This document outlines the professional standards, security protocols, and social responsibilities of Inkstone Limited and its subsidiaries—The English Farm & Kōrero.Online. These policies are informed by our contractual commitments to global partners and our internal mission to provide high-quality, ethical English education with purpose.

1. Code of Business Conduct and Ethics

1.1 Integrity and Compliance

Inkstone Limited and its subsidiaries operate with zero tolerance for extortion, bribery, and all illegal or unethical practices. We comply with all applicable laws and regulations in the jurisdictions where we operate, including anti-corruption legislation such as the New Zealand Secret Commissions Act, the US Foreign Corrupt Practices Act (FCPA), and the UK Bribery Act.

1.2 Conflicts of Interest

Employees and contractors must avoid any interest or association that interferes, or appears to interfere, with their independent exercise of judgment in the best interests of Inkstone or its clients.

1.3 Professionalism

All staff members are expected to conduct themselves with the highest level of professionalism, maintaining the reputation of Inkstone, its subsidiaries and its corporate clients (MBB firms & Fortune Global 500 companies) at all times.

2. Diversity, Equity, and Inclusion (DEI) Policy

2.1 Non-Discrimination Statement

Inkstone Limited and its subsidiaries do not unlawfully discriminate against individuals based on disability, race, color, religion, marital status, sexual orientation, pregnancy, political affiliations, age, sex, ethnic or national origin, or ethical belief.

2.2 Rejection of "Native-Speakerism" and "Inner Circle" Bias

A core pillar of our hiring philosophy is the rejection of "native-speakerism"—the prejudiced belief that native speakers are inherently superior teachers.

• Beyond the Inner Circle: While recruitment has traditionally favored the "Inner Circle" (Kachru, 1985)—including the US, UK, Canada, Australia, and New Zealand—we recognize this model is now widely regarded as static and outdated. We reject the notion that a passport from these nations serves as a proxy for teaching competence.

• Transnational English: English now circulates and spreads transnationally and digitally. We acknowledge that many individuals in locations such as Manila, Singapore, and Delhi identify as first-language speakers of English.

• Modern Pedagogical Frameworks: Instead of adhering to a narrow "Standard English" (American or British) ideal, we embrace the frameworks of English as a Lingua Franca (ELF) and World Englishes. Furthermore, we encourage Translanguaging as a valuable pedagogical tool to support our global student body.

• Merit-Based Hiring: We hire teachers based on their pedagogical abilities, professional qualifications, language proficiency, and cultural competency, regardless of their country of origin.

• Analytical Advantage: We value the diverse perspectives of our teachers, recognizing that those from varied linguistic backgrounds often possess a unique, analytical understanding of English that is highly beneficial to students.

2.3 Inclusive Learning Environment

We are committed to providing an inclusive environment for both staff and students, where human rights (as defined by the UN Universal Declaration of Human Rights) are respected. We do not tolerate violence, intimidation, verbal abuse, or harassment.

3. Information Security Policy

3.1 Data Protection (GDPR Compliance)

In accordance with our agreements and the EU/UK GDPR, we implement strict technical and organizational measures to protect Personal Information. This includes encrypting data at rest and in transit using industry-standard cryptography.

3.2 Access Control and Monitoring

• Principle of Least Privilege: Access to client data (e.g., student names, email addresses, progress reports) is restricted to authorized personnel who require it for the performance of their duties.

• Device Security: All workstations and portable devices used to access client data must be encrypted and protected by anti-malware software. "Jailbroken" or "rooted" devices are strictly prohibited for business use.

• Password Policy: We enforce robust password requirements aligned with industry standards (NIST/CIS).

3.3 Incident Response

In the event of a suspected Security Incident or Privacy Breach, Inkstone Limited and its subsidiaries will:

1. Immediately investigate the cause and scope.

2. Notify affected corporate clients as soon as reasonably practicable.

3. Take all necessary steps to mitigate damage and prevent recurrence.

3.4 Asset Management

We maintain an inventory of all media and equipment where client data is stored. Before disposal or reuse, all storage media are securely wiped using industry-standard overwriting procedures.

4. Social Media and Communication Policy

4.1 Prohibited Content

Staff are prohibited from posting content on social media that:

• Is abusive, threatening, or contains offensive communication regarding ethnicity, religion, gender, or orientation.

• Damages the reputation of Inkstone Limited, its subsidiaries, its corporate clients, or individual students & staff.

• Violates confidentiality or Intellectual Property Rights.

4.2 Professional Boundaries

Teachers must maintain professional boundaries on all communication platforms, ensuring that all interactions are focused on the pedagogical goals of the Lesson Services.

5. Environmental and Labour Standards

5.1 Fair Labour Practices

We comply with New Zealand labour laws regarding wages, sick leave, and holiday pay. We respect the legal rights of employees to join or leave trade unions and do not require overtime except in exceptional circumstances and with explicit consent.

5.2 Environmental Responsibility

As an online service provider, we strive to minimize our carbon footprint by utilizing paperless workflows and encouraging remote work. We implement appropriate waste management and recycling practices within our administrative offices.

6. Supplier and Subcontractor Governance

Inkstone Limited and its subsidiaries ensure that any third-party providers or subcontractors we engage adhere to security and ethical standards consistent with these policies. We participate in the due diligence processes of our clients and maintain transparent books and records.

 

Last Updated: April, 2026