Terms of service - website usage

Terms

By accessing this website, you are agreeing to be bound by these web site Terms and Conditions of Use, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this web site are protected by applicable copyright and trademark law.

Use License

1. Permission is granted to temporarily download one copy of the materials (information or software) on CoGrammar's website for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not:
   1. modify or copy the materials;
   2. use the materials for any commercial purpose, or for any public display (commercial or non-commercial);
   3. attempt to decompile or reverse engineer any software contained on CoGrammar's website;
   4. remove any copyright or other proprietary notations from the materials; or
   5. transfer the materials to another person or "mirror" the materials on any other server.
2. This license shall automatically terminate if you violate any of these restrictions and may be terminated by CoGrammar at any time. Upon termination of your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format. Failing which, you will be held personally liable.

Disclaimer

The materials on CoGrammar's website are provided "as is". CoGrammar makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties, including without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. Further, CoGrammar does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its Internet web site or otherwise relating to such materials or on any sites linked to this site.

Limitations

In no event shall CoGrammar or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption) arising out of the use or inability to use the materials on CoGrammar's Internet site, even if CoGrammar or a CoGrammar authorized representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.

Links

CoGrammar has not reviewed all of the sites linked to its Internet web site and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by CoGrammar of the site. Use of any such linked web site is at the user's own risk.

Site terms of use modifications

CoGrammar may revise these terms of use for its web site at any time without notice. By using this web site you are agreeing to be bound by the then current version of these Terms and Conditions of Use.

Governing law

Any claim relating to CoGrammar's website shall be governed by the laws of the Republic of South Africa without regard to its conflict of law provisions.

Site terms of use - termination

Interactions to be conducted by users of this any sites within the CoGrammar domain/ownership and its subsidiaries are to follow bone fide practices. Users who:

• Provide misinformation
• Provide fraudulent identification
• Attempt unauthorized access to any part of the website and course systems
• Conduct any criminal activity or malicious behaviours

Will have any and all services provided by CoGrammar and its subsidiaries terminated with the user immediately and indefinitely.

Safeguarding, Disability and Prevent Policy

Introduction

HyperionDev aims to create and sustain a learning environment that is safe and inclusive, enabling Students to benefit optimally from their learning experience, and adopts this Safeguarding and Disability Policy.

Purpose

HyperionDev acknowledges its social, moral and legal obligations towards its students, adults at risk, and the disabled.

This policy recognises and gives effect to HyperionDev’s obligation to safeguard the wellbeing and safety of its students, with a specific emphasis on adults at risk. It also gives effect to the rights of disabled persons who seek to participate in activities.

Scope and Application

This policy applies to HyperionDev as a whole, and all its staff, contractors, and representatives in their interactions with students, adults at risk, and disabled persons.

HyperionDev is committed to ensuring that it offers an adequately safeguarded and inclusive setting, and to ensure that it gives effect to the rights of people who use our services in environments free from discrimination, abuse, and neglect.

Definitions: Vulnerable adult and Disabled

A vulnerable adult is someone aged 18 or over who receives or may need community care services because of a disability, age or illness and as a result of those needs is unable to take care of themself or is unable to protect themself against significant harm or exploitation. This can relate to physical, mental or psychological wellbeing or the potential to be drawn into sexual, financial or criminal exploitation and activity.

An adult may become at risk during their time at HyperionDev if they:

• Have particular learning needs because of their age
• Have a disability
• Have a physical or mental health difficulty
• Are detained in custody
• Are receiving community services because of their age, health or disability
• Are living in sheltered accommodation or in a residential care home

Adults as described above may not necessarily be at risk all of the time or at all. They may be at risk when they are not able to protect themselves against significant harm or exploitation.

It may be difficult to identify an applicant’s or Learner’s vulnerability or the possibility that they may become vulnerable to risk during their studies at HyperionDev.

Adults can also be victims of physical, emotional, sexual abuse or neglect. In addition, they can be vulnerable to financial, discriminatory or institutional abuse, modern slavery and self-neglect.

Modern Slavery is when individuals are coerced, deceived or forced into a life of abuse, servitude and inhumane treatment. This can be through human trafficking, forced labour or domestic servitude.

A disabled person is someone who has a physical or mental impairment, which impairment has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities.

We have a channel, specifically for declaring and gaining support with any disabilities challenges students may have. You can seek this support and make a declaration using the HyperionDev Skills Bootcamp Disability Declaration .

Concerns, risks and responding to risk or danger

Welfare concerns include but are not limited to risk of suicide, self-harm, untreated mental health needs, going missing, domestic abuse, exploitation, serious self-neglect, risk of homelessness, or sexual abuse.

HyperionDev recognises that it has social, moral and legal obligations to safeguard the wellbeing and safety of adults at risk involved in any HyperionDev activities, whether they are conducted in person or online.

Disabled students may not be discriminated against, and must be treated fairly. This includes making reasonable adjustments to that effect.

If a student, member of staff, or member of the public is in immediate danger or at risk of harm to themselves or others call emergency services on 999. You should inform the relevant Designated Safeguarding Lead (DSL), our representative assigned to handle matters such as these promptly, as soon as possible:

Attention: Designated Safeguarding Lead safeguarding@hyperiondev.com

To record an incident via our form, you can use the HyperionDev Skills Bootcamp Safeguarding incident report or HyperionDev Skills Bootcamp Disability Declaration.

Procedure and Guidance to members in regular contact with at risk or vulnerable adults

HyperionDev recognises that it has social, moral and legal obligations to safeguard the wellbeing and safety of adults at risk involved in any HyperionDev activities, whether they are conducted in person or online.

This document provides guidance to all staff members who are in regular contact with Learners (adults undergoing online tech bootcamp courses with HyperionDev) who may be considered at risk or vulnerable.

The term “safeguarding” describes the broader preventive and precautionary approach to planning and procedures required to protect vulnerable Learners from any potential harm or damage.

Different types of Abuse

We acknowledge and inform all our staff who work with the Learners of a variety of potential abuse to which vulnerable Learners may be exposed. It is important to acknowledge that different types of abuse may be combined and that all staff must apply their best judgement when it comes to assessing the appropriateness of any intervention.

• Physical abuse – including hitting, slapping, pushing, shaking, kicking, misuse of restraint or inappropriate sanctions. This also includes female genital mutilation (FGM).
• Sexual abuse – including inappropriate touching, grooming, sexual assault, or acts to which the child or adult did not or could not consent.
• Psychological abuse – including emotional abuse, threats, deprivation of contact, mocking, humiliation, bullying, harassment, intimidation, coercion, verbal abuse, isolation, deprivation, or withdrawal of services.
• Neglect or acts of omission – including ignoring medical or physical care needs, withholding of medication or adequate nutrition and failure to provide access to appropriate health, social care, or educational services. This definition has recently been expanded to include inadequate parenting or supervision of children.
• Financial or material abuse – including unauthorised withdrawal from a vulnerable adult's account, theft, fraud (or attempted theft or fraud), exploitation and pressure in connection to wills, property, inheritance, or financial transactions.
• Discriminatory abuse – including discrimination on the grounds of race, gender, religion, age, and any other protected characteristics covered under the Equality Act 2010.
• Environmental abuse – including safeguarding against accidents, lack of supervision in the workplace or home, and also including housing/homelessness issues which can increase the risk of an unsuitable living environment.
• Self-abuse – including self-harm, wilful acts of neglect upon oneself, risk of serious injury or suicide.
• Immigration related problems – including exploitation of individuals due to immigration status, forced marriage.
• Radicalisation – including exploitation of individuals to become involved in or to carry out an act of terrorism and where appropriate to play our part in the rehabilitation of individuals wanting to integrate back into society and remove themselves from terrorist behaviours and activities.

Safeguarding Roles and Responsibilities

The Designated Safeguarding Lead is responsible for:

• Leading a once-every-two-week Safeguarding internal call to review reports raised under the safeguarding policy and to manage the process of regularly check ins and additional support of vulnerable adults engaged in our training
• Arranging training for relevant staff interacting with vulnerable adults
• Reporting to and supporting the Operations function about safeguarding matters
• Monitoring, promoting and reviewing the policy, guidance documents and resources
• Ensuring the dissemination of the policy to all HyperionDev staff through forums, committees and stakeholder meetings
• Acting as the first point of contact for safeguarding concerns and providing support
• Reporting to the LADO (Local Authority Designated Officer) and seeking advice in situations where a safeguarding allegation is made against a member of staff
• Providing support to, and dealing with any queries from, students or members of staff who have been accused of misconduct related to a safeguarding issue
• Keeping records of all safeguarding referrals and outcomes

All staff who work with Learners in any capacity are responsible for:

• Being aware of the safeguarding policies pertinent to their role
• Reporting safeguarding concerns to the Designated Safeguarding Lead
• Completing HyperionDev’s safeguarding training
• Understanding PREVENT & British values

Measures in place

Through tailored student support services via our online platform and dedicated student support team, HyperionDev aims to provide effective support to any student who may be experiencing emotional and psychological problems.

Any students who declare that they are a vulnerable adult, or experience any learning challenges, relating to disabilities will receive the necessary support structure, consisting of an additional series of check-ins with these students during their learning, implemented via our Student Success team and a subset of our Student Progression Associates that are trained to work with vulnerable students. To report back on the additional support, plus any safeguarding issues raised by anyone on our team, the DSL also runs a once every two week internal safeguarding meeting to review such cases and log them in a once every two week written report.

HyperionDev aims to support students who have longer term mental health conditions, physical disabilities and/or learning difficulties and are able to make reasonable adjustments for these students to ensure they can study as independently as possible during their time at our bootcamps. Such additional support includes tailored mentoring, and other specialist help, as needed.

In respect of students with disabilities, we have a channel, specifically for declaring and gaining support with any disabilities challenges students may have. You can seek this support and make a declaration using the HyperionDev Skills Bootcamp Disability Declaration.

Learners may talk to any member of the Safeguarding committee about the support we offer. Admission to any HyperionDev educational opportunity is determined on the basis of the learner meeting the standard minimum enrolment and admissions criteria alone, and we practise nondiscrimination.

We specifically acknowledge that adjustments may be required by students with both neurodiverse and physical abilities, and assess such requests on a case-by-case basis so as to provide individualised responses and reasonable accommodation measures.

As with vulnerable adults in general, disabled students who find themselves in danger or at risk of harm should contact emergency services on 999(UK), and inform the relevant Designated Safeguarding Lead (DSL) or deputy as soon as possible.

HyperionDev acknowledges that disability is a private and confidential matter, and may only be disclosed to HyperionDev where the student requires us to consider the above mentioned reasonable adjustments. Disability information will only be shared when the necessary staff members and bodies involved in arranging and executing the student’s education need it in order to make such reasonable accommodations. Where information relating to the disability needs to be shared, the student will be informed beforehand as far as it is possible.

Recognising concerns in Learners of staff members

Abuse is a form of maltreatment. Somebody may abuse or neglect a vulnerable adult by inflicting harm or by failing to act to prevent harm. Abuse may occur in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse may also take the form of self-harm. Abuse can take place wholly online, or technology may be used to facilitate offline abuse.

Abuse can take different forms and includes physical abuse, sexual abuse, emotional abuse and neglect. You may become aware of a concern through your own observations, something that someone else tells you about a person or something the person themselves tells you.

A member of staff could become an adult at risk at any time during their employment at HyperionDev. Colleagues may notice a change in appearance or behaviour, attendance or performance. Whilst these do not necessarily indicate abuse or neglect, they may indicate a cause for concern.

Staff members who are concerned about a colleague’s welfare or safety should let their colleague’s line manager know.

What to do when someone raises a concern

If someone tells you directly about a concern relating to their safety you should:

• Remain calm
• Offer reassurance that they have done the right thing in telling you
• Listen attentively and show you are taking what you are being told seriously
• If they are an adult at risk, it is good practice to gain the person’s consent to share your concern. If information has been shared with you in confidence, a safeguarding concern may mean that there is justification to share the information without consent.
• Explain to them what will happen next.

Do not:

• Interrupt or stop them from speaking freely
• React strongly, for instance saying, “That’s awful” or “How could someone do that?”
• Jump to conclusions about what happened or who is to blame
• Ask leading questions to gain more information; you can ask questions to clarify, for example “Are you telling me that…?” using their own words
• Promise confidentiality

Recording concerns

As soon as you notice or are told of a concern you must:

• Record your concern via email or by submitting a report incident form to the Designated Safeguarding Lead providing as much detail as possible
• Be precise and use their own words where possible
• You can give an opinion if it relates to their behaviour or demeanour if you note that it is your opinion
• Ensure you provide the date and time of when the concern arose for the first time
• To record an incident via our form, you can use the HyperionDev Skills Bootcamp Safeguarding incident report or HyperionDev Skills Bootcamp Disability Declaration.

You should not:

• Discuss the concern with anyone other than the Safeguarding Committee members.
• Investigate any allegations

The Designated Safeguarding Lead will let you know the next steps once you have recorded your concern.

Actions taken in the event of concerns being raised

The Designated Safeguarding Lead may decide to:

• Contact the student to offer support
• Refer the student to internal support
• Refer the student to an external support agency
• Contact the police if an emergency
• Call an ambulance if an emergency
• Contact the responsible authority within 24 hours to report the allegation
• Contact the Disclosure and Barring Service under their legal duty to refer
• Contact the professional registration body for professional misconduct

Record Keeping

HyperionDev will keep records of safeguarding concerns or allegations including details of how they were resolved, details of decisions reached and how those decisions were arrived at. These records will be kept securely for 6 years.

Confidentiality and Information Sharing

HyperionDev has a duty to share information with other agencies such as PREVENT Partners, Local Police Counterrorism Officers, Local Authority to safeguard adults at risk. HyperionDev will seek consent from the reporting child or adult at risk before sharing the safeguarding information confidentially to an authority or agency. However, information may be shared without consent if HyperionDev believes there is good reason to do so, and that the sharing of information will enhance the safeguarding of an adult at risk in a timely manner. Data protection law and regulations should not be seen as a barrier to sharing information about safeguarding.

Where HyperionDev decides to share information without consent there will be a record kept of the discussion and decision-making process to share that information.

Information should be shared on a need to know basis only, as judged by the Designated Safeguarding Lead and having taken advice from HyperionDev’s legal team.

DBS and criminal record checks

We operate strict hiring processes, which include vetting and personal identification checks for all our staff, including part-time, full-time and contract staff. All staff working with vulnerable adults are given appropriate training in relation to spotting, raising and reporting concerns.

The nature of activities provided by HyperionDev (online tech bootcamps) is such that they do not fall within the definition of the “regulated activity” as defined by the Safeguarding of Vulnerable Groups Acts 2006.

HyperionDev has procedures and systems to ensure that DBS checks, or equivalent in the relevant jurisdiction, are obtained from all relevant staff as necessary.

Prevent

The Counter-Terrorism and Security Act 2015 (CTSA) created a statutory duty for specified public authorities to 'have due regard to the need to prevent people from being drawn into terrorism', which HyperionDev recognises now applies to Skills Bootcamps providers.

Prevent is one of four strands of the government’s counter-terrorism strategy. Compliance with the duty in England is monitored by the Office for Students. HyperionDev’s approach to Prevent is primarily one of safeguarding the welfare of our Learners and staff. This is balanced against our commitment to freedom of speech and other key legislation. As part of our PREVENT duty we will continue to establish partnerships with relevant partners to facilitate to share of information such as Local Authorities, PREVENT Partners and Local Police Counterterroism Officers.

This policy and procedure is subject to The Equality Act 2010 which recognises the following categories of individual as Protected Characteristics: Age, Gender Reassignment, Marriage and Civil Partnership, Pregnancy and Maternity, Race, Religion and Belief, Sex (gender), Sexual orientation, Disability, Socio-economic Disadvantage. The term ‘student’ is used throughout the document to describe all learners, both full and part-time in all settings, including workplace learning, learners and HE learners.

This policy has been written in response to HM Government Prevent Duty Guidance for Further Education Colleges in England and Wales. This guidance was updated in July 2015 and is the subject of the duty under section 26 of the Counter-Terrorism and Security Act 2015 which applies to specified authorities including independent training providers.

Preventing the radicalisation of students is part of a Government initiative to develop a robust counter terrorism programme. The UK faces a range of terrorist threats. All the terrorist groups who pose a threat to us seek to radicalise and recruit people to their cause. The Government Prevent strategy seeks to:

• Respond to the ideological challenge of terrorism and aspects of extremism, and the threat we face from those who promote these views
• Provide practical help to prevent people from being drawn into terrorism and ensure they are given appropriate advice and support
• Work with a wide range of sectors where there are risks of radicalisation which needs to be addressed, including education, criminal justice, faith, charities, the internet and health

A system of threat level has been created which represents the likelihood of an attack in the near future. The five levels are:

• Critical - an attack is expected imminently
• Severe – an attack is highly likely
• Substantial – an attack is a strong possibility
• Moderate – an attack is possible but not likely
• Low – an attack is unlikely

Training providers cater to the over 19 year age group, which include people from ethnically diverse, and socially and economically disadvantaged areas. Training Providers have a part to play in fostering shared values and promoting cohesion. Training Providers should focus on the risks of violent extremism, which represents the greatest threat at national level, while recognising that other forms of violence and extremism can and do manifest themselves within training settings.

This strategy has six key objectives:

• To promote and reinforce shared values; to create space for free and open debate; and to listen and support the learner voice.
• To break down segregation among different student communities including by supporting interfaith and inter-cultural dialogue and understanding, and to engage all students in playing a full and active role in wider engagement in society.
• To ensure student safety and that HyperionDev is free from bullying, harassment and discrimination
• To provide support for students who may be at risk and ensure appropriate sources of advice and guidance
• To ensure that students and staff are aware of their roles and responsibilities in preventing violent extremism.
• To correctly refer and record any issues concerning staff and students.

To achieve these objectives, the strategy will concentrate on four areas:

Leadership and Values

To provide an ethos which upholds our core values of Transparency, Ambition, respectful, Guiding, Empowering, teamwork and Excellence for all students, staff and visitors and promotes equality and diversity and understanding. This will be achieved through:

• Promoting our core values
• Building staff and student understanding of the issues and confidence to deal with them
• Continuing to engage with our local communities through partnership
• Actively working with local authorities, police and other agencies

Teaching and Learning

To provide a curriculum which promotes knowledge, skills and understanding to build the resilience of students, by undermining extremist ideology and supporting the learner voice. This will be achieved through embedding equality, diversity and inclusion, wellbeing and community cohesion and British values and the understanding of the UK Government’s PREVENT strategy.

• Promoting wider skill development such as social and emotional aspects of learning
• A curriculum adapted to recognise local needs, challenge extremist narratives, and promote universal rights.
• Teaching and learning strategies which explore controversial issues in a way which promotes critical analysis and pro social values.
• Use of external programmes or groups to support learning while ensuring that the input supports HyperionDev goals and values.
• Encouraging active citizenship and learner voice.

Student Support

To ensure that staff are confident to take preventative and responsive steps working with partner professionals, families and communities. This will be achieved through:

• Establishing strong and effective student support services
• Listening to what is happening in HyperionDev and the community
• Implementing anti-bullying strategies and challenging discriminatory behaviour
• Helping students and staff know how to access support in HyperionDev and or through community partners.
• Supporting problem solving and repair of harm
• Supporting at risk students through safeguarding processes and crime prevention processes
• Focussing on narrowing the attainment gap for all students
• Ensure students are safe from terrorist and extremist material when accessing the internet. Ensuring students are taught about online safety.

Managing Risks and Responding to Events

To ensure that The HyperionDev monitors risks and is ready to deal appropriately with issues which arise. It will do this through:

• Understanding the nature of the threat from violent extremism and how this may impact directly or indirectly on HyperionDev.
• Understanding and managing potential risks within The HyperionDev and from external influences
• Responding appropriately to events in local, national or international news that may impact on students and communities
• Ensuring measures are in place to minimise the potential for acts of violent extremist within HyperionDev.
• Ensuring plans are in place to respond appropriately to a threat or incident within HyperionDev
• Developing effective ICT and e-safety policies
• Having strong relationships with Channel links, PREVENT Partners, Local Authorities and Local Police Authorities to share knowledge and information

Managing the Process

Anti-radicalisation is a category under the safeguarding policy and procedures and any concern arising under this heading should be dealt with in the same way as other safeguarding concerns. To record a concern, you can use the HyperionDev Skills Bootcamp Safeguarding incident report or HyperionDev Skills Bootcamp Disability Declaration.

References

Web Content Accessibility Guidelines:
What's The Difference Between WCAG Level A, Level AA, and Level AAA?

UK Department for Education’s Special Educational Needs and Disability guidelines for further education providers:
SEND: guide for further education providers - GOV.UK

Gov.uk Disabled Person Education Rights:
Disability rights: Education - GOV.UK

Gov.uk Safeguarding Policy: Protecting Vulnerable Adults:
Safeguarding policy: protecting vulnerable adults - GOV.UK

Prevent Duty Guidance:
https://www.gov.uk/government/publications/prevent-duty-guidance

Helplines and useful support numbers

HyperionDev around Modern Day Slavery and Human Trafficking Statement

Statement

Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 December 2023.

HyperionDev / CoGrammar ('the Company', 'we', 'us' or 'our') is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

HyperionDev policy and statement

HyperionDev is committed to working towards the eradication of slavery and human trafficking. This document acknowledges the legislation and laws implemented by the Modern Slavery Act 2015 and details the steps that the organisation is taking to work towards the provision of the Act.

We are committed to ensuring that there is no slavery or human trafficking in its organisation and supply chains. This policy reflects our commitment to acting ethically and with integrity in all business relationships and implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Organisational Structure

HyperionDev / CoGrammar has business operations in the United Kingdom in relation to the offering of fully funded Skills Bootcamps. We operate in the education sector. The nature of our supply chains is as follows: We work with a number of key direct suppliers, who provide us with goods, such as equipment for our premises, and services, such as outsourced business processes, IT software and marketing services.

With respect to social compliance, we have a code of conduct for our suppliers. We and our suppliers:

• shall not use, nor allow any Subcontractors to use forced, bonded or involuntary prison labour;
• shall not require any Supplier Personnel or the personnel of any Subcontractors to lodge deposits or identity papers with their employer and shall be free to leave their employer after reasonable notice;
• warrant and represent that it has not been convicted of any slavery or human trafficking offences anywhere around the world;
• warrant that to the best of its knowledge it is not currently under investigation, inquiry or enforcement proceedings in relation to any allegation of slavery or human trafficking offences anywhere around the world;
• shall make reasonable enquiries to ensure that its officers, employees and sub- contractors have not been convicted of slavery or human trafficking offences anywhere around the world;
• shall have and maintain throughout the Contract Period its own policies and procedures to ensure its compliance with the Modern Slavery Act 2015 and include in its contracts with its Subcontractors anti-slavery and human trafficking provisions;
• shall implement due diligence procedures to ensure that there is no slavery or human trafficking in any part of its supply chain performing obligations under the Contract;
• shall prepare and deliver to the Customer, an annual slavery and human trafficking report setting out the steps it has taken to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its business;
• shall not use, nor allow its employees or Subcontractors to use physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation of its employees or subcontractors;
• shall not use or allow child or slave labour to be used by its Subcontractors; and
• shall report the discovery or suspicion of any slavery or trafficking by it or its sub- contractors to the Customer and the Modern Slavery Helpline (modernslaveryhelpline.org).

For more information about the Company, please visit our website: https://www.hyperiondev.com/

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

• Safeguarding and Prevent policy
• HyperionDev Modern Slavery and Human Trafficking Statement
• Anti Harassment and bullying policy

Our safeguarding policy states how we actively look to protect everyone within HyperionDev and those who work with us.

We make sure our suppliers (if any) are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

• providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking
• ensuring staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK
• ensuring that consideration of the modern slavery risks and prevention are added to HyperionDev’s policy review process as an employer and procurer of goods and services
• making sure HyperionDev’s procurement strategies and contract terms and conditions include references to modern slavery and human trafficking
• continuing to take action to embed a zero tolerance policy towards modern slavery
• ensuring that staff involved in buying or procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices

Our due diligence procedures aim to:

• Identify and action potential risks in our business and supply chains.
• Monitor potential risks in our business and supply chains.
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

Risk and Compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through evaluating the slavery and human trafficking risks of each new supplier. Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chains.

Our supply chains are limited and we offer services from a restricted range of UK and overseas suppliers, mainly through UK government frameworks and the managed office spaces and universities we work in.

We do not consider that we operate in a high-risk environment because the business operates in this risk level environment because the majority of our supply chain is based in the UK and in low-risk industries, such as internet software and services.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.

Effectiveness

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

We will train our staff about modern slavery issues and increase awareness within the Company.

Training Staff

The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The company's training covers:

• How to identify the signs of slavery and human trafficking.
• What initial steps should be taken if slavery or human trafficking is suspected.

This training will be completed and refreshed annually in house.

References

DSL Training link:
E-Learning First Responder Training - NPCC Modern Slavery & Organised Immigration Crime Programme
Modern slavery training: resource page - GOV.UK
Modern slavery: how to identify and support victims - GOV.UK
Modern slavery victims: referral - GOV.UK

Our fully serviced office spaces are owned and managed by Soho House and Imperial College London. Their Modern Slavery Statements can be found below:
Modern Slavery Statement | Soho House
Statement on Modern Slavery | Administration and support services | Imperial College London

Certificated Training for Staff:
Hope for Justice Learning Academy

This statement will be reviewed and updated every year.

Student Complaints Procedure (SCP)

Introduction

This Students Complaints Procedure (SCP) describes the complaints policy for all programmes offered by HyperionDev in the United Kingdom. It seeks to ensure that student complaints are dealt with fairly and appropriately and are given careful consideration.

We regard a complaint as any expression of dissatisfaction about our action or lack of action, or the standard of service provided by us or on our behalf, via the processes set out in this document. “Complaints”, for purposes of this document, do not include any third-party complaints (cases where the dissatisfaction is caused by a party that is not HyperionDev), nor any academic complaints (dissatisfaction on marks assigned or academic progression, which is to be addressed during a 1:1 with the student’s mentor).

“Complaints,” for purposes of this document does not include complaints related to how HyperionDev stores and uses your data (which must be submitted Privacy Policy for more on how we store and use your data; also refer to the DfE’s Skills Bootcamps Privacy Notice; LRA Privacy Notice if you are on a DfE funded bootcamp).

Appeals against applications of the regulations, or decisions made by us are also considered as complaints.

Purpose

HyperionDev is dedicated to providing a high-quality student experience.However, we recognise that students may sometimes become dissatisfied. Where concerns are brought to our attention, we commit to investigating the matters raised, clarifying regulatory or procedural issues, and, where appropriate, taking the necessary steps to provide remedy and redress.

If a student wishes to make a complaint, they should follow the guidance below.

It is understood that making a complaint is a serious matter and it is treated as such by HyperionDev. All submissions under this Procedure are treated confidentially and students should be assured that raising a grievance of any kind will not negatively impact their academic progress or standing with HyperionDev.

It is our principal aim to resolve any complaint or problem quickly, fairly, and simply at the informal stage. All informal complaints will be dealt with through our Education Student Success Support team.

All complaints will be recorded on an internal database and retained for future reference.

HyperionDev’s Complaint Policy has been made to meet and comply with the DfE’s executive agency, ESFA (Education and Skills Funding Agency).

Whilst dealing with any complaints, we will comply with several of our policies, including

• Safeguarding Policy
• Data Protection and Privacy Policy
• Complaints Policy

Procedure

The following process must always be followed, to ensure complaints are dealt with in the correct way, with a swift resolution.

Step 1: Informal Resolution

When airing a complaint, the first step will entail bringing it to the attention of the HyperionDev Education Student Success Support team at www.hyperiondev.com/support. Alternatively, students may choose to make use of HyperionDev’s student surveys, circulated anonymously from time to time, to bring complaints to our attention.

If no relief follows after Informal Resolution procedures have been exhausted, the student may proceed to Formal Resolution as set out below.

Step 2: Formal Resolution: Identification & Logging

All complaints that have not been resolved via Informal Resolution, must be directed to:

• the Student Success Support team via email at complaints@hyperiondev.com and include the below details:
• Details on the complaint including how and when it arose
• Name & Surname
• Contact details
• Screenshot/All relevant details around the complaint
• Any comments or suggestions the student has on resolving the complaint

Process of formal resolution

Stage 1 - Lodge

Process
1-1	Once a complaint has been raised via the channel above, acknowledgement of the complaint will be sent to you
1-2	An investigation will take place internally, looking at factual evidence, circumstances, staff and relevant parties. We may also contact you for any clarification. A summary of the complaint and actions will be logged in a tracker.
1-3	We aim to have a resolution within 15 working days from the date the complaint is raised via our escalation channel. However, if this is not possible, we will contact you to explain the reason for the delay, and the time extension required to provide a response to the complaint.

If the complaint has been resolved, and is closed at this stage, issues identified, problems solved, and any recommended changes will be logged in a tracker. This will be submitted to HyperionDev’s SMT (Senior Management Team) via a summary of the tracker, to be discussed at the next complaints committee meeting, in order to ensure sustainable problem solving and complaint resolution, with this committee to be held at least once per quarter.

Stage 2 - Appeal

If you are unhappy with how we have dealt with your complaint, or the outcome, you can appeal by emailing the complaints@hyperiondev.com email address again, labelling your email as ‘Complaint Resolution Appeal’, and it will be referred to the below senior management team member. This must be done within 1 working day of receiving the outcome. They will use all documented actions and evidence, and aim to provide feedback within a further 10 working days.

Senior Management Team member (SMT)

Person name and email – Simone Botes - Success Lead

Process
2-1	Acknowledgement of the escalated complaint will be sent to you as soon as possible, we will aim to do so on the same day. Throughout this process, all actions will be documented for reference
2-2	Once all information is reviewed, contact will be made with all parties concerned
2-3	We will aim to respond to you with a final outcome to your complaint, in writing within 10 working days of the complaint being appealed. However, if this is not possible, we will contact you to explain the reason for the delay, and the time extension required to provide a final response to the complaint.

If the complaint has been resolved, and is closed at this stage, issues identified, problems solved, and any recommended changes will be logged in a tracker. This will be submitted to HyperionDev’s SMT (Senior Management Team) via a summary of the tracker, to be discussed at the next complaints committee meeting, in order to ensure sustainable problem solving and complaint resolution, with this committee to be held at least once per quarter.

Appeal Escalation

Stage 3

If you are still not satisfied with the outcome of your complaint and appeal, you may have the ability to appeal or escalate your complaint depending on the programme you are on with HyperionDev.

Please refer to your Student Undertaking Agreement for further details of this escalation policy that applies to your programme.

Please be aware that a prerequisite may be having followed this complaints process in full, giving HyperionDev a chance to give you a final decision on your complaint.