Modern Slavery Statement

This statement is made by Turnitin, LLC for the 2024 fiscal year, ending on 31st December 2024.

Our Organization

Turnitin, LLC (Turnitin) and its associated group companies set the benchmark for online academic integrity and assessment services worldwide. Serving more than 21,000 customers globally, our mission is to ensure the integrity of global education and meaningfully improve learning outcomes.

This statement is written to cover the operations of Turnitin and its group companies, which as of May 2024 include ExamSoft, UniCheck, ProctorExam, PlagScan and Ouriginal. References in this statement to Turnitin are references to the whole group.

We pride ourselves in respecting the individual no matter what gender, race, religion, or orientation. We are committed to doing business in an ethical way, with honesty, integrity and humanity, and we expect the same from our suppliers and their supply chains.

At Turnitin we take our social responsibility extremely seriously. Our Code of Conduct, which was released in 2021, recognizes our commitment to obeying the laws and our ethical standards, in all areas in all countries in which we operate.

Our Policies and Training

In addition to the Code of Conduct, Turnitin has issued policies and procedures reflecting our zero-tolerance approach to bribery and corruption in our operations and supply chain. We also strengthened our third-party due diligence practices. We continue to refine these policies and practices to ensure that third parties we work with act in accordance with our business and ethical standards and to incorporate our zero-tolerance approach to modern slavery and human trafficking. We will take seriously any allegations that human rights are not properly respected by anyone working with or for us. We have trained our staff on these important issues and the principles espoused in our Code of Conduct.

Risk Assessment & Management

We have assessed the main areas of risk within our business and supply chain; the results of this assessment are summarized below:

Personnel

Turnitin has employees based in all regions in the world. The majority of our workforce performs professional, white-collar work and we comply with applicable local legislation and requirements governing our employment and contractual relationships, including laws governing wages and working conditions. Turnitin offers salaries, benefits and compensation that meet or exceed regulatory requirements in the relevant jurisdictions. Additionally, our policies and procedures, including those incorporating our strong stance against modern slavery and human trafficking, will apply to all employees globally, and employees will receive appropriate training regarding our ethical standards. As a result, Turnitin believes that the risk of modern slavery occurring within its staff base is very low.

Supply Chains

Turnitin’s software services are almost exclusively generated in-house by its team members and to the extent that we have a ‘supply chain’ it is minimal as very few materials or services are procured. The small number of suppliers that we do have provide only software services, are primarily based in Europe and North America, and do not present a meaningful modern slavery risk. However, as part of the continued refinement of our third-party diligence process we conduct risk assessments to identify whether there are undiscovered direct or indirect risks in our supply chain.

Our Approach

As noted above, our Code of Conduct was put in place in 2021, and we believe this helps to reduce the risk of modern slavery in our business and supply chain. Training on the Code of Conduct and related issues was provided in 2021 for those employed at the time; for those who joined the Company after the initial launch, completion of training on the Code of Conduct is a mandatory requirement. We will be providing updated training on the Code of Conduct when we issue an updated Code of Conduct. Once available, this updated training will be provided to new employees upon joinder.

Key Performance Indicators

Turnitin is developing ways to assess the effectiveness of the steps it has taken to combat modern slavery. These are likely to include a review of existing suppliers to determine those which present the greatest risk of modern slavery whether because of the jurisdiction in which they are based or the services that they provide.

Approval

This statement has been approved by the Turnitin Board of Directors, as of May 28, 2024. This statement and Turnitin’s approach to Modern Slavery issues and laws will be reviewed periodically.

The Board of Directors