Modern Slavery Statement

Last Updated: 24th January 2025

Growth Engineering is committed to the highest standards of ethical conduct and social responsibility. We recognise that modern slavery is a serious global issue affecting millions of people, including within developed economies. As a B-Corp accredited provider of learning management solutions, we take a zero-tolerance approach to slavery and human trafficking in our operations and supply chains.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and outlines the steps we have taken during the financial year ending 31 December 2026 to prevent modern slavery and human trafficking.

Our Business and Supply Chains

Growth Engineering operates globally, delivering SaaS-based learning solutions to clients across the public and private sectors. We maintain trusted relationships with our suppliers, built on integrity and mutual respect. Our supplier onboarding process includes due diligence checks covering legal compliance, health and safety standards, and ethical practices.

We have not received any allegations of modern slavery or human trafficking within our supply chain. Should any arise, we would act immediately and report the matter to the relevant authorities.

Risk Assessment

We conduct annual risk assessments of our supply chain, considering:

• Country-level risk profiles using the Global Slavery Index
• Nature of services provided
• Presence of vulnerable demographic groups
• News analysis and insights from labour and human rights organisations

These assessments inform our mitigation strategies and control measures.

Policies and Governance

We have implemented the following policies to identify and prevent modern slavery:

• Whistleblowing Policy: Encourages confidential reporting of concerns without fear of retaliation.
• Code of Conduct: Sets clear expectations for ethical behaviour across all business activities.
• Purchasing Code: Explicitly references modern slavery and is embedded in supplier contracts.

Supplier Due Diligence

We conduct due diligence on all new and existing suppliers, including:

• Risk assessments based on service type and geography
• Audits of health and safety standards, labour relations, and employment contracts
• Sanctions for non-compliance with our ethical standards

Suppliers are required to confirm that:

• No forced, bonded, or involuntary labour is used
• Employees work voluntarily and may leave freely
• Employment contracts include reasonable notice periods
• No deposits or salary withholding practices are in place
• Passports or work permits are not retained by the employer

Training and Awareness

We have rolled out mandatory training and awareness programmes for all employees and supplier contacts. These cover:

• Forms and indicators of modern slavery
• Reporting mechanisms and escalation procedures
• Guidance for suppliers on implementing anti-slavery controls
• Support available for victims

Employees are required to attest their commitment to our anti-slavery policy.

Measuring Effectiveness

We monitor our performance using key indicators, including:

• Completion rates of mandatory training
• Supplier adoption of equivalent awareness programmes
• Ethical issue reporting by staff
• Findings from our cross-functional Ethics Team

Future Commitments

We will continue to strengthen our approach by:

• Enhancing supplier engagement and ethical sourcing
• Expanding training content and delivery
• Collaborating with public sector partners to promote social value

Approval

This statement covers the period from 1 January 2025 to 31 December 2026 and has been approved by the Board of Directors.