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Approved and effective — 1 August 2026

UNILINK Education

Responsible business, stated at the size we actually are

UNILINK's standing environmental, social and governance framework for its professional-services operations in Australia and China, with clear responsibilities, proportionate controls and evidence-based reporting.

Policy status

In force

Effective 1 August 2026

Covered entities

Two

Australia and China

Sub-agents

None

Counselling delivered directly

Independent assurance

None

No figure here is assured

Three pillars, one framework

The umbrella policy covers all three. The environmental commitments have their own page so that the detail lives in one place, and there is never a second, conflicting environmental policy to reconcile.

E

Environment

Office energy, business travel, digital and cloud services, IT equipment and waste.

The environmental commitments are the E pillar of the umbrella policy below. The detailed policy, the 2026–2028 action plan and the planned FY2026/27 emissions baseline are set out in full on the sustainability page rather than repeated here.

Read the environmental detail →
S

Social and human rights

Labour rights, modern slavery risk, student protection and service integrity.

UNILINK employs its counselling staff directly and uses no sub-agents for its core counselling and application-processing services, which keeps the service supply chain short. The voluntary statement sets out the risk assessment, current controls and areas where risk is not yet fully assessed.

Modern slavery and human rights →
G

Governance

Integrity, conflicts of interest, anti-bribery, privacy, records and responsible AI.

Accountability sits with the Director. Baining Wu is ESG Owner and retains AI accountability; Mavis Xiaomao Wang leads Australia operations and Baining Wu leads China operations.

Code of conduct →

Who the policy covers

Both entities are named, registered and checkable. “Covered entities” is an operational description: it does not, by itself, assert a parent, subsidiary or ownership relationship between them.

UNILINK EDUCATION PTY. LTD.

ABN 50 152 187 650 · Australia

Operations in Australia

盘否教育科技(北京)有限公司

Unified Social Credit Code 91110105MA01M1Y31U · People's Republic of China

Operations in China, including nationally delivered digital services

The policy applies to directors and employees. Contractors and suppliers are expected to meet relevant provisions to the extent UNILINK can reasonably direct or influence their work.

Governance and code of conduct

What the code requires

Integrity and conflicts
Act honestly, keep accurate records, and disclose actual, potential or perceived conflicts of interest.
Bribery, fraud, gifts and sanctions
Bribery, facilitation payments, kickbacks, fraudulent documents and improper commissions are prohibited. Gifts or hospitality must not be offered or accepted where they could appear to influence a decision.
Privacy, security and records
Personal information is collected, used, shared, retained and deleted only for lawful and authorised purposes, with access limited by role.
Responsible AI
AI supports research, drafting, translation and document review; it does not remove professional accountability. Student-facing advice and significant decisions require human review, people are told when they are interacting with an AI system, and there is a route to question an AI-supported outcome.
Student protection
No guaranteed admission outcome is promised and no provider relationship is misrepresented. Identity and document-integrity controls must be lawful, explained, minimised, secured, and backed by a manual-review route.

Who is accountable

One person may hold more than one of these roles in an organisation of this size, but the assignment and duties have to be written down.

Director — Baining Wu

Approved the policy and remains accountable for it. Receives escalations, policy exceptions and corrective actions.

ESG Owner — Baining Wu

Risk register, evidence register, staff training, annual review and the public progress update.

AI Accountable Owner — Baining Wu

Material AI use cases, privacy and human-oversight controls, and the route to contest an AI-supported outcome.

Office Operations Leads

Australia — Mavis Xiaomao Wang; China — Baining Wu. Records, activity data and first-line escalation.

Voluntary statement — not a statutory statement

Modern slavery and human rights

UNILINK does not tolerate modern slavery or serious labour exploitation in its operations or supply chains, including forced labour, human trafficking, servitude, debt bondage and the worst forms of child labour. The statement below is voluntary: it has not been lodged on the Australian Government Modern Slavery Statements Register and has not been independently assured.

Supplier and contractor due diligence

Checks are proportionate to risk rather than applied uniformly to every supplier. A review may cover:

  • Business registration and identity
  • Capability and relevant qualifications
  • Labour practices and applicable labour law
  • Privacy and information-security controls
  • Further subcontracting and adverse information
  • Written labour-rights and compliance terms

A risk finding does not automatically require termination. The decision weighs severity, leverage, the impact on workers, and whether remediation is credible.

Where the risk is higher

These categories get attention first. UNILINK's own counselling and application processing are delivered by directly employed staff, with no sub-agents, which keeps the service supply chain short.

  • Labour-intensive outsourced services
  • Recruitment, cleaning and facilities services
  • Promotional merchandise
  • Electronics and hardware
  • Offshore data handling
  • Contractors with access to student information

Speaking up

Employees, contractors, suppliers, students and other stakeholders can raise an ESG, human-rights, integrity, privacy or AI-governance concern by emailing [email protected]. The policy establishes this as a confidential channel with an acknowledgement target, protection from retaliation for anyone raising a concern in good faith, and a documented assessment and corrective-action process.

Use the subject “Confidential ESG concern”. Concerns connected with goods or services provided to a client may also be raised through that client's applicable complaints and speak-up channels.

ESG action plan 2026–2028

This approved plan also serves as the modern-slavery action plan and supply-chain risk mitigation plan. Actions remain planned unless the document records that their completion evidence exists.

  1. 01

    Approval and ownership

    Effective 1 August 2026 / first 30 days

    Director approval and named owners are complete. Staff briefing and the risk and evidence registers follow within the stated implementation period.

  2. 02

    Controls in operation

    First 120 days

    Supplier due-diligence process in use for new material engagements; AI, facial-verification and online-notarisation uses reviewed against the policy; concern and corrective-action process running.

  3. 03

    Evidence and training

    FY2026/27

    Annual staff training on modern slavery and responsible business; activity data collected for the first emissions baseline; supplier and incident records maintained.

  4. 04

    First public progress update

    Proposed by 30 September 2027

    Completed actions distinguished from planned actions, material data gaps explained, and any independent assurance stated. No result will be reported as achieved before it is.

Emissions management. The emissions workstream of this plan is set out in full, with its data boundary, owners and evidence register, in the Environmental Sustainability page and its Environmental Action and Emissions Management Plan 2026–2028.

Approved documents

Read the policies and plan in full

Each document records approval by Baining Wu, Director, and an effective date of 1 August 2026.

Environmental documents

The Environmental Sustainability Policy and the Environmental Action and Emissions Management Plan 2026–2028 are published together with the emissions detail on the Environmental Sustainability page, so there is one source for the environmental position rather than two.

What we do not claim

Stating this plainly is part of the framework. A plan, a target or a certification will not be presented as an achieved result, and where data is incomplete the limitation is stated rather than filled in with a zero.

  • No carbon-neutral, net-zero or climate-positive status
  • No SBTi validation and no ISO 14001 certification
  • No completed greenhouse gas inventory and no verified carbon footprint
  • No quantitative emissions-reduction target
  • No statutory modern slavery statement lodged on the Commonwealth register
  • No independent assurance of any figure on this page