September 25, 2018

To whom it concerns,

I am pleased to confirm that E and A Language Services Cursos de Idiomas Ltda. reaffirms its support of the Ten Principles of the United Nations
Global Compact in the areas of Human Rights, Labor, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the
Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing
this information with our stakeholders using our primary channels of communication.

Sincerely,

Anthony Oladipo
Executive Director

In reference to Human Rights, E and A Language Services is committed to providing a workplace free from discrimination of any kind, sexual harassment and bullying.
Behavior that constitutes discrimination, sexual harassment or bullying is not be tolerated and will lead to action being taken, which may include dismissal.

Our Employee Manual has been revised since our Global Compact membership to reflect our conviction for all Human Rights. Additionally, all new employees have been trained on unacceptable behavior.

As it relates to Human Rights policies, listed below is a guideline from our Employee Manual;

EQUAL EMPLOYMENT OPPORTUNITY & ANTI BULLYING

Policy

This policy applies to all staff including contractors and covers all work-related functions and activities including external training courses sponsored by E and A Language Services (E and A Idiomas). It also applies for all recruitment, selection and promotion decisions.

The objective of E and A Language Services Equal Opportunity Policy is to improve business success by:

1. Attracting and retaining the best possible employees
2. Providing a safe, respectful and flexible work environment
3. Delivering our services in a safe, respectful and reasonably flexible way

Discrimination, Sexual Harassment and Bullying

E and A Language Services (E and A Idiomas) is committed to respecting Human Rights and providing a workplace free from discrimination, sexual harassment and bullying. Behavior that constitutes discrimination, sexual harassment or bullying will not be tolerated and will lead to action being taken, which may include dismissal.

For the purposes of this policy, the following definitions apply:
1. Direct discrimination occurs when someone is treated unfavorably because of a personal characteristic that is protected under Brazilian law.
2. Indirect Discrimination occurs when a rule seems neutral, but has a discriminatory impact on certain people.
3. Sexual harassment includes unwelcome conduct of a sexual nature in circumstances in which it could reasonably be expected to make a person feel offended,
humiliated or intimidated, having regard to all the circumstances, would have anticipated that the person harassed would be offended, humiliated or intimidated.
4. Harassment is extended beyond direct action made toward an individual but includes conversation deemed inappropriate by the listener.
5. Workplace bullying may include behavior that is directed toward an employee, or group of employees, that creates a risk to health and safety e.g. physical and/or
verbal abuse, excluding or isolating individuals; or giving impossible tasks.

E and A Language Services (E and A Idiomas) provides equal opportunity in employment to people without discrimination based on a personal characteristic protected under state and federal equal opportunity legislation.

They include:
• age
• disability
• employment activity
• gender identity
• lawful sexual activity
• marital status
• parental status
• personal association with someone having any of these characteristics
• physical features
• political activity/belief
• pregnancy
• race
• religious activity/belief
• sex – gender based
• sexual orientation

Any employee found to have contravened this policy will be subject to disciplinary action, which may include dismissal as outlined in the complaint procedure below.
Employees must report any behavior that constitutes sexual harassment, bullying or discrimination to their manager.
Employees will not be victimized or treated unfairly for raising an issue or making a complaint.

The company has implemented a strategy for addressing such behavior that is in contradiction to our respect for Human Rights in the follow ways;

1. The implementation of conducting quarterly performance reviews and use this opportunity to discuss and monitor said topics.
2. The creation of an Annual Workshop to inform and train the staff of "What are Human Rights Violations and How to Avoid".

E and A Language Services has implemented a system for Reasonable Adjustments as they relate to Labor.

Reasonable adjustments are changes that allow people with a disability to work productively.
E and A Language Services will make reasonable adjustments for a person with a disability who:
1. Applies for a job
2. Is offered employment
3. Is an employee, and requires the adjustments to participate in the recruitment process or perform the genuine and reasonable requirements of the job.

Examples of reasonable adjustments include:
1. Reviewing and, if necessary, adjusting the performance requirements of the job
2. Arranging flexibility in work hours
3. Approving more regular breaks for people with chronic pain or fatigue

Additionally, the company will ensure that no employee will be required additional hours unless said employee has agreed to perform such tasks and to be financially compensated. The employee will also be paid transportation expenses while performing these tasks.

E and A Language Services has taken the following action;
1. Ensure that the company does not participate in any form of forced or bonded labor.
2. Comply with minimum wage standards and fare compensation.
3. Implemented quarterly reviews which includes merit increases for all qualifying employees.
4. Ensure that employment-related decisions are based on relevant and objective criteria.

Since becoming a member of UN Global Compact, E and A Language Services has researched many ways to enhance the working experience for all of our employees by attempting to increase employee loyalty ad commitment. We feel that we should demonstrate a commitment to our staff by creating the "Good Jobs Scorecard".

What this has done is to view our employees as our customers. To do this, we asked several tough questions and aggressively answered/dealt with them to ensure that we truly are representative of The UN Global Compacts commitment to Human and Labor Rights. Additionally, we looked at four key components and asked the following;

1. Pay & Benefits
a. Are we creating value for your employees?
b. Is the pay decent?
c. Is the pay fare?
d. Is it favorable compared to the work that others do?

2. Schedules
a. Are the employee schedules predictable?
b. Do they allow the employee opportunity to live their life outside work?

3. Career Path
a. Are there opportunities for the employee to move to a higher paying position?
b. Does the company provide training to enhance employee careers?

4. Security & Safety
a. Safe psychologically?
b. Is it safe physically?
c. If an employee does their job well, will they be recognized and keep their job?

We have successfully implemented this strategy with the purpose of retaining each employee and to adhere to The UN Global Compacts commitment to supporting and respecting the protection of human rights and to make sure that we are not complicit in human rights abuses.

E and A Language recognizes the risks to our present environment and to the ecosystem. For this reason, have committed ourselves to the use of excess printing and and began the use of recycling bins. Our intention is to create new initiatives toward playing a larger role in being environmentally responsible.

1. Ensure the continued use of recycling bins.
2. Ensure safe disposal of batteries and printing cartridges.
3. Reduction of printing and use of photocopier.

Creation of recycle bins and elimination of photocopier.
Cleaning personal checks each trash can to ensure that trash is sorted properly.

E and A Language Services has a zero-tolerance for accepting payment for favors, and firmly stands against any form of bribery, corruption, and extortion.
Each staff member is strictly forbidden from accepting gifts that exceed R$ 100,00 from the clients.
Our Employee Manual clearly defines what action should be taken if they are presented with the presence of a quid pro quo offer from anyone.

At E and A Language Services, when raced with the situation where we are asked to falsely create a receipt that benefits a customer, we immediately refuse to work with said prospective customer. As it is written in our Employee Manual, such behavior is forbidden and when it occurs, it is to be reported immediately to either the Commercial Director, Operations Director, or Executive Director.

Additionally, we will not offer service to a potential customer unless it has been approved.

We have implemented a strategy where all sales and customer activity is reviewed by the Executive Director and his Committee.
A weekly scheduled Committee Meeting occurs to discuss all activity in the company pertaining to sales, financial, client visits, request for service, and client entertainment.