Unity Institute Inc.

VenCap Developments LLC · U.S. Licensed Operator

Prepared Academy · Youth Pathway

Youth Safeguarding Policy

Effective 30 July 2026 · Version 1.0 · United States · Applies to all participants under 18

The safety, dignity, privacy, and wellbeing of every young person in our programs come before every other consideration. We build young people toward a higher standard—and we protect them while we do it.

1. Purpose & Scope 2. Eligibility & Youth Participation 3. Parent or Guardian Authorization 4. Schools, Teams & Youth Partners 5. Vetting & Screening of Adults 6. Adult Code of Conduct 7. Supervision, Contact & Transportation 8. Communication Boundaries 9. Online & Virtual Sessions 10. Assignments & Community Participation 11. Photography, Recordings & Testimonials 12. Youth Privacy & Information Practices 13. Access, Withdrawal, Retention & Deletion 14. Handling Disclosures 15. Reporting & Escalation 16. Privacy & Security Incidents 17. Not Clinical Care 18. Related Policies 19. Designated Safeguarding Lead

1Purpose & Scope

This Policy establishes the safeguarding, conduct, supervision, privacy, communication, and reporting standards used by VenCap Developments LLC, licensed by Unity Institute Inc., for U.S. participants under 18. It applies to youth Offerings distributed or operated through VenCap, including Prepared Academy, YouthVision, the Youth Clarity Accelerator, student-athlete programs, and any other Offering expressly identified as a youth or family program.

This Policy applies to VenCap personnel and every instructor, facilitator, coach, contractor, volunteer, expert-network partner, institutional partner representative, or other adult who delivers, supervises, moderates, transports, communicates with, or otherwise supports a youth Offering (each, an “Authorized Adult”).

Unity Institute Inc. remains the creator, licensor, and intellectual-property owner of the applicable programs and frameworks. VenCap Developments LLC is the U.S. seller of record and authorized operator responsible for applying this Policy to U.S. delivery.

2Eligibility & Youth Participation

General Offerings are intended for individuals who are at least 18 years old unless the applicable Offering is expressly identified as a youth or family program. A participant under 18 may access only a program intended for children, teenagers, young adults, or families and only with parent or legal-guardian authorization.

For every participant under 18:

A parent or legal guardian must complete or expressly authorize enrollment, purchase, and account creation.
The parent or legal guardian must accept the applicable Terms of Use, Privacy Policy, this Policy, and any youth-specific rules on the participant’s behalf.
The parent or legal guardian must provide required consent for collection, use, and disclosure of the participant’s information.
The parent or legal guardian is responsible for accurate enrollment information, appropriate account security, and supporting safe and appropriate use.
The participant must follow the Terms of Use, community standards, facilitator directions, and youth-specific rules.

Participants under 14. As an organizational standard, a participant under 14 may not independently create an account, make a purchase, or directly submit personal information before a parent or legal guardian completes or approves the enrollment process. For children under 13, any online collection subject to the Children’s Online Privacy Protection Act requires the applicable parental notice and verifiable parental consent before collection, unless a lawful exception applies.

VenCap may request reasonable information to verify the identity or authority of a parent or legal guardian. Access may be delayed, restricted, or suspended where required authority or consent cannot be verified. Nothing in this section limits a privacy, access, consent, or participation right that a young person may exercise directly under applicable law.

Parents or guardians receive information about the program purpose, format, schedule, platforms, supervision model, communication channels, and material risks or requirements.
Enrollment records identify the parent or guardian’s name, email address, relationship to the participant, and confirmation of legal authority.
The participant’s age or age range is collected; a full birth date is requested only where reasonably necessary.
A separate youth-program consent is obtained in addition to general purchase acceptance.
Media, recording, testimonial, and promotional permissions are separate and optional.
Where appropriate, the young person receives a short, clear, age-appropriate explanation of program and privacy practices and is asked for acknowledgement or assent.
A parent or guardian may request appropriate information about participation, withdraw consent, or discontinue participation, subject to legal, safety, certification, payment, and record-retention requirements.

A parent or guardian’s access to a young person’s information may be limited where applicable law gives the young person an independent right, disclosure could create a credible safety risk, or another legal restriction applies. These situations are reviewed individually.

4Schools, Homeschool Organizations, Teams & Youth Partners

Where a school, homeschool organization, sports organization, youth organization, foundation, or other institutional partner enrolls or refers participants under 18, that organization must confirm that it has lawful authority and the consents needed to provide participant information and authorize participation.

Partner responsibilities may be documented through a written agreement addressing enrollment authority, parent notice and consent, data-sharing, supervision, communication, emergency procedures, incident reporting, retention, access requests, and safeguarding responsibilities. An institutional partner’s involvement does not eliminate VenCap’s responsibility to apply this Policy to information and activities under its control.

5Vetting & Screening of Adults

Every Authorized Adult with direct, recurring, unsupervised, or trust-based access to youth must complete screening before contact begins. Screening is proportionate to the role and may include:

Identity verification and a criminal-background check conducted with any notice and authorization required by applicable law.
A search of relevant state and national sex-offender registries where lawful and appropriate.
Reference checks and confirmation of relevant education, credentials, experience, and employment or volunteer history.
Review of role-specific professional, licensing, disciplinary, or safeguarding history where relevant.
A signed Facilitator Policy Agreement or equivalent acknowledgement of this Policy, confidentiality requirements, and the Code of Conduct.

Background screening is renewed at least every 3 years and may be repeated sooner where a role changes, a concern arises, or law, insurance, a partner agreement, or risk assessment requires it. No adult may be placed in an unsupervised position of trust before required screening is complete and approved.

6Adult Code of Conduct

Every Authorized Adult must:

Treat each young person with dignity and maintain high standards without belittling, shaming, humiliating, threatening, or manipulating them.
Never engage in, encourage, normalize, conceal, or tolerate abuse, exploitation, grooming, harassment, discrimination, bullying, sexualized conduct, or inappropriate physical contact.
Never pursue a romantic, sexual, secretive, exploitative, or private personal relationship with a participant.
Never request secrecy from a participant or use gifts, money, favors, special access, or private attention to build inappropriate influence.
Never exchange sexually explicit, violent, degrading, or age-inappropriate content with or in the presence of a participant.
Never possess, use, or be impaired by alcohol, cannabis, illegal drugs, or misused medication while responsible for youth.
Report boundary violations, suspected abuse, unsafe practices, and concerning conduct without delay.

Retaliation, intimidation, punishment, or adverse treatment against a young person, parent, reporter, witness, or staff member who raises a concern in good faith is prohibited.

7Supervision, Physical Contact, Meetings & Transportation

Youth activities are conducted in observable and interruptible settings. A two-adult standard is used for live delivery where reasonably practicable.
One-on-one contact is permitted only where genuinely necessary, authorized for the program, known to the parent or guardian, and conducted in an observable, recorded, or parent-visible format.
Closed-door meetings, private home visits, hotel-room meetings, or other isolated contact are prohibited unless an emergency makes the contact necessary and it is documented and reported.
Physical contact must be necessary, appropriate, minimal, explained where practical, respectful of the participant’s boundaries, and visible to others. Athletic or movement instruction uses verbal direction or demonstration before physical correction.
An Authorized Adult may not transport a participant alone in a personal vehicle except in an emergency or under a documented, preauthorized transportation arrangement with guardian consent and appropriate safeguards.
Overnight activities, travel, changing areas, accommodations, and off-site events require program-specific supervision, privacy, rooming, communication, and emergency procedures.

8Communication Boundaries

Communication occurs through approved program, institutional, or business channels—not personal social-media accounts, disappearing-message services, or secret communication channels.
Parents or guardians are copied on or have visibility into individual communication with a minor wherever reasonably possible.
Authorized Adults do not solicit private contact details, initiate private social relationships, or connect with participants through personal social-media accounts.
Messages are limited to legitimate program, scheduling, support, safety, and administrative purposes and are sent at reasonable times.
Content that creates a safety, privacy, conduct, or safeguarding risk may be restricted, preserved for review, or escalated.

9Online & Virtual Sessions

Virtual sessions use approved platforms with controlled access, unique or protected links, waiting rooms where available, and host controls appropriate to the program.
Authorized Adults use professional settings, names, profiles, backgrounds, and on-camera conduct.
Private breakout rooms are monitored or configured to permit host access and are not used for secret or unobservable one-on-one contact.
Sessions may be recorded for safeguarding, accessibility, documentation, or quality purposes only when participants and parents are informed and the recording is authorized.
Participants may not independently record, screenshot, download, publish, or distribute another participant’s image, voice, disclosure, assignment, username, or identifying information.
Youth profiles, submissions, and direct-messaging features are private, restricted, disabled, or moderated by default where the Platform permits.

10Assignments, Reflections & Community Participation

Youth Offerings may include worksheets, personal reflections, projects, discussion activities, or moderated community participation. Unless a program clearly states otherwise:

Assignments, progress information, and personal reflections are private program information.
A participant is not required to publicly disclose personal experiences, family circumstances, trauma, health information, or other sensitive information to complete a program.
Neutral, hypothetical, fictionalized, or non-personal completion options are provided where an activity might otherwise require sensitive disclosure.
Participants must not post home addresses, personal telephone numbers, passwords, school schedules or locations, precise location information, financial information, or other information that could create a safety risk.
Community areas may be supervised, moderated, restricted, or closed. Content may be removed where it creates a privacy, safety, intellectual-property, or conduct concern.
Direct messaging between youth participants and other users may be restricted or disabled where necessary to protect participants.

11Photography, Recordings, Work Samples & Testimonials

VenCap does not use a participant’s photograph, video, audio, name, testimonial, work sample, or identifiable participation for public, promotional, or marketing purposes without separate prior authorization from a parent or legal guardian. Where appropriate, VenCap also seeks the young person’s age-appropriate assent.

Promotional consent is separate from consent needed to deliver the program.
Declining promotional consent does not prevent access to the underlying educational service.
Consent may be limited by purpose, medium, or duration and may be withdrawn for future use.
Withdrawal does not necessarily require recall of materials lawfully published or distributed before the withdrawal was received.
Published youth content avoids unnecessary surnames, school names, precise locations, schedules, routines, contact details, and other information that could identify or locate a participant.

12Youth Privacy & Information Practices

Information about participants under 18 is treated as sensitive and handled in accordance with the U.S. Privacy Policy, this Policy, applicable law, and any program-specific notice.

Information that may be collected

Participant name, age or age range, approved contact information, and account information.
Parent or guardian name, contact information, relationship, legal-authority confirmation, and consent records.
Enrollment, attendance, progress, completion, certification, assignments, worksheets, reflections, and voluntarily submitted program materials.
Communications involving the participant, parent, guardian, facilitator, support team, or institutional partner.
Device, login, security, and technical information necessary to operate and protect the Platform.
Emergency, accessibility, accommodation, support, or safety information where reasonably necessary for a facilitated, live, athletic, or in-person program.

Only information reasonably necessary to enroll the participant, deliver the program, provide support, protect participants, administer completion or certification, and meet legal or operational obligations is collected. Participants should not provide medical, mental-health, financial, family, precise-location, or other highly sensitive information unless it is specifically requested for a clear and appropriate purpose.

How youth information is used

Create, secure, and administer the participant’s account.
Deliver programs, activities, resources, support, assessments, and certificates.
Communicate with the participant and parent or guardian.
Record attendance, participation, progress, completion, and consent.
Moderate community areas and protect the safety, security, and integrity of participants and the Platform.
Respond to privacy, conduct, safety, legal, or emergency concerns.
Meet legal, regulatory, tax, insurance, accreditation, certification, and record-keeping obligations.

Privacy-protective defaults

VenCap does not knowingly:

Sell or rent personal information concerning participants under 18.
Use youth information for behaviorally targeted or cross-context behavioral advertising.
Create unrelated commercial profiles based on a young person’s course activity.
Require a public profile, public assignment, or public personal reflection.
Collect precise location information unless necessary, clearly disclosed, and appropriately authorized.
Require more personal information than is reasonably necessary to participate.

Marketing about youth programs is ordinarily directed to the parent or guardian. Direct marketing to a participant under 18 is used only where lawful, appropriate, and supported by the consent required for that communication.

Service providers and processing locations

VenCap may use service providers for course delivery, account administration, communications, cloud storage, video delivery, forms, scheduling, analytics, security, and payment processing. Providers receive youth information only as reasonably necessary to provide authorized services or as permitted by law.

Information may be processed in Nevada, elsewhere in the United States, Canada, or another jurisdiction where VenCap, Unity Institute Inc., or an authorized provider operates. VenCap remains accountable for information under its control and uses reasonable contractual, administrative, and technical measures intended to require providers to protect information and use it only for authorized purposes.

13Access, Correction, Withdrawal, Retention & Deletion

A participant, parent, or legal guardian may contact VenCap to request access to or correction of personal information, withdraw consent, or request deletion, subject to applicable legal, contractual, safety, certification, and record-retention requirements.

VenCap may verify identity and, where an adult acts for a young person, verify parental or guardianship authority.
Requests are evaluated in light of applicable law, the participant’s age and maturity, legal rights, safety, and best interests.
Withdrawal of consent may limit continued participation where information is necessary for account creation, program delivery, certification, required records, or participant safety.
Information may be retained where reasonably necessary for legal, tax, accounting, payment, security, certification, dispute-resolution, insurance, or safeguarding purposes.
Youth information is not retained solely for speculative future marketing.

VenCap maintains a youth-data retention schedule and periodically reviews youth information. Information no longer required is deleted, anonymized, aggregated, or securely disposed of using measures appropriate to its sensitivity.

14Handling Disclosures or Signs of Harm

If a young person discloses harm, abuse, exploitation, neglect, self-harm risk, or another serious safety concern—or an Authorized Adult observes credible signs of possible harm—the Authorized Adult must:

Remain calm, listen, take the concern seriously, and prioritize immediate safety.
Not promise secrecy or confidentiality that cannot be maintained.
Ask only minimal, open, non-leading questions needed to clarify immediate safety and reporting requirements.
Not investigate, interrogate, confront the alleged person responsible, or ask the young person to repeat the account unnecessarily.
Record the date, time, context, observations, actions, and the young person’s words as accurately as possible.
Report the concern immediately under Section 15.

Safeguarding records are factual, access-restricted, and maintained separately or appropriately protected from ordinary program files.

15Reporting & Escalation

External reporting comes first where required. An internal report does not replace any duty to report suspected child abuse or neglect to a child-protection or law-enforcement agency. If a child may be in immediate danger, call 911 or the appropriate emergency service first.

All Authorized Adults must immediately notify the Designated Safeguarding Lead of a safeguarding concern unless doing so could delay a legally required external report, increase danger, compromise evidence, or involve the Lead as the subject of the concern. Where law requires a direct report, the person with the concern must make it and may not delegate that legal duty to VenCap.

Reporting duties vary by state and by the reporter’s role. For Nevada operations, a person covered by Nevada’s mandatory-reporting law who knows or has reasonable cause to believe, in a professional or occupational capacity, that a child has been abused or neglected must report as soon as reasonably practicable and no later than 24 hours. Reports are made to the appropriate child-welfare agency or law-enforcement agency as required by the circumstances.

The Designated Safeguarding Lead coordinates immediate safety measures, documentation, preservation of relevant records, parent or guardian communication where appropriate, institutional-partner notification where authorized, and reports to insurers, regulators, child-protection authorities, or law enforcement where required. Good-faith reporters are protected from retaliation under this Policy.

16Privacy & Security Incidents

Where a privacy, security, account, communication, or platform incident involves a participant under 18, VenCap will:

Investigate promptly and take reasonable containment, preservation, and corrective measures.
Assess the information involved, affected participants, potential harm, and continuing safety risks.
Restrict compromised access, reset credentials, preserve evidence, and coordinate with service providers where necessary.
Notify the participant, parent or guardian, Unity Institute Inc., institutional partners, insurers, regulators, law enforcement, or other parties where notification is required or reasonably necessary.
Document the incident, response, decisions, and corrective actions under the applicable incident-response procedure.

17Not Clinical Care

Youth Offerings are educational and developmental. They are not therapy, counseling, medical care, mental-health treatment, diagnosis, crisis intervention, or child-protection services. Authorized Adults must not diagnose, treat, investigate abuse, or act outside their qualifications.

Where a young person needs professional support beyond program scope, VenCap may pause participation, contact the parent or guardian where appropriate, and direct the family to licensed or emergency services. A safeguarding or legal reporting duty is followed even where the family prefers that no report be made.

This Policy operates with the following U.S. policies and agreements:

19Designated Safeguarding Lead

Questions, concerns, disclosures, or reports relating to this Policy should be directed without delay to:
Designated Safeguarding Lead — VenCap Developments LLC, licensed by Unity Institute Inc.
Ian France, CEO
[email protected] · www.unityinstitute.us

If the concern involves the Designated Safeguarding Lead or senior leadership, do not report the concern only to the person implicated. Make any required report directly to child protective services or law enforcement and notify another authorized VenCap officer where reasonably possible.

No public U.S. mailing address is listed on this page. Legally sufficient service of process must be completed through VenCap Developments LLC’s registered agent or another method permitted by applicable law.