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Modern Slavery Statement

Mind Gym Plc Modern Slavery Act Statement

We conduct a modern slavery risk assessment for each new supplier before they are approved;Mind Gym plc (‘Mind Gym’) is committed to ensuring that slavery and human trafficking is not taking place in our business or in our supply chain. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Mind Gym’s slavery and human trafficking statement for the financial year ending 31st March 2024. This statement outlines the steps that Mind Gym has taken and is taking to ensure slavery or human trafficking is not taking place in any part of our business or in our supply chains.

Organisation's structure

We are a global provider of behavioural science in the Learning & Development sector. Mind Gym plc is the parent company of wholly owned subsidiary companies in the USA and Singapore (the “Group”). The Group has over 250 employees and operates in up to 60 countries.

Our business

Mind Gym’s business model provides for separate teams for sales, creative, session delivery and programme management, located primarily in the UK and US. Our creative team consists of freelance creatives as well as employees. Sessions are delivered by a diverse pool of freelance qualified coaches, locally based in over 30 countries.

Our policies and training

Mind Gym has a global policy on modern slavery which states we oppose all forms of slavery or human trafficking, and we are committed to taking steps to ensure these do not occur in our business. Our modern slavery policy is one of several policies that reflect our commitment to acting with integrity in all our business relationships.

We are committed to ensure our personnel have a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business. Our managers and others responsible for procurement are trained on the modern slavery policy and all staff are advised of the range of policies we have implemented.

Other policies include an equal opportunities policy, an anti-harassment and bullying policy, an anti-bribery and corruption policy and a whistleblowing policy or their local equivalents. Our whistle-blowing policy (or local equivalent) provides a detailed internal mechanism for reporting concerns in the strictest confidence, without fear of disciplinary action.

Our supply chains and due diligence processes

In addition to our freelance coaches and creatives, our supply chains include a range of indirect support services (for example IT, printing services, professional advisers) providing goods and services to enable the services we in turn provide to our clients. Suppliers are managed by the relevant business function. Some are engaged on a global scale, whereas others are managed at a local level.

We recognise that modern slavery and human trafficking may occur in countries from which we procure goods and services. We are committed to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

We assess potential risk in order to mitigate and monitor those risks in our supply chain.

Procurement Processes

Our main aim is to ensure we engage with suppliers that have similar values and ethics and to ensure we implement measures to gauge how effective we have been to ensure that slavery and human trafficking has not taken place in our business and supply chains.

Key initiatives
  • We have formed a dedicated supplier management team, which consists of representatives of the legal, finance, operations, information technology and people teams;
  • We require all new suppliers to review and complete a mandatory supplier questionnaire which references issues such as modern slavery;
  • We have implemented processes within the relevant business teams to ensure new suppliers complete the questionnaire;
  • We conduct a modern slavery risk assessment for each new supplier before they are approved;
  • We have implemented processes to ensure our supplier contracts are reviewed and in high-risk areas have appropriate provisions;
  • We have a whistleblowing policy (or its local equivalent) to protect whistle blowers;
  • We have prepared a supplier code of conduct to which suppliers must sign up and which addresses issues such as Modern Slavery, corruption and diversity.

Ongoing commitment

We are identifying Modern Slavery KPIs and are committed to continuous monitoring, to ensure that our practices remain consistent with our policies. The Group’s policies and procedures are subject to an annual review and where required they will be updated.

The Group’s employees and contractors will receive appropriate training to ensure such updated policies and procedures are explained and understood by them.

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 31st March 2024.

Christoffer Ellehuus

Chief Executive Officer

Mind Gym plc

This statement has been approved by the Board of Directors on 3rd March 2025.