Anti-Slavery Policy​

Modern Slavery (Anti-Slavery and Human Trafficking) Policy

INTRODUCTION

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

OUR BUSINESS AND ORGANISATION STRUCTURE 

RapL Inc., a Delaware US corporation and its subsidiaries provide online and mobile learning solutions to enterprise and education customers around the world. This statement applies to all RapL’s businesses.

OUR SUPPLY CHAINS

As a technology solution and services company, we outsource some business functions, for example, some content creation services.

OUR POLICIES ON MODERN SLAVERY

RapL is committed to protecting Human Rights and prohibiting all acts of human trafficking, slavery, servitude, forced marriage, forced or compulsory labour, debt bondage, deceptive recruiting for labour or services, and child labour throughout the organization, its business and supply chain. Pursuant to the UK Modern Slavery Act 2015 and Australia’s Modern Slavery Act, 2018, RapL herein elucidates its initiatives to mitigate/eradicate modern slavery and human trafficking from its business and supply chain. 

RapL has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

RapL is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery. We expect the same high standards from all our contractors, suppliers, and other business partners. We expect that our suppliers will hold their own suppliers to the same high standards.

SCOPE/TO WHOM THIS POLICY APPLIES

This policy applies to all persons working for RapL or on our behalf in any capacity, including employees at all levels, directors, officers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

This policy does not form part of any employee’s contract of employment and RapL may amend it at any time. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

COMPLIANCE WITH THIS POLICY

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

TRAINING

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will be provided, as necessary. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.