1.   Policy Statement

Modern slavery is one of the most critical and complex human rights challenges facing the world today. Slavery is a crime and a violation of fundamental human rights. Although there is no finalised definition, ‘modern slavery’ is used as an umbrella term to cover a range of exploitative situations that an individual cannot leave or refuse due to threats of violence, coercion, deception, or abuse of power.[1] It takes various forms, such as slavery, servitude, forced and compulsory labor, forced marriage, debt bondage and human trafficking, whether adults or children, all of which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain (‘Modern Slavery’).

Apiom Inc (DUNS: 80363488) and its subsidiaries, including Go1 Pty Ltd (ACN 134 998 020) and Go1 UK Learning Ltd (Company number: 11867333) (‘Go1’ or ‘our’) have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships.

This policy sets out Go1’s commitment to:

• (a) Ensure there is transparency in our approach to tackling modern slavery in our own business and throughout our supply chains;
• (b) Responsibly source goods and services used by our business;
• (c) Take action to prevent, mitigate and where appropriate, remediate the harm caused by modern slavery occurring in our business or supply chains; and
• (d) Comply with applicable laws and regulations including under the Modern Slavery Act 2018 (Cth) of Australia and the Modern Slavery Act (2015) of the United Kingdom.

We expect the same high standards from all Distribution Partners, Content Partners, contractors, suppliers, and other business partners (‘you’). As a content aggregator and software provider we are fortunate that our supply chain presents limited risk of modern slavery. However, where we do identify that there is a risk, we include specific prohibitions against modern slavery in our contracts. We expect that our suppliers will hold their suppliers to high standards and include due diligence processes to ensure modern slavery risk is identified, assessed, addressed and where appropriate, remediated.

This policy (including any updates) must be complied with and incorporated into the policies, procedures, and operations of our own business and our supply chains.

This policy applies to all persons working for us or on our behalf in any capacity, including (but not limited to) employees at all levels, directors, officers, agency workers, seconded workers, interns, agents, contractors, external consultants, third-party representatives, supply chain participants, and business partners. Any persons working for or with us are to read this policy alongside the Go1 Code of Conduct.

This policy does not form part of any commercial contract or any employee's contract of employment, and we may amend it at any time.

2.   Minimum Modern Slavery Standards

The minimum modern slavery standards expected of our own business, employees and supply chain include:

• (a) Compliance with applicable modern slavery laws and regulations;
• (b) Compliance with other applicable relevant laws (including but not limited to laws relating to minimum working age, employment conditions, and wages).
• (c) Ensuring workers have the right to freely choose employment and enjoy freedom of movement and association;
• (d) Provision of safe and clean working conditions;
• (e) Provision of a work environment free from discrimination, harassment, and abuse;
• (f) Appointment of a compliance officer/s with responsibility for overseeing the implementation and monitoring of modern slavery policies and procedures;
• (g) Implementation and participation in training, consultation, and engagement to identify, understand, and address modern slavery risks;
• (h) Regular internal and external audits to check for signs of modern slavery within our business;
• (i) Commitment to mitigating any identified risks of modern slavery;
• (j) Commitment to provide remediation where required.

3.   Responsibility for the Policy

The board of directors of Apiom Inc (‘the Board’) has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that our business and supply chains comply with it. The Board is also responsible for approving our annual modern slavery statement and ensuring that it complies with local legislative requirements.

The General Counsel and Chief People Officer (Compliance Officers) are jointly responsible for the day-to-day implementation of this policy, and for monitoring its use and effectiveness. They are also responsible for answering any queries about this policy. The Compliance Officers’ responsibilities extend to:

• (a) monitoring and auditing internal controls and procedures, and consulting with relevant stakeholders to identify risks of modern slavery practices in Go1’s operations;
• (b) monitoring, auditing, and consulting with our contractors and suppliers to identify risks of modern slavery practices in our supply chains;
• (c) developing measures to assess and address any risks of modern slavery, including through due diligence and contractual obligations;
• (d) monitoring the effectiveness of those measures;
• (e) developing appropriate training materials and programs for our employees to comply with this policy;
• (f) developing remediation programs and grievance mechanisms; and
• (g) Overseeing the preparation of our annual modern slavery statements in accordance with local legislative requirements.

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.

Employees and our contractors are also responsible for aiding their own understanding of this policy, participating in training, following this policy into their day-to-day activities and reporting any risks of modern slavery they identify in our business or supply chains via Go1’s grievance/whistleblower mechanisms.

Suppliers are responsible for ensuring their employees and suppliers involved in the supply of goods or services to Go1 understand and comply with this policy and are given adequate and regular training.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Compliance Officers at [email protected]  

4.  Compliance with the Policy

Anyone who is working for Go1 (e.g. our employees and contractors), on our behalf (e.g. our suppliers, Distribution Partners, and Content Partners) or under our control (e.g. our subsidiaries) must ensure that they have read, understand, and comply with this policy.

We are all responsible for the prevention, detection, and reporting of modern slavery. You are required to avoid any activity that might lead to a potential or actual breach of this policy or relevant laws making modern slavery an offence.

If you believe or suspect that a breach of this policy has occurred, or may occur in the future, as soon as possible, you must notify the Compliance Officers or report your concerns in accordance with our Whistleblowing Policy. Similarly, if you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within our business or any tier of our supply chains constitutes any of the various forms of modern slavery, please notify the Compliance Officers or report your concerns in accordance with our Whistleblowing Policy.

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.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

If you believe that you have suffered any such treatment, you should inform the Compliance Officers immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the process set out in the Go1 Whistleblowing Policy.

5.   Communication and awareness of this policy

As a leading training provider, the Go1 platform has a number of training courses addressing the critical issue of modern slavery. The training that will be provided to our employees on modern slavery will address how to identify modern slavery practices, key areas of risk, mitigation steps that can be taken, and how to report concerns. This training will also form part of the induction process for all new employees.

Our zero-tolerance approach to modern slavery in our business and supply chains must be communicated to all contractors and supply chain participants at the outset of our business relationship with them and reinforced as appropriate thereafter (including by way of obligations included in high-risk supply contracts).

6.   Breaches of this policy

Go1 is committed to the global end to modern slavery and will therefore take any breach of this policy with the utmost seriousness. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. If we become aware of any breach of this policy by any individuals or organisations working with Go1 in any capacity, we may terminate our relationship with them.

7.   Review of this Policy

This policy will be reviewed on an annual basis and may be updated by Go1 from time to time. Any updates to this policy must be complied with by our business and our supply chains.

This policy was last updated on: December 12, 2023