Modern Slavery Act Transparency Statement

The Modern Slavery Act 2015 came into effect in October 2015. Every organisation carrying on a business in the UK with a total annual turnover of £36m or more is required to produce a slavery and human trafficking statement for each financial year of the organisation. This law is designed to increase the amount of information made available by manufacturers and retailers on their efforts to eliminate slavery and human trafficking in its supply chains, allowing customers to make more informed choices regarding the products they buy and the companies they choose to support.

This statement is made on behalf of VitalSource Technologies Ltd. and its U.S. counterpart, VitalSource Technologies, LLC ("VST"). VST believe that workers should have the right to freely choose where they work and be treated with dignity and respect. We are committed to upholding human and labour rights by ensuring that every worker has safe and fair working conditions.

Our organizational structure and our business

VST is a global leader in building, enhancing, and delivering e-learning content. We provide proprietary online and native platforms that enable the creation, management and delivery of various form of digital content in the education and corporate training marketplace.

Our UK company, VitalSource Technologies Ltd, is wholly owned by VitalSource Technologies, Inc.. Both form part of the Ingram group of companies.

Our staff

We strive to ensure a fair and ethical workplace for all our staff. We prohibit the use of all forms of forced labour and any form of human trafficking.

We ensure compliance with all applicable employment legislation relating to employee recruitment and terms and conditions, including right to work evidence and that no UK staff in the UK offices are paid less than the living wage. Our employees may terminate employment by giving the required contractual notice.

Our supply chains

VST does not produce, source, or sell any manufactured articles or products. Our suppliers are generally publishers converting print texts to digital media. The nature of the business and the way in which we contract with our suppliers means that we are confident that VST fully complies with the law. We do still remain vigilant and monitor the level of risk involved throughout our supply chain.

Our policies in relation to slavery and human trafficking

VST has adopted a Code of Ethics which applies throughout the organization. This sets out our commitment to maintaining the trust of our associates, customers, and the communities in which we work by strongly supporting an open and honest culture where our business practices are above reproach.

The Code sets out VST's commitment to strictly complying with each and every law, rule or regulation governing its business and implores all associates of the business to be responsible for understanding the legal and regulatory environment which affects their work. It also provides a route through which concerns can be raised through official channels.

Particularly the Code sets out VST's standards for dealings with suppliers and customers, and clearly and expressly sets out that any form of human trafficking or any other form of forced, prison, bonded or any other involuntary labour will not be tolerated.

Due diligence

We expect all our contractors, suppliers and other business partners to uphold the same high standards as we do, by ensuring all employees and workers are treated with dignity and respect in a fair and ethical environment.

We work to identify, assess, and monitor any potential areas of risk in relation to our business and supply chains. This includes considering the length of the relationship, nature of what is being supplied and the location from where it is being supplied. We will continue to look to manage any risks identified.

Training

It is important to us that our employees are aware of the issues surrounding modern slavery and support our values. Our legal and compliance team is aware of and trained in the requirements of the Modern Slavery Act.

Looking ahead

We will continue to monitor and develop our practices in respect of combatting slavery or human trafficking to target areas of our business if we become aware there is a potential risk of modern slavery. Our legal function is responsible for checking and testing the success of our commitments, and will work to ensure we meet our expectations.

This statement is given on behalf of the VST for the financial year ending 31 December 2016. It sets out the steps taken during the financial year to prevent modern slavery and human trafficking in our business and supply chains.

[This statement has been signed by the sole member of VitalSource Technologies LLC and a copy of the signed statement is available upon request.]