دم½¶تسئµ

دم½¶تسئµ. Modern Slavery Statement

Introduction

دم½¶تسئµ. (“دم½¶تسئµâ€‌) recognizes that modern slavery is a worldwide problem and appreciates the efforts from both the public and private sector to eradicate it. دم½¶تسئµ strives to act ethically and with integrity in all its business relationships and maintains processes and controls to avoid involvement in human rights violations related to its own operations, supply chain, and services.

دم½¶تسئµâ€™s statement was produced in accordance with the obligations under theج‎UK Modern Slavery Act of 2015ج‎and theج‎Australian Modern Slavery Action 2018. Although Canada’s bill S-211 has not been enacted at this time, the obligations in the proposed Canadian legislation were considered.

About دم½¶تسئµ

دم½¶تسئµ was founded in Kitchener, Ontario, Canada in 2015. The organization simplifies the study abroad search, application, and acceptance process by connecting international students, recruitment partners (“RPsâ€‌), and academic institutions on one platform.ج‎
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دم½¶تسئµ believes that education is a right for human beings, not a privilege and empowers people around the world to access the best education.

People and Supply Chains at دم½¶تسئµ

دم½¶تسئµ operates in the education and technology sectors and procures goods and services from a range of suppliers. Itج‎does notج‎have complex supply chainsج‎or vendor relationships with large businesses in sectors where modern slavery has been found to be an issue (i.e., mining, fishing, construction, etc).

Its people areج‎notج‎engagedج‎in low-skilled, low-paying or hazardous jobs considered high-risk for modern slavery. Instead its people are engaged in:ج‎

Identifying and assessing modern slavery risks

دم½¶تسئµ was unable to identify any occurrence whereج‎its activitiesج‎caused an adverse impact to its people. This conclusion is based on the sector in which it operates, the online services it provides and the functions that its people perform directly for دم½¶تسئµ.

دم½¶تسئµ recognizesج‎that any organization could be unknowingly indirectly linkedج‎to the risk of modern slavery through its suppliers of products and services but believes this is extremely unlikely given its sector, services and functions. Most of its largest suppliers show accountability by having prepared modern slavery statements despite the absence of Canadian and American legislation driving compliance.

دم½¶تسئµ is confident its online platform for connecting international applicants to educational institutionsج‎does not contribute to modern slaveryج‎and that the compensating and preventative controls residing with partner (academic) institutions to pre-screen applicants, and governments’ robust student-visa-approval processes (in Canada, US, UK, Ireland, Australia) mitigate the risk of student exploitation in دم½¶تسئµâ€™s supply chain.ج‎

دم½¶تسئµ has a significantج‎geographicalج‎footprint as its mission of Educating the World is intrinsically tied to countries often most associated with occurrences of modern slavery including India, Pakistan, China, Nigeria, Indonesia, and the Philippines. Given the nature of دم½¶تسئµâ€™s operations and business and the services performed by its RPs (many of which operate other businesses including education consulting, language schools, travel agencies), it isج‎extremely unlikely that دم½¶تسئµ is directly linked to modern slaveryج‎practices.

Policies

دم½¶تسئµ maintains policies that support good governance including its Code of Business Conduct and Ethics, Whistleblower Policy, Suppression of Terrorism and Sanctions Policy, and Global Procurement Policy.ج‎

دم½¶تسئµâ€™s RPs are subject to due diligence before being onboarded and they sign terms and conditions with دم½¶تسئµ where they agree they are familiar with modern slavery, and the UK and Australian acts.

Remediation measures and effectiveness of actions

Modern slavery risks were assessed in accordance with دم½¶تسئµâ€™s existing enterprise risk management framework and risk tolerances.ج‎
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دم½¶تسئµ has stated it has zero tolerance to modern slavery but understands any measures taken to de-risk, specifically in geographies most associated with modern slavery, could result in the loss of income to the most vulnerable families. Any modern slavery issues would be reported to دم½¶تسئµâ€™s enterprise risk management committee and/or its RP compliance committees, sub-committees of its Executive Committee.

Statement of Approval

Approved by دم½¶تسئµ. Board of Directors on November 25 , 2024.