Applyboard Modern Slavery Annual Statement

91猎奇. Modern Slavery Statement

Introduction

91猎奇. (鈥�91猎奇鈥�) recognizes that modern slavery is a worldwide problem and appreciates the efforts from both the public and private sector to eradicate it. 91猎奇 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.

91猎奇鈥檚 statement was produced in accordance with the obligations under the听UK Modern Slavery Act of 2015听and the听Australian Modern Slavery Action 2018. Although Canada鈥檚 bill S-211 has not been enacted at this time, the obligations in the proposed Canadian legislation were considered.

About 91猎奇

91猎奇 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 (鈥淩Ps鈥�), and academic institutions on one platform.听
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91猎奇 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 91猎奇

91猎奇 operates in the education and technology sectors and procures goods and services from a range of suppliers. It听does not听have complex supply chains听or 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 are听not听engaged听in low-skilled, low-paying or hazardous jobs considered high-risk for modern slavery. Instead its people are engaged in:听

Knowledge work roles including software programmers, engineers, accountants, project managers, lawyers, relationship managers, and editors.
Processing and production roles including people who process electronic applications from international students.
Delivery of products or services roles including those who manage or support RPs in the field, and support people on their student journey.

Identifying and assessing modern slavery risks

91猎奇 was unable to identify any occurrence where听its activities听caused 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 91猎奇.

91猎奇 recognizes听that any organization could be unknowingly indirectly linked听to 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.

91猎奇 is confident its online platform for connecting international applicants to educational institutions听does not contribute to modern slavery听and that the compensating and preventative controls residing with partner (academic) institutions to pre-screen applicants, and governments鈥� robust student-visa-approval processes (in Canada, US, UK, Ireland, Australia) mitigate the risk of student exploitation in 91猎奇鈥檚 supply chain.听

91猎奇 has a significant听geographical听footprint 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 91猎奇鈥檚 operations and business and the services performed by its RPs (many of which operate other businesses including education consulting, language schools, travel agencies), it is听extremely unlikely that 91猎奇 is directly linked to modern slavery听practices.

Policies

91猎奇 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.听

91猎奇鈥檚 RPs are subject to due diligence before being onboarded and they sign terms and conditions with 91猎奇 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 91猎奇鈥檚 existing enterprise risk management framework and risk tolerances.听
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91猎奇 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 91猎奇鈥檚 enterprise risk management committee and/or its RP compliance committees, sub-committees of its Executive Committee.

Statement of Approval

Approved by 91猎奇. Board of Directors on November 25 , 2024.