Modern Slavery Statement

A) Organisation

This statement applies to all companies within and associated to Gateway Educonnect (referred to in this statement as ‘The Group’).

B) Organisational Structure

Gateway Educonnect Investment Pte Ltd is the holding company for Gateway Educonnect’s group of companies, including entities in India, the USA, the UK and Australia. The Gateway Educonnect group is managed via the Gateway Educonnect Investment Pte Ltd Board which meets quarterly and is made up of both executive and non-executive directors and a designated Chairman.

Gateway Educonnect supports organisations looking to Explore, Enter and Expand into dynamic international markets. These activities can be broadly categorised into advisory and ongoing support activity. The work is largely unseasonal with the exception of peaks in activity as driven by local financial, accounting and compliance and HR regulations in the markets that we operate.

The labour supplied to the Gateway Educonnect group in pursuance of its operation is carried out in the UK, India and the USA. Gateway Educonnect’s team travel from time to time domestically and internationally as their role requires.

C) Definitions

Gateway Educonnect considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have a restriction placed on freedom of movement

D) Commitment

Gateway Educonnect acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Gateway Educonnect understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

Gateway Educonnect does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Gateway Educonnect in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Gateway Educonnect strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK, India and the USA, and in many cases exceeds those minimum standards in relation to its employees.

E) Supply Chains

In order to fulfil its activities, Gateway Educonnect’s main supply chains include those related to the supply of services to run the business (e.g. HR services, premises, marketing, technology, finance and admin) or services required to supply clients (e.g. market entry and support services in countries in which Gateway Educonnect does not have a business).

F) Potential Exposure

Given the nature of our business, Gateway Educonnect considers its main exposure to the risk of slavery and human trafficking to be in the supply of labour in countries where protection against breaches of human rights may be limited.

In general, Gateway Educonnect considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

G) Steps

Gateway Educonnect carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

Gateway Educonnect has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Gateway Educonnect has taken the following steps to ensure that modern slavery is not taking place:

• Reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery.

H) Key Performance Indicators

Gateway Educonnect has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in Gateway Educonnect or its supply chains.

• Periodic engagement of ‘at-risk’ staff via Gateway Educonnect’s Human Capital Team’s regular Employee Relations activity

I) Policies

Gateway Educonnect has the following policies which further define its stance on modern slavery:

• Code of conduct
• Recruitment policy

J) Training

Gateway Educonnect provides the following training to staff to effectively implement its stance on modern slavery:

• For our Human Capital and Admin Operations teams in India, training on modern slavery policies.

K) Slavery Compliance Officer

Gateway Educonnect has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Gateway Educonnect obligations in this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.