1. Introduction

This statement sets out Learner Key Ltd.’s (Company Reg. SC 339387, registered at 23 Scotland Street, Glasgow G5 8NB, www.learnerkey.com) commitment to understanding all potential modern slavery risks related to its business and to putting in place steps aimed at ensuring that modern slavery and human trafficking are not taking place within its business or supply chains.

2. Our Commitment

Learner Key Ltd is committed to acting ethically and with integrity in all its business dealings and relationships. We are committed to preventing acts of modern slavery and human trafficking from occurring within our business and supply chains. We strive to ensure that all our activities comply with the Modern Slavery Act 2015.

3. Our Business and Supply Chains

Learner Key Ltd operates as an educational provider. Our supply chains primarily involve services related to:

• Educational materials and resources.
• IT services and software.
• Professional services (e.g., legal, accounting).
• Premises management (if applicable).

We assess our supply chains to be low risk in relation to modern slavery and human trafficking due to the nature of the services procured and the geographical locations of our suppliers.

4. Our Policies on Slavery and Human Trafficking

We operate internal policies to ensure that we are conducting business ethically and transparently. These include:

• Recruitment Policy: Ensuring robust recruitment processes, including checking eligibility to work in the UK for our staff.
• Whistleblowing Policy: Encouraging staff to report any concerns related to practices within our business or supply chains.
• Code of Conduct: Setting out the expected ethical behaviour for all staff members.

5. Due Diligence Processes

While our risk is considered low, we undertake due diligence when engaging with new suppliers or reviewing existing ones. This may include:

• Requesting suppliers to confirm their compliance with relevant legislation.
• Assessing the nature of the services and the supplier’s policies.

6. Training

We aim to raise awareness among our staff regarding the risks of modern slavery and human trafficking. Relevant staff are encouraged to familiarise themselves with this statement and report any concerns.

7. Further Steps

Learner Key Ltd will continue to review and refine its processes to combat modern slavery and human trafficking in line with best practice and legislative developments.

8. Review

This statement will be reviewed annually and updated as necessary.