gupta (Contracts & Compliance Officer).

This statement has been approved by Clare Lumsden, CFO, for the financial year ending 31 July 2026. This statement will be reviewed and updated every year.