Modern Slavery & Human Trafficking Policy
Last updated: January 2, 2026
1. Policy Statement
Lynx Educate SAS (“Lynx Educate”) is committed to conducting its business ethically, responsibly, and transparently. We recognise our responsibility to respect human rights and to take active steps to prevent modern slavery and human trafficking in our operations and supply chains.
Although Lynx Educate is not currently required to publish a statement under the UK Modern Slavery Act 2015, we voluntarily adopt the principles of the Act and align our practices with internationally recognised human rights standards, including the International Labour Organization (ILO) conventions and the UN Guiding Principles on Business and Human Rights.
Lynx Educate has zero tolerance for modern slavery and human trafficking.
2. Scope
This policy applies to:
- All employees, directors, officers, interns, and contractors of Lynx Educate
- All suppliers, subcontractors, consultants, and business partners with whom Lynx Educate has a direct commercial relationship
- Any other parties acting on behalf of Lynx Educate
3. Definition of Modern Slavery
For the purposes of this policy, “modern slavery” includes:
- Slavery and servitude
- Forced or compulsory labour
- Human trafficking
- Debt bondage
- Child labour and the worst forms of child exploitation
These practices are strictly prohibited within Lynx Educate’s business and in any part of its supply chain that it can reasonably influence.
4. Organisational Context and Risk Profile
Lynx Educate SAS is an education and learning-focused organisation operating internationally, with a distributed supplier base that includes technology providers, professional service firms, facilities services, and other third-party vendors.
While Lynx Educate’s direct operations present a relatively low inherent risk of modern slavery, we recognise that risks may arise through:
- International supply chains
- Use of outsourced or subcontracted services
- Suppliers operating in jurisdictions with weaker labour protections
We therefore adopt a risk-based and proportionate approach to managing modern slavery risks.
5. Commitments
Lynx Educate commits to:
- Prohibiting forced, bonded, involuntary, or trafficked labour in any form
- Respecting the rights of workers to freedom of movement and freedom of association
- Working with suppliers that comply with applicable labour and employment laws
- Taking reasonable steps to identify, assess, and mitigate modern slavery risks
- Acting promptly and appropriately if concerns are identified
6. Due Diligence and Practical Measures
To give effect to this policy, Lynx Educate implements proportionate measures including:
- Maintaining oversight of key and critical suppliers
- Applying risk-based supplier assessments aligned to supplier geography, service type, and criticality
- Including ethical, labour-law, and modern slavery expectations in supplier contracts where appropriate
- Periodically reviewing core suppliers (at least annually) for emerging risks
- Committing to completion and annual re-assessment using the UK Cabinet Office Modern Slavery Assessment Tool (MSAT), with results shared with contracting authorities upon request
7. Training and Awareness
All employees are expected to:
- Act ethically and in accordance with this policy
- Remain alert to potential indicators of modern slavery
- Raise concerns where suspected risks are identified
As Lynx Educate grows, it will consider introducing more formal training and awareness activities proportionate to its size and risk profile.
8. Reporting Concerns and Whistleblowing
Concerns relating to suspected modern slavery or human trafficking may be raised:
- Confidentially with management
- Via Lynx Educate’s Whistleblowing Policy
All concerns will be taken seriously, investigated appropriately, and handled confidentially. Lynx Educate strictly prohibits retaliation against any individual who raises a concern in good faith.
9. Governance, Review, and Continuous Improvement
Senior management is responsible for:
- Oversight of this policy
- Ensuring appropriate implementation
- Reviewing effectiveness annually
This policy will be reviewed at least once per year and updated to reflect changes in business operations, supply chain risks, or regulatory expectations.
