ApplyBoard Modern Slavery Annual Statement

Introduction 

ApplyBoard Inc. (“ApplyBoard”) recognizes that modern slavery is a worldwide problem and appreciates the efforts from both the public and private sector to eradicate it. ApplyBoard strives to act ethically and with integrity in all its business relationships and maintains processes and controls to avoid involvement in human rights violations related to its own operations, supply chain, and services.

ApplyBoard’s statement was produced in accordance with the obligations under the UK Modern Slavery Act of 2015 and the Australian Modern Slavery Action 2018. Although Canada’s bill S-211 has not been enacted at this time, the obligations in the proposed Canadian legislation were considered.

About ApplyBoard

ApplyBoard was founded in Kitchener, Ontario, Canada in 2015. The organization simplifies the study abroad search, application, and acceptance process by connecting international students, recruitment partners (“RPs”), and academic institutions on one platform. 

ApplyBoard believes that education is a right for human beings, not a privilege and empowers people around the world to access the best education.

People and Supply Chains at ApplyBoard

ApplyBoard operates in the education and technology sectors and procures goods and services from a range of suppliers. It does not have complex supply chains or vendor relationships with large businesses in sectors where modern slavery has been found to be an issue (i.e., mining, fishing, construction, etc).

Its people are not engaged in low-skilled, low-paying or hazardous jobs considered high-risk for modern slavery. Instead its people are engaged in: 

• Knowledge work roles including software programmers, engineers, accountants, project managers, lawyers, relationship managers, and editors.
• Processing and production roles including people who process electronic applications from international students.
• Delivery of products or services roles including those who manage or support RPs in the field, and support people on their student journey.

Identifying and assessing modern slavery risks

ApplyBoard was unable to identify any occurrence where its activities caused an adverse impact to its people. This conclusion is based on the sector in which it operates, the online services it provides and the functions that its people perform directly for ApplyBoard.

ApplyBoard recognizes that any organization could be unknowingly indirectly linked to the risk of modern slavery through its suppliers of products and services but believes this is extremely unlikely given its sector, services and functions. Most of its largest suppliers show accountability by having prepared modern slavery statements despite the absence of Canadian and American legislation driving compliance.

ApplyBoard is confident its online platform for connecting international applicants to educational institutions does not contribute to modern slavery and that the compensating and preventative controls residing with partner (academic) institutions to pre-screen applicants, and governments’ robust student-visa-approval processes (in Canada, US, UK, Ireland, Australia) mitigate the risk of student exploitation in ApplyBoard’s supply chain. 

ApplyBoard has a significant geographical footprint as its mission of Educating the World is intrinsically tied to countries often most associated with occurrences of modern slavery including India, Pakistan, China, Nigeria, Indonesia, and the Philippines. Given the nature of ApplyBoard’s operations and business and the services performed by its RPs (many of which operate other businesses including education consulting, language schools, travel agencies), it is extremely unlikely that ApplyBoard is directly linked to modern slavery practices.

Policies

ApplyBoard maintains policies that support good governance including its Code of Business Conduct and Ethics, Whistleblower Policy, Suppression of Terrorism and Sanctions Policy, and Global Procurement Policy. 

ApplyBoard’s RPs are subject to due diligence before being onboarded and they sign terms and conditions with ApplyBoard where they agree they are familiar with modern slavery, and the UK and Australian acts.

Remediation measures and effectiveness of actions

Modern slavery risks were assessed in accordance with ApplyBoard’s existing enterprise risk management framework and risk tolerances. 

ApplyBoard has stated it has zero tolerance to modern slavery but understands any measures taken to de-risk, specifically in geographies most associated with modern slavery, could result in the loss of income to the most vulnerable families. Any modern slavery issues would be reported to ApplyBoard’s enterprise risk management committee and/or its RP compliance committees, sub-committees of its Executive Committee.

Next steps

The organization expects awareness of its program to grow and develop once the proposed Canadian bill S-211 or “Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff“ enters into force in 2024 (expected).

Statement of Approval

Approved by ApplyBoard Inc. Board of Directors on April 4, 2023.