Modern Slavery & Human Trafficking Policy and Statement for Financial Year ending 31st December 2024



This document contains In Diverse Company’s policy on modern slavery and human trafficking and its statement under section 54 of the Modern Slavery Act 2015.

Forced or compulsory labour, human trafficking and other kinds of slavery represent some of the gravest forms of human rights abuse in any society. We all have a responsibility to be alert to the risks in both the In Diverse Company business and our supply chain.

In Diverse Company is committed to conducting all aspects of its business in an ethical and transparent manner. We acknowledge and are committed to our duties and responsibilities under the Act.

In Diverse Company values require that all workers are treated with dignity and respect. We are fundamentally opposed to slavery, human trafficking, forced labour, debt bondage, the sale or exploitation of children and all exploitative practices in the workplace.

In Diverse Company requires that all contractors and suppliers do not engage in any such practices, and do not knowingly themselves contract with third parties which do.

In Diverse Company values require that it terminates business relations and reports to the respective authorities any contractor or supplier found to be in breach of anti-slavery and human trafficking obligations.


Modern slavery statement

This statement sets out the approach that  In Diverse Company ltd have either already taken during the financial year to 31 December 2020, or intend to take during the current financial year, to prevent modern slavery and human trafficking in its business and supply chains.

We are seeking to apply the policies and procedures detailed in this statement across relevant parts of the business but acknowledge it may take time to achieve consistent standards, especially overseas and within our supply chains.


Our business

In Diverse Company is a dynamic international People and Technology company with expertise in business and technology strategy and delivery, organisational transformation, diversity and inclusion and organisation development. Our people specialise in delivering innovative and commercial, solutions to business and technology challenges. In Diverse Company partners with businesses who want to accelerate their commercial success. Using a unique methodology and incorporating data science and human expertise, data is analysed from the past, to make recommendations for the future, ensuring there is focus on D&I in its broadest sense. In Diverse Company helps clients make decisions that will impact significantly, and measurably, on their business performance. Services include Include LXP, D&I Maturity Model, D&I ROI, D&I solutions including coaching, leadership development, and other workshops. Support can also be provided in strategy development and consultancy.


In Diverse Company employee overview

We have teams based in the UK, Ukraine, India and the US with a diverse client base across the public and private sectors. We are committed to providing an inspiring and rewarding place to work and this is at the heart of our business strategy. We comply with all relevant local minimum age and wage laws and do not employ child labour.

All our employees are paid by bank transfer; we do not allow payment to be made into third party bank accounts, thus minimising the risk of forced or compulsory labour; and vetted for the right to work in the country where they are employed. Where employees require a work permit/VISA we ensure they have the necessary documentation in place.

As a responsible employer, we take the welfare of our employees seriously. Our whistleblowing policy encourages employees to report wrongdoing (including exploitation) in any form.


Supply chain overview

In Diverse Company may outsource operating areas such as IT development, Finance, Legal, Creative and some international business development as well as other ad-hoc non-core business and our business model means that on large programmes we may work with several contractors, sub-contractors and other suppliers to fulfil our commercial and contractual obligations to our customers.

In common with many other businesses operating in our industry, depending on the size and scale of the projects we are involved in our supply chain can potentially be complex; there are sometimes multiple tiers of suppliers between In Diverse Company (as the main contractor) and the source of the materials and labour we use.

We are aware that the biggest slavery and human trafficking risks for In Diverse Company lie in our supply chains, particularly the supply chains of our sub-contractors in higher risk jurisdictions and we monitor and review our processes with all our suppliers to ensure we mitigate risk wherever possible.



We provide training to our staff in order to ensure a sound comprehension of the risks within our business, our clients and supply chains of modern slavery and human trafficking.


Ongoing review

We will continue to review and evolve our modern slavery and human trafficking policies and procedures over time.


Failure to comply

A failure to comply with the Act, and/or this policy statement will be deemed to be a material breach of the terms of our standard commercial agreements and contracts of employment.

This statement is made pursuant to Section 54(1) of the Act and constitutes In Diverse Company Ltd’s Modern slavery and human trafficking statement.


For and on behalf of In Diverse Company 

What we’re talking about

Johanna launched In Diverse Company in 2019 out of a strong belief that there was a better way to create and measure inclusive cultures.

We live by our values, and our approach to our own recruitment policy, team and purpose reflects this. We are a tech company driven by a senior team that are experts in people, with one of the only female CEOs of a HR tech platform across the world.

Our Learning Platform, Include™ is the only LXP that combines Learning and Engagement. Include aims to create more inclusive working cultures and is underpinned by social and behavioural psychology principles.