Child Abuse and Neglect

Prevention and Reporting Guidelines

The Safety of Our Students is Our #1 Priority

TPR Education, LLC d/b/a The Princeton Review and Tutor.com and their subsidiaries (collectively,
the “Company) are committed to providing high-quality services in a safe environment. The
Company has zero tolerance for actual or threatened acts of physical or emotional abuse, sexual abuse,
or neglect against children who are the Company’s minor students. It is the purpose of this policy to
provide important guidance regarding child abuse and neglect prevention and reporting.

All Company employees, officers, directors and contractors (collectively, “Company personnel”) must
follow this policy when they reasonably suspect, learn of, or witness child abuse or neglect. The
Company will terminate the employment of or affiliation with anyone who commits child abuse or
neglect.

Definitions

Child abuse and neglect include, but are not limited to, the following and any other mistreatment of
children prohibited by applicable law:

 Physical abuse is the intentional use of physical force that results in or that can
result in physical injury to a child. Examples of physical abuse include hitting,
kicking, or burning a child.

 Emotional abuse is behavior that harms a child’s self-worth or emotional

well-being or that impairs a child’s emotional development. Examples of
emotional abuse include constant criticism and making threats.

 Sexual abuse is pressuring or forcing a child to engage in sexual acts or use

of a child for sexual gratification. Examples of sexual abuse that involves
contact include fondling, intentionally touching directly or through the
clothing the intimate parts of a child or causing the child to touch the
intimate parts of another, rape, and prostitution or sex trafficking of a child.
Examples of sexual abuse that does not involve contact include exposing a
child to sexual activity such as pornography, indecent exposure, filming a
child in a sexual manner, and voyeurism of a child.

 Neglect is the failure to provide for a child’s basic needs or the

failure to protect a child from harm. Examples of neglect include
failure to provide adequate nutrition, hygiene, shelter, medical care,
and education.

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Interactions – What’s Appropriate and What’s Not

All Company personnel are expected to conduct themselves professionally at all times and to treat all
minor students respectfully and fairly. While it is not feasible to anticipate every situation that may be
encountered, it is critical that all Company personnel who work with minor students be guided by the
policies and examples described herein to ensure a safe environment for minor students. Not every act
that might be inappropriate will constitute child abuse or neglect. However, the Company will review
incidents of inappropriate interactions to determine whether, under the circumstances, an individual’s
conduct is prohibited and subject to disciplinary action up to and including termination.

 Physical Contact (when COVID-19 social distancing guidelines are no longer in effect)
The Company’s policy with respect to physical contact is to promote a positive and safe
environment. Inappropriate physical contact is prohibited. Examples of appropriate and
inappropriate physical interactions are as follows:

Appropriate Physical Interactions Inappropriate Physical Interactions

 Pats on the shoulder or back  Kisses
 Handshakes  Any type of massage given by or to a
 High-fives and hand slapping minor student
 Roughhousing
 Physical discipline

 Verbal Interactions
All Company personnel are prohibited from speaking to in a way that is or could be
construed as threatening, coercive, intimidating, derogatory, demeaning, or humiliating.
In addition, no one is permitted to initiate sexually-oriented conversations or to discuss
their own sexual activities. Examples of appropriate and inappropriate verbal
interactions include:

Appropriate Verbal Interactions Inappropriate Verbal Interactions

 Positive reinforcement  Name-calling, belittling, shaming, or making
 Appropriate jokes derogatory remarks
 Encouragement  Discussing sexual encounters
 Praise  Cursing or using obscene, vulgar, or profane
language
 Off-color or sexual jokes

 Electronic Communications
o Any non-work-related electronic communication between Company personnel and
minor students, including through instant messaging, texting, and social networking
websites like Facebook, Instagram, and Snapchat, is prohibited. This includes
“friending” minor students on social networking sites.

o All electronic communications between instructors and tutors and minor students
regarding work or the Company’s services must be appropriate and professional. Any
verbal interaction that would be inappropriate under the preceding the section is also
inappropriate in electronic communications.

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  Attire
All Company personnel interacting with minor students in person or through video must
wear appropriate clothing. Inappropriate clothing includes, but is not limited to,
clothing that is revealing or that includes words that constitute inappropriate verbal
interactions or images of a sexual nature.

 One-on-One, In-Person Interactions

o Tutors for TPR Education, LLC are not permitted to meet in person with a minor student
in a private home unless another adult is present during the entire session. If a tutor
arrives for a session and an adult is not present, the tutor may not conduct the session. If
the other adult leaves in the middle of a session with a minor student, the tutor must also
leave at that time. Tutors may meet in person with minor students in public locations,
such as a library or coffee shop, without another adult present. Tutors may also meet in
person with minor students at the Company’s offices if there are other people in the
offices and if they conduct the session in rooms that have doors with windows.

o Situations may arise from time to time in which classroom instructors for TPR Education,
LLC are meeting one-on-one with a minor student in-person. Instructors should generally
try to avoid these situations, but when they arise, instructors should, to the extent possible,
attempt to meet in a public place or in a room, office, or other area that can be easily
observed by others with the door open.

Who is Required to Report and What is the Procedure?

Under this policy, all Company personnel are required to report any knowledge or suspicion of abuse
or neglect of a minor student, whether perpetrated by Company personnel or someone else,
immediately to the appropriate authorities in their jurisdiction and the head of the Company’s
Human Resources department (the “Designated Officer”). In emergency situations, make the report
to law enforcement (911) first.

The U.S. Department of Health and Human Services’ website at

https://www.childwelfare.gov/organizations/?CWIGFunctionsaction=rols:main.dspList&rolType=
Custom&RS_ID=%205 provides contact information for reporting child abuse and neglect in US
jurisdictions. In Canada, Company personnel must contact the local child welfare authority. Most
states and provinces have laws that require certain occupations or professional roles (e.g., social
workers, school officials, teachers, nurses, and therapists) to report child abuse or neglect. In some
states and provinces, everyone is required to report child abuse and neglect. If you are unsure of
your jurisdiction’s requirements, please contact the Human Resources department for more
information. Mandatory reporters may be held legally liable for fines and subject to criminal
penalties for failure to report in jurisdictions with mandatory reporting requirements. Where state or
provincial laws apply, they take precedence over this policy.

Please note that due to the anonymity of Tutor.com’s tutoring service, Tutor.com tutors must submit
a Support Ticket categorized as “Student in Crisis” right away to report child abuse and neglect
and include the following in the Support Ticket: the date and time of the session, the student’s
institution (e.g., school, library system) if known, subject covered in the session and statements
made by the student that led you to think the student should be considered the victim of abuse or
neglect. To submit a Support Ticket go to http://www.tutor.com/providers/go/support.

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To report child abuse or neglect to the Company so that the Company can also report and investigate
it, please contact the Designated Officer at 646-619-8230 or HR@Review.com.

Failure to report child abuse or neglect may result in disciplinary action, up to and including
termination.

Retaliation Prohibited

The Company prohibits retaliation against any Company personnel who, in good faith, reports
suspected child abuse or neglect or who participates in any related investigation. Anyone who retaliates
against someone who has made a good faith allegation of child abuse or neglect will be subject to
discipline, up to and including termination.

Investigation and Follow-up

The Company takes allegations of child abuse or neglect by Company personnel seriously. Once the
allegation is reported, the Company will promptly and thoroughly conduct an investigation to determine
whether there is a reasonable basis to believe that the prohibited conduct has occurred and that it was
committed by the target of the investigation. The Designated Officer may conduct the investigation using
either outside third parties or appropriate internal personnel, depending on the nature and circumstances
of the allegation. The Company will cooperate fully with any investigation conducted by law
enforcement or regulatory agencies, and the Company may refer the complaint and the result of its
investigation to those agencies. Individuals perpetrating child abuse or neglect will be subject to civil or
criminal prosecution. The Company reserves the right to place the target of the investigation on an
involuntary leave of absence or reassigning that person to responsibilities that do not involve personal
contact with individuals or students. To the fullest extent possible, but consistent with its legal obligation
to report suspected prohibited conduct to appropriate authorities, the Company will endeavor to keep the
identity of the target and the alleged victim confidential.

Background Checks

In an effort to screen for individuals who may engage in child abuse or neglect, the Company performs
background checks, including screening for sex offenders, when it hires employees or engages
independent contractor tutors, and the Company may perform recurring background checks on its
instructors and tutors.

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