Corporate Social Responsibility Policy

Corporate Social Responsibility (CSR) Policy

Applies to: All employees, contractors, suppliers, and partners
Owner: Managing Director
Last updated: January 2025

1) Purpose

Learn Studios designs and develops digital learning that improves skills, safety and inclusion. This policy sets out how we operate responsibly—protecting people and planet, upholding ethical business practices, and contributing to our community.

2) Scope

This policy covers our offices, remote work, on-site client work, and our supply chain (including subcontractors, vendors, and hosting providers).

3) Guiding frameworks

  • ISO 26000 (Social Responsibility), UN Global Compact principles, UN SDGs (with focus on 3, 4, 5, 8, 10, 12, 13, 16).

  • Australian laws including the Privacy Act 1988 (APPs), Fair Work Act 2009, Work Health and Safety (WHS) laws, Modern Slavery Act 2018 (Cth), and applicable state anti-discrimination legislation.

  • Accessibility: WCAG 2.2 AA as our default accessibility design standard.

4) Our CSR principles

  1. Integrity & transparency – comply with the law, tell the truth, and honour commitments.

  2. Human rights & inclusion – respect the dignity of all people; design for everyone.

  3. Learner-first, safe-by-design – privacy, security and accessibility embedded from the start.

  4. Environmental stewardship – measure and reduce our footprint; prefer low-impact choices.

  5. Community value – share our skills to reduce digital inequity.

5) Commitments

A. Ethical business & governance

  • Zero tolerance for bribery, corruption, facilitation payments and conflicts of interest. Gifts/hospitality must be modest, declared, and never influence decisions.

  • Whistleblowing: confidential channels to the Managing Director (and an alternate director); no retaliation.

  • IP & copyright: use licensed materials only; clear usage rights in all client deliverables.

  • Responsible AI & content: test for bias, accuracy and harm; disclose AI use where relevant; never use AI to mislead or to replace required professional judgement.

B. People, diversity & wellbeing

  • Fair employment: comply with Fair Work, pay at or above award rates, ban forced/child labour.

  • Inclusion & equal opportunity: recruit and promote on merit; foster gender equality and cultural safety; reasonable adjustments for disability.

  • Safe work: practise WHS; risk assessments for field work/filming; psychosocial risk controls; EAP or equivalent support options.

  • Learning & development: minimum 20 hours/year of paid professional development for each employee.

C. Privacy, security & responsible tech

  • Privacy by design: collect the minimum personal data; clear lawful basis; consent where required.

  • Security: apply secure-development practices; MFA for production systems; vendor risk checks for LMS/LRS and cloud services; incident response plan; data retention & deletion schedules.

  • Standards: respect SCORM/xAPI/cmi5 while safeguarding learner data.

D. Accessibility & inclusive design (core to our work)

  • Default to WCAG 2.2 AA for all learning deliverables (captions, transcripts, keyboard access, colour contrast, alt text). Only excluded on client request.

  • Use plain English, culturally respectful imagery, and inclusive examples; test with assistive tech where feasible.

E. Environment

  • Measure: annually estimate Scope 1–2 emissions and material Scope 3 (cloud hosting, travel, hardware).

  • Reduce:

    • Prefer virtual workshops; plan travel-lite projects; economy flights when flying is essential.

    • Buy energy-efficient hardware; extend device life; certified e-waste recycling.

    • Choose cloud/hosting providers using high shares of renewable energy.

  • Targets (initial):

    • 100% renewable electricity for offices/servers where available by <year>.

    • 100% e-waste diverted from landfill.

F. Community & pro bono

  • Commit 1% of annual billable hours (team total) to pro bono/discounted learning projects for charities, schools or First Nations organisations.

  • Provide one paid Volunteer Day per employee per year.

G. Supply chain & modern slavery

  • Issue a Supplier Code of Conduct (Appendix A) to all vendors and subcontractors.

  • Conduct risk-based due diligence (Appendix B) for higher-risk categories (e.g., print merchandise, offshore dev, hardware).

  • Include contract clauses on labour standards, health & safety, environment, data protection and right to audit.

  • Work with suppliers on corrective actions; reserve the right to terminate for non-compliance.

6) Roles & responsibilities

  • Managing Director: overall accountability; approves targets; signs public statements.Maintains this policy; runs training; tracks KPIs; compiles the annual CSR report.

  • Project Leads: ensure accessibility, privacy and ethical standards in every project.

  • All staff & contractors: follow the policy; report concerns immediately.

7) Measurement & reporting

We report internally on::

  • Accessibility compliance on each project.

  • Employee training; safety incidents (incl. near misses).

  • Privacy/security incidents and remediation actions.

  • Pro bono hours delivered and community partners supported.

  • Supplier screening coverage (% of spend under Code and due diligence).

8) Training & awareness

  • CSR induction for all new starters; annual refresher covering accessibility, privacy, anti-bribery, modern slavery, and WHS.

  • Quick-reference checklists for producers/developers (accessibility, data minimisation, inclusive language).

9) Grievances & remediation

Concerns (ethical, safety, privacy, accessibility or labour) can be raised with the Managing Director. We acknowledge within 5 business days, investigate fairly, and communicate outcomes while protecting confidentiality.

10) Review

This policy is reviewed annually or when material changes occur in laws, operations, or stakeholder expectations.

Appendix A – Supplier Code of Conduct (summary)

Suppliers must:

  • Prohibit forced, bonded or child labour; ensure freely chosen employment and lawful working hours/pay.

  • Provide a safe and healthy workplace; prevent harassment and discrimination.

  • Respect freedom of association and collective bargaining.

  • Protect personal data and confidential information.

  • Avoid bribery and corruption; declare conflicts of interest; keep accurate records.

  • Minimise environmental impacts; manage e-waste responsibly; comply with hazardous-substance rules.

  • Support accessibility and inclusive design for digital deliverables.

  • Cascade these standards to their own suppliers and allow Learn Studios reasonable assurance activities.

Appendix B – Supplier Due Diligence (quick questionnaire)

  1. Country of operation and any use of subcontractors?

  2. Policies covering labour standards, anti-bribery, privacy/security, environment (attach).

  3. Evidence of worker age verification and right-to-work checks.

  4. Health & safety management system (incidents in past 12 months).

  5. Data protection controls if handling learner or client data (encryption, access control, breach processes).

  6. Environmental practices (energy, e-waste, certifications, renewable usage).

  7. Accessibility capability for digital content (WCAG conformance).

  8. Any breaches, fines, or investigations in the past 3 years?

  9. Contact for grievances/whistleblowing.