MODERN SLAVERY POLICY

Dual-Jurisdiction Policy: Malaysia • United Kingdom

Document Reference	BAC-EG-MSP-V1.0
Policy Type	Mandatory – Group-wide
Version	1.0
Effective Date	1 July 2025
Policy Owner	Group General Counsel, BAC Education Group
Approved By	Board of Directors / Academic Board, BAC Education Group
Malaysian Law Basis	Anti-Trafficking in Persons and Anti-Smuggling of Migrants Act 2007 (ATIPSOM) (as amended 2022) | Employment Act 1955 (as amended 2023) | Passport Act 1966 | ILO Forced Labour Convention 1930 (ratified Malaysia 1957)
UK Law Basis	Modern Slavery Act 2015 (MSA), s.54 | UK Home Office Transparency in Supply Chains Statutory Guidance (March 2025) | Proceeds of Crime Act 2002
International Frameworks	ILO Protocol of 2014 to the Forced Labour Convention | UN Protocol to Prevent, Suppress and Punish Trafficking in Persons (Palermo Protocol) | UN Guiding Principles on Business and Human Rights (UNGPs) | OECD Guidelines for Multinational Enterprises
Review Cycle	Annual (mandatory); or earlier upon material law change
Next Review Due	1 July 2027
Classification	Public – to be published on Group website

1. STATEMENT OF COMMITMENT

BAC Education Group (“the Group”) comprising Brickfields Asia College, IACT College, Veritas University College, UNIMY, and Reliance College (collectively “the Institutions”) is committed to acting ethically, with integrity, and with full transparency in all its business relationships and operations. The Group has zero tolerance for all forms of modern slavery, human trafficking, forced labour, debt bondage, child labour, and any practice that deprives a person of their freedom and dignity.

This Policy applies to all persons and entities connected to the Group, including employees, academic staff, adjunct lecturers, administrative staff, contractors, suppliers, service providers, recruitment agencies, and business partners, wherever they are located.

Malaysian Law Commitment	UK Law Commitment
The Group complies with and supports the full enforcement of: Anti-Trafficking in Persons and Anti-Smuggling of Migrants Act 2007 (ATIPSOM), as amended in 2022 Employment Act 1955, as amended (including the 2023 forced labour provisions) Passport Act 1966 (prohibition on passport retention) Children and Young Persons (Employment) Act 1966 Private Employment Agencies Act 1981	The Group complies with and supports the full enforcement of: Modern Slavery Act 2015 (MSA), including s.54 transparency obligations UK Home Office Transparency in Supply Chains Statutory Guidance (March 2025) Proceeds of Crime Act 2002 (supply chain criminal liability) Modern Slavery Act 2015 (s.1–3): offences of slavery, servitude, forced labour, and human trafficking

2. SCOPE

This Policy applies to:

• All employees of the Group including full-time, part-time, adjunct, temporary, seconded, and contracted personnel.
• All students: to the extent they participate in work placements, internships, clinical programmes, or employment-related activities facilitated by the Group.
• All suppliers, vendors, and service providers: including cleaning, catering, maintenance, security, IT, staffing agencies, and recruitment agencies.
• All third-party business partners: including joint venture partners, licensees, and affiliated organisations.
• All operations: across all five Institutions and the Group holding entity, in Malaysia and internationally.

3. DEFINITIONS

In this Policy, the following terms have the meanings set out below. Where Malaysian law and UK law use different terminology for the same underlying conduct, both terms are used.

Term	Definition / Legal Basis
Modern Slavery	An umbrella term covering slavery, servitude, forced or compulsory labour, and human trafficking. Offences under ss.1–4 of the UK Modern Slavery Act 2015. Equivalent conduct is criminalised in Malaysia under ATIPSOM and the Employment Act 1955.
Slavery and Servitude	Exercising powers of ownership over a person (slavery) or compelling a person to provide services using coercion where they cannot change their situation (servitude). s.1 MSA 2015.
Forced or Compulsory Labour	Work or service extracted from any person under the menace of any penalty and for which the person has not offered themselves voluntarily. ILO Convention No. 29 (1930), ratified by Malaysia (1957) and UK. Codified in s.1 MSA 2015; criminalised for employers under Employment Act 1955 s.99H (Malaysia) as amended 2023.
Human Trafficking	Recruiting, conveying, transferring, harbouring or receiving persons, by means of threat, force, coercion, deception, or abuse of power or vulnerability, for the purpose of exploitation. ATIPSOM s.12 (Malaysia); s.2 MSA 2015 (UK).
Debt Bondage	A situation where a worker is compelled to work to pay off a real or perceived debt, including inflated recruitment fees. A key indicator of forced labour in Malaysia’s migrant worker context.
Child Labour	Employment of a child (under 18 years in Malaysia; under 16 under UK law; under 18 for hazardous work under ILO Convention 182) in work that deprives them of childhood, dignity, or educational opportunity, or is harmful to their development.
Passport / Document Retention	Retaining or confiscating an employee’s identity document or travel document without lawful authority. A criminal offence under Malaysia’s Passport Act 1966; a recognised indicator of forced labour under UK guidance.
Exploitation	As defined in ATIPSOM: all forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude, any illegal activity or the removal of human organs.
Supply Chain	All external organisations and individuals that provide goods or services to the Group directly or indirectly, including sub-contractors and sub-suppliers at any tier.
Annual Transparency Statement (ATS)	The annual statement required under s.54 MSA 2015 (UK) and anticipated under proposed ATIPSOM amendments, setting out the steps taken to prevent modern slavery in the Group’s business and supply chains.

4. LEGAL FRAMEWORK: MALAYSIA AND UK COMPARED

This Policy is designed to comply with both legal frameworks simultaneously, applying the higher standard in every area.

Area	Malaysia	United Kingdom
Primary Statute	Anti-Trafficking in Persons and Anti-Smuggling of Migrants Act 2007 (ATIPSOM), as amended 2022; Employment Act 1955, as amended 2023	Modern Slavery Act 2015 (MSA)
Forced Labour Criminalisation	ATIPSOM s.12: 3–20 years’ imprisonment + fine. Employment Act s.99H: up to 2 years + RM100,000 fine (employer).	MSA s.1: up to life imprisonment for slavery/servitude; up to life for human trafficking.
Corporate Reporting Obligation	ATIPSOM Amendment (proposed s.57A): annual modern slavery, anti-trafficking, and anti-smuggling statement for qualifying commercial organisations. Thresholds to be prescribed by regulation.	MSA s.54: annual slavery and human trafficking statement mandatory for commercial organisations with turnover ≥£36 million carrying on any part of a business in the UK.
Statement Approval	Anticipated: Board-level or senior management approval.	MSA s.54(6): must be approved by Board of Directors (or equivalent) and signed by a director (or designated partner for an LLP).
Publication	Anticipated: formal publication requirement.	MSA s.54(7): must be published on the organisation’s website with a prominent homepage link. Recommended: upload to UK Government Modern Slavery Statement Registry.
Enforcement	ATIPSOM: criminal prosecution by MAPO/RMP. Employment Act: Department of Labour inspections, fines, and prosecution. Secretary of State may seek injunction.	MSA s.54: Secretary of State may apply for a High Court injunction. Breach of injunction: contempt of court, unlimited fine. Proceeds of Crime Act 2002: supply chain criminal liability for money laundering.
Passport Retention	Criminal offence under Passport Act 1966; also a trafficking indicator under ATIPSOM.	Recognised forced labour indicator under Home Office Guidance; potential criminal liability under MSA s.1 and s.2.
Migrant Worker Protection	Specific vulnerability; ATIPSOM amendments 2022 address debt-based coercion; employers must not retain passports.	MSA s.54 guidance requires explicit risk assessment for migrant worker supply chains.
ILO Protocol 2014	Ratified by Malaysia March 2022.	Ratified by UK November 2016.

5. RISK ASSESSMENT AND IDENTIFICATION

5.1 Group Risk Profile

BAC Education Group is an education services provider. Its primary operations involve teaching, curriculum delivery, and related educational services. The Group’s exposure to modern slavery risk, while lower than in manufacturing or agricultural supply chains, is not negligible. The key risk areas are:

Risk Area	Nature of Risk	Likelihood	Severity
Migrant Workers in Facilities Services	Cleaning, security, maintenance, and catering services are frequently provided by third-party contractors who may employ migrant workers vulnerable to debt bondage and passport retention.	Medium	High
Recruitment Agencies	Use of third-party staffing or recruitment agencies, particularly for lower-paid or temporary roles, creates risk of agency workers being subject to excessive recruitment fees or debt bondage.	Medium	High
Construction and Renovation Contractors	Campus construction, renovation, or fit-out contractors may use sub-contracted labour including migrant workers at risk of exploitation.	Medium – Low	High
IT and Technology Supply Chains	Hardware and technology goods may originate from supply chains in higher-risk jurisdictions where forced labour in manufacturing has been documented.	Low – Medium	Medium
Overseas Student Recruitment Agents	Agents recruiting international students may charge excessive fees to prospective students, creating debt-based vulnerability.	Low	High
Work Placements and Internships	Students placed with external employers may be vulnerable to exploitation if placement oversight is inadequate.	Low	High
Printing, Stationery, and Branded Goods	Procurement of uniforms, branded merchandise, and printed materials may involve supply chains in higher-risk manufacturing jurisdictions.	Low	Medium

5.2 Annual Risk Assessment Process

The Group shall conduct an annual modern slavery risk assessment covering:

1. Mapping the Group’s supply chains at least to Tier 1 (direct suppliers), with best-efforts mapping beyond Tier 1 for higher-risk categories.
2. Identifying geographic risk hotspots using internationally recognised risk indices (e.g. Global Slavery Index, US State Department TIP Report, ILO indicators).
3. Reviewing any incidents, complaints, or intelligence received during the preceding year.
4. Updating the risk register and prioritising due diligence resources accordingly.
5. Documenting areas of incomplete supply chain visibility and the steps being taken to improve visibility.

The annual risk assessment shall be led by the Group General Counsel (“GGC”) in consultation with the Head of Operations, Head of Finance, and Head of Human Resources. Findings shall be reported to the Board and incorporated into the Annual Transparency Statement.

6. DUE DILIGENCE

6.1 Supplier and Vendor Due Diligence

The Group will apply proportionate due diligence to all suppliers and vendors, with enhanced due diligence applied to higher-risk categories as identified in the annual risk assessment.

6.1.1 Pre-Engagement Due Diligence

Before engaging any new supplier, contractor, or service provider, the procurement team shall:

6. Complete a Modern Slavery Pre-Engagement Questionnaire covering: ownership structure; countries of operation; use of recruitment agencies or sub-contractors; worker recruitment practices; policies on passport retention; and any previous findings of modern slavery or labour violations.
7. For higher-risk suppliers: obtain copies of the supplier’s own modern slavery policy (or equivalent) and any relevant certifications or audit reports (e.g. Sedex SMETA, SA8000, Amfori BSCI).
8. Review publicly available information including news reports, NGO findings, and regulatory records.
9. Include anti-modern slavery contract provisions as standard (see Section 7).

6.1.2 Ongoing Due Diligence

• Annual review of all Tier 1 suppliers against the modern slavery risk criteria.
• Periodic on-site visits or independent audits for higher-risk suppliers, prioritised based on the annual risk assessment.
• Monitoring of supplier compliance with contractual anti-modern slavery obligations.
• Reviewing any changes in a supplier’s operations, ownership, or geographic footprint that may affect their risk profile.

6.1.3 Recruitment Agencies

The use of third-party recruitment agencies carries specific modern slavery risks, particularly in relation to domestic and migrant workers. The Group shall:

10. Only use recruitment agencies licensed under the Private Employment Agencies Act 1981 (Malaysia) and reputable equivalents in other jurisdictions.
11. Confirm in writing that the agency does not charge excessive recruitment fees to workers (in line with the ILO’s fair recruitment principles: fees should be paid by the employer, not the worker).
12. Verify that the agency does not retain workers’ passports or identity documents.
13. Require the agency to confirm compliance with Malaysian minimum wage legislation and Working Hours Regulations.
14. Conduct spot checks on agency-supplied workers to ensure their rights are being respected.

6.2 Human Resources Due Diligence

6.2.1 Recruitment and Onboarding

The Group’s HR function shall apply the following safeguards in all recruitment and onboarding processes:

15. All employees, regardless of nationality or employment status, must be recruited through a fair, transparent process with clear written terms of employment provided before work commences.
16. The Group shall never charge recruitment or placement fees to job applicants or employees.
17. Pre-employment verification shall confirm the right to work in Malaysia (or the relevant jurisdiction) through inspection of original documents. Documents shall be returned immediately after verification and shall not be retained.
18. Employment contracts shall be provided in a language understood by the employee, in English and Bahasa Melayu as standard, and in other languages where a significant proportion of the workforce requires it.
19. Deductions from wages shall only be made in circumstances permitted by the Employment Act 1955 and shall never be used as a coercive mechanism.

6.2.2 Migrant Worker Protections

Given Malaysia’s significant migrant workforce and the documented vulnerability of migrant workers to exploitation, the Group commits to the following specific protections:

20. The Group shall NEVER retain the passport, identity document, or any travel document of any employee, whether Malaysian or foreign national. This is a criminal offence under the Passport Act 1966 and is recognised as a fundamental indicator of forced labour.
21. Migrant workers shall be fully informed of their rights under Malaysian employment law, including minimum wage entitlements, rest day entitlements, and the right to change employers or terminate employment.
22. Housing or accommodation provided to migrant workers by the Group or any contractor shall meet minimum habitability standards. Workers shall not be required to live in accommodation as a condition of employment.
23. The Group shall not make deductions from wages in excess of those permitted by law, and shall not use inflated accommodation, transport, or food costs to create effective debt bondage.
24. Migrant workers shall have unimpeded access to their embassy or high commission and to relevant support organisations.

6.2.3 Work Placements and Student Internships

Where the Group facilitates work placements or internships for students:

25. Host employers must be vetted against modern slavery criteria before placement agreements are signed.
26. Students must be briefed on their rights, including the right to report exploitation without fear of academic penalty.
27. The Group shall maintain a point of contact for students to report concerns confidentially during placements.
28. Placement agreements must include a modern slavery compliance clause binding on the host employer.

6.3 Student Recruitment Agent Due Diligence

The Group uses third-party agents to recruit international students. Excessive fees charged by agents to prospective students create debt-based vulnerability. The Group commits to:

• Approving only agents who have signed the Group’s Agent Code of Conduct, which includes a prohibition on charging fees to students that exceed the Group’s published and approved agency commission structure.
• Conducting periodic audits of agent fee practices in higher-risk source countries.
• Maintaining a transparent, publicly accessible fee schedule to enable prospective students to verify that they have not been overcharged.
• Terminating agent agreements immediately upon evidence of student fee exploitation.

7. SUPPLY CHAIN STANDARDS AND CONTRACTUAL OBLIGATIONS

7.1 Supplier Code of Conduct

The Group requires all suppliers and contractors to adhere to the BAC Education Group Supplier Code of Conduct, which sets out the minimum standards expected of all suppliers in the following areas:

• Labour rights: compliance with all applicable local and international labour laws; payment of at least the statutory minimum wage; respect for workers’ rights to freely chosen employment.
• Prohibition on forced labour: no use of coerced, bonded, trafficked, or involuntary labour of any kind. No excessive recruitment fees. No retention of identity documents.
• Prohibition on child labour: no use of child labour as defined by applicable law and ILO Conventions 138 and 182.
• Freedom of movement: workers must be free to leave their employment and are not subject to physical or documentary restrictions on movement.
• Safe and healthy working conditions: compliance with all applicable health and safety laws.
• Non-retaliation: workers must be able to raise concerns without fear of retaliation.
• Sub-contractor compliance: suppliers must cascade equivalent requirements to their own sub-contractors and suppliers.

7.2 Mandatory Contract Provisions

All supply contracts, service agreements, and contractor engagements entered into by the Group shall include the following provisions as standard:

29. A representation and warranty by the supplier that it complies with all applicable anti-slavery, anti-trafficking, and labour laws, including ATIPSOM (Malaysia) and MSA 2015 (UK), and that it does not engage in or permit any form of modern slavery in its operations or supply chain.
30. An obligation to notify the Group promptly upon becoming aware of any actual or suspected modern slavery in its operations or supply chain.
31. The right of the Group to conduct or commission audits of the supplier’s relevant operations and records upon reasonable notice.
32. An obligation on the supplier to cooperate with any Group investigation into a modern slavery concern.
33. The right of the Group to terminate the contract immediately, without liability, upon evidence of modern slavery in the supplier’s operations.
34. A sub-contracting provision requiring the supplier to impose equivalent obligations on all sub-contractors.
35. A remediation obligation: where modern slavery is identified in a supplier’s operations, the supplier must implement a time-bound remediation plan approved by the Group, failing which the Group may terminate.

7.3 Preferred Supplier Incentives

The Group will recognise and preferentially procure from suppliers who:

• Hold recognised ethical labour certifications (Sedex, SA8000, Amfori BSCI, RSPO for palm oil products, or equivalent).
• Proactively publish their own modern slavery statement and supply chain mapping.
• Participate in the Group’s supplier engagement and capacity-building initiatives on modern slavery.

8. GROUP POLICIES AND COMMITMENTS

8.1 Zero Tolerance

8.2 No Passport Retention

The Group strictly prohibits the retention, confiscation, or unauthorised possession of any employee’s passport, identity card, or travel document. This prohibition applies to the Group itself and to all contractors and agencies supplying workers to the Group. Any staff member who retains an employee’s document without that employee’s freely given written consent for temporary safekeeping commits a disciplinary offence and may be personally liable under the Passport Act 1966.

8.3 No Recruitment Fees

The Group will not charge and will not permit any recruitment agency acting on its behalf to charge recruitment fees to prospective employees. This standard applies globally across all Group operations and all categories of worker, including migrant workers, domestic workers, and agency-supplied staff.

8.4 Fair Wages and Working Hours

All workers engaged directly by the Group shall receive at least the applicable statutory minimum wage and shall not be required to work in excess of the maximum permitted working hours under applicable law. Any authorised overtime shall be compensated at the prescribed rate. The Group shall maintain transparent and accurate payroll records accessible to relevant authorities on request.

8.5 Freedom of Association

The Group respects workers’ rights to freely associate and to engage in collective bargaining to the extent permitted by applicable law, including the Trade Unions Act 1959 and Industrial Relations Act 1967 (Malaysia).

8.6 Child Labour

The Group prohibits the use of child labour in any part of its operations. The minimum working age is 18 years for any role within the Group’s direct operations. For light work in non-hazardous environments, the Group complies with the Children and Young Persons (Employment) Act 1966 (Malaysia) and the equivalent applicable law in other jurisdictions, in all cases ensuring that work does not interfere with compulsory schooling or harm the child’s development.

9. GOVERNANCE AND ACCOUNTABILITY

9.1 Policy Owner and Senior Responsibility

The Group General Counsel (“GGC”) is the Policy Owner and is responsible for:

• Developing, implementing, and reviewing this Policy.
• Overseeing the annual risk assessment and due diligence processes.
• Preparing the Annual Transparency Statement for Board approval.
• Managing any modern slavery incident, investigation, or referral to law enforcement.
• Ensuring the Policy is published and accessible on the Group’s website.

The Board of Directors has ultimate accountability for the Group’s compliance with modern slavery obligations and must approve and sign the Annual Transparency Statement as required by s.54(6) MSA 2015.

9.2 Designated Modern Slavery Contact

Each Institution shall designate a Modern Slavery Contact (who may be the institution’s Head of HR or Head of Operations) responsible for:

• Receiving and escalating reports of suspected modern slavery from staff, students, and third parties.
• Maintaining the institution-level supplier register and due diligence records.
• Delivering or coordinating delivery of mandatory modern slavery training.
• Reporting to the GGC quarterly on modern slavery risk indicators and any concerns identified.

9.3 Board Oversight

The Board shall receive an annual modern slavery governance report from the GGC covering:

36. Summary of the annual risk assessment findings and any material changes in risk profile.
37. Due diligence activities conducted during the year.
38. Any modern slavery incidents, investigations, or disclosures made.
39. Training completion rates.
40. Key performance indicators against targets (see Section 11).
41. Proposed actions and priorities for the coming year.

The Board shall review and approve the Annual Transparency Statement before publication.

10. REPORTING, WHISTLEBLOWING AND VICTIM SUPPORT

10.1 Reporting Channels

The Group encourages and expects all employees, students, contractors, and third parties to report any concern, suspicion, or knowledge of modern slavery or human trafficking immediately. Reports may be made through any of the following channels:

Channel	Contact / Method	Confidentiality
Line Manager / HR	Direct report in person or in writing to immediate line manager or institution HR department.	Treated confidentially to the extent possible; anonymity maintained where practicable.
Designated Modern Slavery Contact	Each institution has a designated contact (see s.9.2).	Treated confidentially.
Group General Counsel	Direct report by email or in person to the GGC for serious or sensitive matters.	Treated confidentially.
Anonymous Whistleblowing Channel	Available via the Group’s whistleblowing platform / hotline. Details available on each institution’s intranet and HR portal.	Anonymous; the Group will investigate all anonymous reports on a best-efforts basis.
External — Malaysia	MAPO (Council for Anti-Trafficking in Persons and Anti-Smuggling of Migrants) Hotline: 15001. Royal Malaysia Police (RMP): 999 / 03-2115 9999. Department of Labour: 1800-88-8228.	Reports direct to competent authority.
External — UK	Modern Slavery Helpline: 08000 121 700. National Crime Agency: www.nationalcrimeagency.gov.uk. Gangmasters and Labour Abuse Authority (GLAA): 0800 432 0804.	Reports direct to competent authority.

10.2 Non-Retaliation

Any employee or student who makes a good-faith report of suspected modern slavery shall be fully protected from retaliation, including victimisation, dismissal, academic penalty, demotion, or any other adverse treatment. This protection applies even if the concern proves unfounded, provided it was raised in good faith. Retaliating against a person who has raised a modern slavery concern is a disciplinary offence.

10.3 Victim-Centred Response

Where the Group identifies or suspects that a person connected to its operations is a victim of modern slavery or human trafficking, it shall:

42. Prioritise the safety, welfare, and dignity of the potential victim above all other considerations including commercial, legal, or reputational considerations.
43. Immediately refer the matter to the GGC and, if required, to the relevant competent authority (MAPO or RMP in Malaysia; NCA or GLAA in the UK) and emergency services where appropriate.
44. In Malaysia: cooperate fully with Protection Officers appointed under Part V of ATIPSOM and facilitate the victim’s access to shelter, medical care, legal assistance, and support as provided under the Act.
45. In the UK: cooperate with the National Referral Mechanism (NRM) for victim identification and support.
46. Not take any action that would obstruct a victim from accessing support, seeking legal redress, or cooperating with law enforcement.
47. Maintain strict confidentiality regarding the identity of any identified or suspected victim.

10.4 Mandatory Reporting

Employees who are aware of or reasonably suspect that a modern slavery offence has been committed have a professional obligation to report this through the channels set out in Section 10.1. Wilful failure to report a known modern slavery offence by a staff member in a supervisory position is a serious disciplinary offence and may constitute a criminal offence under applicable law.

11. TRAINING AND AWARENESS

11.1 Mandatory Training

The Group shall deliver the following mandatory modern slavery training:

Audience	Training Content	Frequency
All new staff (induction)	Introduction to modern slavery: definitions, indicators, reporting channels, Group policy and zero-tolerance commitment. Malaysian and UK legal context.	At induction; within 30 days of start date.
All existing staff	Refresher: updated law and guidance; case studies; new risk areas identified in the annual risk assessment; updated reporting procedures.	Annual.
Procurement and operations staff	Enhanced: supply chain due diligence; supplier engagement; contract provisions; audit processes; red flags in supplier relationships.	Annual + on-role appointment.
HR staff	Enhanced: recruitment safeguards; employment documentation; migrant worker rights; passport retention prohibition; recognising worker exploitation; NRM / MAPO referral procedures.	Annual + on-role appointment.
Senior management and Board	Strategic: governance obligations; s.54 MSA; ATIPSOM corporate obligations; Annual Transparency Statement; reputational and legal risk.	Biannual.
Student Welfare and Placement staff	Recognising exploitation in work placements; student rights; referral channels; victim support.	Annual.
All students (work placement cohort)	Rights awareness: minimum standards at work placement; how to report exploitation; contact for support.	Before each placement commences.

11.2 Training Records

The Group shall maintain records of all modern slavery training delivered, including the names of participants, date, content, and method of delivery. Training completion rates shall be reported annually in the Annual Transparency Statement and to the Board. The target completion rate for mandatory training is 95% of all eligible staff per calendar year.

11.3 Supplier Capacity Building

For higher-risk suppliers, the Group will offer or signpost modern slavery awareness resources and, where appropriate, engage collaboratively with suppliers to support improvement of their practices rather than immediately terminating relationships, provided the supplier demonstrates genuine commitment to improvement.

12. KEY PERFORMANCE INDICATORS AND MONITORING

12.1 KPIs

The Group shall measure and report the following key performance indicators annually in the Annual Transparency Statement:

KPI	Target	Measurement Method
% of Tier 1 suppliers completing modern slavery pre-engagement questionnaire	100% of new suppliers	Procurement records
% of higher-risk suppliers subject to annual review	100%	Supplier risk register
% of staff completing mandatory modern slavery training annually	95%	HR training records
Number of modern slavery concerns reported	Report all; trend analysis	Whistleblowing and HR records
Number of modern slavery incidents confirmed	Zero target; any confirmed incident triggers enhanced review	GGC incident log
% of employment contracts including modern slavery compliance clause	100%	Legal / HR review
% of supply contracts including mandatory anti-modern slavery provisions	100% of new and renewed contracts	Legal / procurement records
Annual Transparency Statement published on website by deadline	Yes, by 6 months after financial year end (UK MSA s.54)	GGC / Board confirmation

12.2 Continuous Improvement

The Group is committed to continuous improvement in its modern slavery response. Each Annual Transparency Statement shall include a clear comparison with the prior year’s KPIs and shall set out specific improvement targets for the coming year, consistent with the UK Home Office Guidance’s Level 1 and Level 2 disclosure framework and the expectation of progressively more sophisticated reporting over time.

13. ANNUAL TRANSPARENCY STATEMENT

13.1 Obligation and Content

The Group shall publish an Annual Transparency Statement (“ATS”) for each financial year. The ATS shall satisfy the requirements of s.54 MSA 2015 and the UK Home Office Transparency in Supply Chains Statutory Guidance (March 2025 edition and any subsequent updates), and shall follow the six recommended disclosure areas:

48. Organisation structure, business and supply chains: Description of the Group’s structure, the five Institutions, key supply chains, and the countries in which it operates.
49. Policies in relation to slavery and human trafficking: Summary of this Policy and related policies (HR, procurement, whistleblowing, equal opportunities).
50. Due diligence processes: Description of the due diligence activities conducted during the year, including supplier questionnaires, audits, and HR safeguards.
51. Risk assessment and management: Identification of the parts of the business and supply chains where there is a risk of modern slavery, and the steps taken to assess and manage that risk.
52. Effectiveness: Report against the KPIs set out in Section 12.1 of this Policy, with year-on-year comparison.
53. Training: Description of the training delivered and completion rates.

13.2 Approval and Publication

The ATS shall be:

• Approved by the Board of Directors of the relevant Group entity before publication, as required by s.54(6) MSA 2015.
• Signed by a director of the relevant Group entity.
• Published on the Group’s website in a prominent location, with a link from the homepage.
• Submitted to the UK Government Modern Slavery Statement Registry.
• Retained by the Group for a minimum of 6 years.

13.3 Timing

The ATS shall be published within six (6) months of the end of each financial year, in accordance with s.54 MSA 2015.

14. REMEDIATION

14.1 Remediation Principle

Where the Group identifies modern slavery in its own operations or supply chain, it will take prompt, meaningful, and victim-centred remediation action. Remediation is not limited to ceasing a business relationship; where appropriate, the Group will work with suppliers to remediate, recognising that abrupt disengagement may further harm workers.

14.2 Remediation Process

54. Immediate containment: suspend the relevant relationship, activity, or contract pending investigation; refer any identified victims to support authorities.
55. Investigation: conduct a root cause analysis with the involvement of relevant stakeholders including, where possible, affected workers and civil society organisations.
56. Remediation plan: where the supplier commits to remediation, agree a time-bound remediation plan with measurable milestones and independent verification.
57. Victim remedy: identify and pursue appropriate remedy for any confirmed victims, which may include back-pay of withheld wages, access to legal assistance, and facilitation of their exit from the exploitative situation.
58. Supplier outcome: terminate the relationship if the supplier fails to remediate within the agreed timeframe or if the breach is of such seriousness that remediation is not appropriate.
59. Learning and prevention: incorporate lessons learned into updated risk assessments, supplier due diligence procedures, and training.

14.3 Collaboration

The Group will collaborate with NGOs, civil society organisations, industry peers, and the relevant competent authorities in Malaysia (MAPO, Department of Labour) and the UK (GLAA, NCA) in developing effective remediation responses and sharing best practices.

15. ENFORCEMENT AND CONSEQUENCES OF BREACH

15.1 Employees and Staff

• Minor breach (e.g. failure to complete mandatory training by deadline): Written warning; completion required within 30 days.
• Moderate breach (e.g. failure to report a known concern; inadequate due diligence): Formal disciplinary action under applicable employment contract.
• Serious breach (e.g. facilitating or participating in modern slavery; knowingly engaging a supplier known to use forced labour; retaining an employee’s passport): Immediate suspension pending investigation; termination for cause; referral to law enforcement authorities in Malaysia (ATIPSOM: up to 20 years’ imprisonment and fine) and/or the UK (MSA 2015: up to life imprisonment).

15.2 Suppliers and Contractors

• Breach of supplier code of conduct or contractual anti-modern slavery obligations: Formal notice requiring cure within 30 days (minor breach) or immediate suspension (serious breach).
• Confirmed modern slavery in supplier operations: Termination of contract; referral to competent authority; blacklisting from future Group procurement.
• Failure to remediate within agreed timeframe: Termination of contract.

15.3 Group Entities (Corporate Liability)

The Group is aware of its potential corporate liability exposure under:

• ATIPSOM s.57A (proposed): failure to prepare an adequate anti-trafficking and modern slavery statement; enforcement by Minister via civil proceedings in the High Court.
• MSA s.54: failure to publish an Annual Transparency Statement; Secretary of State may seek injunction; breach of injunction is contempt of court subject to unlimited fine.
• Proceeds of Crime Act 2002 (UK): supply chain criminal liability where the Group benefits from goods or services produced through forced labour.
• Reputational and commercial consequences: loss of accreditation, student enrolment impacts, and reputational damage.

16. POLICY REVIEW AND AMENDMENT

This Policy shall be reviewed annually by the GGC in consultation with senior management and the Board. An extraordinary review shall be conducted immediately upon:

• Any material change in Malaysian or UK law, including implementation of the proposed ATIPSOM s.57A reporting obligations or any reform to s.54 MSA 2015 following the House of Lords Select Committee recommendations (October 2024).
• Any confirmed modern slavery incident within the Group or a direct supplier.
• Material updates to the UK Home Office Transparency in Supply Chains Statutory Guidance.
• Publication of significant guidance by MAPO, the ILO, or other competent international body.

Material amendments to this Policy require Board approval. Minor amendments (clarificatory and operational) may be made by the GGC. All amendments shall be versioned and dated. Prior versions shall be retained for a minimum of 6 years.

17. RELATED DOCUMENTS AND POLICIES

Document	Purpose
BAC Education Group Supplier Code of Conduct	Sets minimum standards for all suppliers, contractors, and agencies.
BAC Education Group Whistleblowing Policy	Governs the reporting and investigation of concerns, including modern slavery.
BAC Education Group HR Recruitment Policy	Governs fair recruitment and prohibition on recruitment fees.
BAC Education Group Equal Opportunities Policy	Prohibits discrimination and supports worker dignity.
BAC Education Group AI Policy Framework (BAC-EG-AI-POLICY-FRAMEWORK-V1.0)	Governs AI use in Group operations, including HR processes.
Annual Transparency Statement (published annually)	Satisfies s.54 MSA 2015 and anticipated ATIPSOM s.57A obligations; sets out annual performance against this Policy.
Modern Slavery Risk Register	Maintained by GGC; updated annually; records identified risks and mitigation measures.
Supplier Modern Slavery Pre-Engagement Questionnaire	Due diligence tool for new supplier onboarding.
Student Work Placement Agreement (standard form)	Includes modern slavery compliance clause binding on host employers.

SIGN-OFF AND BOARD APPROVAL

This Modern Anti-Slavery and Human Trafficking Policy was reviewed, approved and adopted by the Board of Directors of BAC Education Group as well as all related Public Higher Education Institution (PHEI) and shall be open for review on 1 July 2027

BAC Education Group • Modern Slavery and Human Trafficking Policy • Version 1.0 • Effective 1 July 2025 • Public Document