Modern Slavery and Human Trafficking Policy

Global Pathway Partners Ltd (GP2)

Effective Date: 29/09/2026
Last Reviewed: 29/09/2026
Policy Owner: Directors, Global Pathway Partners Ltd

1. Policy Statement

Global Pathway Partners Ltd (“GP2”, “we”, “us” or “our”) is committed to conducting its business ethically, responsibly and with respect for human rights.

GP2 has a zero-tolerance approach to modern slavery, human trafficking, forced labour, servitude, exploitation and other practices that deprive individuals of their freedom or dignity.

We expect our employees, contractors, partners, suppliers and other business associates to share these principles and to conduct their activities in accordance with applicable laws and appropriate ethical standards.

This policy sets out GP2’s approach to identifying, preventing and addressing modern slavery and human trafficking risks within our business activities and relevant business relationships.

2. About GP2

GP2 operates within the international education referral sector. Our activities may include providing education-related information, generating student enquiries and connecting individuals with education providers, learning platforms, consultants and specialist partners.

Our operations may involve relationships with organisations and individuals in different countries and jurisdictions. We recognise that differing legal, regulatory and employment environments can create varying levels of risk.

3. Our Partner and Supplier Network

Depending on the nature of our activities, GP2 may work with:

• Education recruitment and referral partners;
• Education providers and authorised representatives;
• Independent consultants and professional service providers;
• Technology and software suppliers;
• Marketing and digital service providers;
• Student-support and administrative service providers; and
• Other organisations or individuals supporting our business activities.

We recognise that modern slavery risks may arise not only within our direct operations but also through third parties and extended business relationships.

4. Our Commitment

GP2 expects people involved in our operations and business relationships to be treated fairly, lawfully and with dignity.

In particular, we do not support or tolerate:

• Forced, bonded or compulsory labour;
• Human trafficking or the exploitation of individuals;
• Slavery or servitude;
• The use of threats, coercion or intimidation to obtain or maintain labour;
• Unlawful withholding or confiscation of identity or travel documents;
• Unlawful recruitment or employment fees imposed on workers;
• Deceptive recruitment practices; or
• Other practices that unlawfully restrict an individual’s freedom to work or leave employment.

Where relevant to our activities, GP2 expects workers to receive appropriate information about their employment or engagement and to be able to raise concerns without intimidation or retaliation.

5. Risk Awareness and Assessment

GP2 recognises that modern slavery risks can vary depending on the nature and location of activities, the use of third-party organisations and the structure of supply and partner networks.

Potential risk factors may include:

• Extended or complex partner and supplier networks;
• Outsourced or subcontracted services;
• Recruitment-related activities;
• Temporary or migrant labour;
• Cross-border business relationships;
• Operations or services in jurisdictions where worker protections may be weaker; and
• Limited transparency within third-party supply chains.

GP2 aims to take a proportionate, risk-based approach to identifying and addressing these risks.

6. Due Diligence

Where appropriate and proportionate to the nature of the relationship, GP2 may undertake due diligence before and during engagement with partners, suppliers and other relevant third parties.

This may include:

• Considering the identity, location, ownership and role of a proposed partner or supplier;
• Reviewing relevant registrations, licences, professional permissions or other available information;
• Assessing relevant policies, procedures or ethical standards;
• Communicating appropriate compliance and ethical expectations;
• Including relevant contractual provisions where appropriate;
• Considering credible concerns, complaints or warning signs; and
• Reviewing relationships where material risks or concerns arise.

Where serious concerns relating to modern slavery or human trafficking are identified and cannot reasonably be addressed, GP2 may suspend, restrict or terminate the relevant business relationship, subject to applicable contractual and legal requirements.

7. Recruitment and Working Practices

GP2 is committed to fair and responsible recruitment and working practices.

Where applicable to our direct workforce and engagements, we aim to:

• Follow applicable employment and recruitment laws;
• Verify the right to work where legally required;
• Avoid retaining workers’ identity documents except where lawful and genuinely necessary;
• Avoid practices that require workers to pay unlawful recruitment or employment fees;
• Provide appropriate information regarding relevant terms and conditions; and
• Treat individuals with dignity, fairness and respect.

We expect relevant third parties acting on behalf of GP2 to maintain comparable standards.

8. Training and Awareness

GP2 will promote awareness of modern slavery and human trafficking risks among individuals whose responsibilities may expose them to relevant risks, including those involved in:

• Partner and supplier management;
• Recruitment and engagement;
• Business operations; and
• Compliance or risk management.

Where appropriate, relevant personnel should understand common indicators of exploitation and know how to escalate concerns.

9. Reporting Concerns

GP2 encourages employees, contractors, partners, suppliers and other relevant parties to raise genuine concerns about suspected modern slavery, human trafficking or related exploitation.

Concerns should be reported through GP2’s designated management or compliance contact.

Reports should be treated seriously and reviewed appropriately. GP2 will seek to handle concerns responsibly and, where appropriate, maintain confidentiality to the extent reasonably possible and permitted by law.

Where there is an immediate risk of serious harm or danger to an individual, the appropriate emergency service or competent authority should be contacted.

GP2 does not tolerate retaliation against a person who raises a genuine concern in good faith.

10. Monitoring and Record Keeping

Where relevant and proportionate to our activities, GP2 may maintain records relating to:

• Relevant due-diligence checks;
• Risk assessments or reviews;
• Partner and supplier requirements;
• Concerns or reports received;
• Investigations and corrective actions; and
• Relevant training or awareness activities.

These records may be reviewed periodically to help GP2 assess the effectiveness of its approach and identify areas where additional controls may be appropriate.

11. Responsibilities

The directors of GP2 have overall responsibility for approving and overseeing this policy.

Individuals involved in managing employees, partners, suppliers or relevant business relationships are expected to support the principles contained in this policy and to escalate material concerns appropriately.

All relevant third parties are expected to comply with applicable laws and to cooperate with reasonable GP2 requests relating to ethical business practices and modern slavery risk.

12. Policy Review

This policy will be reviewed periodically and may be updated when there are material changes to GP2’s business activities, partner network, risk profile or applicable legal and regulatory requirements.

The directors retain responsibility for approving material changes to this policy.

13. Legal Status

This policy represents GP2’s voluntary commitment to preventing and addressing modern slavery and human trafficking risks within its activities and relevant business relationships.

It is not intended to constitute, and should not be interpreted as, a statutory modern slavery statement under Section 54 of the Modern Slavery Act 2015, unless GP2 is legally required to publish such a statement and expressly identifies this document as fulfilling that requirement.

Global Pathway Partners Ltd
Website: https://gp2.online/
Policy: Modern Slavery and Human Trafficking Policy
Approved by: The Directors of Global Pathway Partners Ltd