(Section 54, Modern Slavery Act 2015)
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps taken by Climate Impact Partners and its subsidiaries (together, the “Group”) during the financial year ending 31 March 2026 to prevent modern slavery and human trafficking in our business and supply chains.
Modern slavery is a violation of fundamental human rights and includes slavery, servitude, forced or compulsory labour, child labour and human trafficking. We maintain a zero-tolerance approach to modern slavery and are committed to acting ethically, responsibly and with integrity in all our business relationships.
This statement builds on our prior disclosures and reflects enhancements made during 2025 to our third-party standards, due diligence processes, monitoring and governance arrangements.
Climate Impact Partners is a service provider, project developer and retailer in the climate action sector. We work with businesses, project partners and suppliers globally to deliver high quality climate solutions.
The Group’s operations span the United Kingdom, the United States, Kenya, India and multiple jurisdictions across Latin America, Africa and Asia. Our supply chain primarily comprises professional services providers, project developers, certification bodies, auditors, consultants, technology providers and other third-party suppliers. We do not manufacture physical goods.
Our project development and delivery activities represent the areas of highest inherent modern slavery risk within our supply chain, and we have prioritised our due diligence and monitoring efforts in these geographies accordingly.
We have established and maintain a framework of policies to prevent modern slavery and human trafficking, including:
Our Supplier Code of Conduct sets out mandatory minimum standards for all suppliers, contractors, subcontractors and project partners. It covers human rights and labour standards, including prohibitions on forced labour, child labour and human trafficking, and requires compliance with applicable laws and internationally recognised standards.
Suppliers are expected to cascade these standards throughout their own supply chains, maintain appropriate controls (including whistleblowing mechanisms), and cooperate with audits, monitoring and remediation where required.
All relevant policies are reviewed periodically and communicated internally and externally as part of onboarding and contracting processes. Our policies consider relevant international standards, including ILO Conventions and the UN Guiding Principles of Business and Human Rights (UNGPs).
In line with international guidance, we seek to identify and assess modern slavery and forced labour risks that may arise in our own operations and in our supply chains.
Our approach prioritises risks based on factors such as:
We focus primarily on Tier 1 and Tier 2 suppliers and project partners, recognising current limitations in visibility beyond these levels. The absence of identified risks does not necessarily indicate an absence of risk.
Where risks are identified, we seek to prevent and mitigate potential adverse impacts through proportionate measures, which may include:
These measures are applied on a case-by-case basis, taking into account leverage, severity and practical feasibility.
We operate a risk based due diligence framework designed to identify, assess and mitigate modern slavery risks in our operations and supply chains. During 2025, we strengthened this framework by embedding it more systematically across third party onboarding and lifecycle management.
Our due diligence measures include:
We recognise that an absence of identified risks does not necessarily indicate an absence of risk and remain committed to continuous improvement in our approach. We also apply responsible recruitment principles in our own operations.
We promote awareness of modern slavery risks across the organisation through internal policies, guidance and targeted training for relevant teams, including those involved in procurement, project development and partner engagement. We review training content at least annually to ensure that it remains current and relevant to our supply chain, and modern slavery risk.
Suppliers are encouraged to provide appropriate training to their own personnel and to maintain mechanisms for reporting concerns without fear of retaliation, in line with our Supplier Code of Conduct.
We also recognise the importance of access to grievance and reporting mechanisms. Internally, employees may raise concerns through established reporting channels. Externally, suppliers and partners are expected to maintain appropriate mechanisms and to notify us of material issues.
We assess grievance and whistleblowing cases raised and seek to respond in a manner that is reasonable and proportionate, having regard to our role, involvement and degree of influence.
We monitor the effectiveness of our approach through periodic review of due diligence outcomes, supplier engagement and internal controls.
During 2025, we progressed work to develop performance indicators to assess the effectiveness of our approach, including:
Where noncompliance is identified, we seek to work collaboratively with suppliers to address issues, while reserving the right to suspend or terminate relationships where remediation is not possible or appropriate.
In the coming year, we will continue to:
Responsibility for oversight of modern slavery and human rights risks sits with senior management, with escalation to the Board where appropriate.
Relevant functions (including legal, procurement, project development and compliance) are responsible for implementing policies and controls within their respective areas.
This governance approach reflects a risk based and proportionate model, consistent with international expectations while recognising the nature, size and complexity of the Group’s operations.
This statement is intended to satisfy the reporting requirements of the UK Modern Slavery Act 2015 and to align, where applicable and proportionate, with comparable transparency expectations under:
Nothing in this statement is intended to create additional contractual, legal or fiduciary obligations beyond those required under applicable law.
We will continue to monitor developments in international modern slavery and human rights due diligence legislation and will update our disclosures as required by law.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31 March 2026.
Sheri Hickok
CEO of Climate Impact Partners
April 2026