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.

These policies are informed by our global contractual commitments and our internal mission to provide high-quality language education to our partners & learners.

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1. Code of Business Conduct and Ethics

1.1 Integrity and Anti-Corruption

Inkstone and its companies The English Farm and Kōrero.Online operate with zero tolerance for extortion, bribery, and all illegal or unethical practices. We are committed to conducting business with the highest level of integrity.

• Prohibited Payments: We strictly prohibit the offering, promising, authorizing, or giving of anything of value (including bribes, kickbacks, or inappropriate gifts) to any public officials, client employees, or third parties to obtain or retain business or any improper advantage.

• Business Partner Code of Conduct: We stay updated with our partners' specific Codes of Conduct and ensure all relevant staff are trained on these ethical requirements.

• Financial Integrity: All transactions must be accurately and transparently reflected in our accounting books and records in a timely manner. We maintain internal controls to ensure that no "off-book" accounts or slush funds are established or maintained.

1.2 Sanctions and Anti-Social Forces

• Trade Sanctions: Inkstone and its companies The English Farm and Kōrero.Online conduct regular verification to ensure that the organization, its officers, and its entities are not listed on any US, EU, or Japan trade sanction lists.

• Anti-Social Forces: We maintain a strict policy against any ties to organized crime. We perform annual screenings of our officers and key personnel to ensure no affiliation with "Anti-Social Forces" or similar criminal organizations.

1.3 Conflicts of Interest

All employees and contractors are required to avoid situations where their personal interests may conflict, or appear to conflict, with their professional duties.

• Disclosure: Staff must promptly disclose any actual or perceived conflicts of interest to management.

• Gifts and Hospitality: Staff may not accept gifts, favors, or hospitality from clients or suppliers that could influence their professional judgment.

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

2.1 Non-Discrimination Statement

Inkstone and its companies The English Farm and Kōrero.Online are a global community. We do not unlawfully discriminate against individuals based on disability, race, color, religion, marital status, sexual orientation, gender identity, pregnancy, political affiliations, age, sex, ethnic or national origin, or ethical belief.

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

• Pedagogical Competence: We reject the discriminatory belief that a "native speaker" is inherently a better teacher. Our recruitment focuses on pedagogical skill and linguistic awareness.

• Linguistic Authority: We acknowledge the linguistic authority of English speakers in global hubs such as Singapore, Manila, and Delhi.

2.3 Diversity in the Supply Chain

Inkstone and its companies The English Farm and Kōrero.Online actively encourage diversity within their own supply chains. We prioritize engagement with small businesses, indigenous-owned businesses, and women-owned enterprises whenever practicable. For the purposes of this policy, indigenous-owned and women-owned enterprises are defined as entities with at least 50% ownership and control by one or more indigenous persons or women, respectively.

3. Information Security & Data Privacy Policy

3.1 Data Protection Strategy

We implement a multi-layered security strategy aligned with international standards (e.g., NIST, ISO 27001).

• Encryption: Sensitive data is protected using high-level encryption—minimum 128-bit symmetric or 2048-bit asymmetric encryption.

• Audit and Testing: We perform annual vulnerability and penetration testing of our IT systems to ensure the ongoing integrity of our digital infrastructure.

3.2 Endpoint and Infrastructure Security

• Managed Devices: Storage of client data on personal, unmanaged devices is prohibited. Access is restricted to authorized, company-managed devices with strict security configurations.

• Principle of Least Privilege: Access to information is granted only to personnel who require it for their specific duties.

3.3 Incident Response and Breach Notification

• 24-Hour Notification: In the event of a confirmed or suspected data breach involving client information, we will notify the affected client(s) within 24 hours of discovery.

4. Labor, Human Rights, and Records Management

4.1 Fair Labor & Human Rights

• Working Conditions: We guarantee safe, hygienic, and inclusive working conditions.

• Modern Slavery: We have zero tolerance for forced labor or human trafficking.

• Insurance: We maintain and renew all required professional indemnity, public liability, and cyber insurance certificates in accordance with global enterprise standards.

4.2 Records Management and Retention

• Retention Period: All contract-related records—including financial records, lesson logs, and official correspondence—are retained for a minimum of 7 years following the conclusion of a partnership.

5. Operational Processes

5.1 Audit Readiness

Inkstone and its companies The English Farm and Kōrero.Online maintain a state of "audit readiness" and will provide documented evidence of compliance with our security and ethical policies upon reasonable request.

5.2 Sub-contractor Governance

No core services are sub-contracted without prior written client consent. Approved sub-contractors undergo a rigorous security and ethics assessment.

5.3 Secure Decommissioning

Upon termination of a client engagement, all client-proprietary data is either returned or securely destroyed (including all backup copies) using industry-standard digital shredding techniques.

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Last Updated: April, 2026