Environmental Policy

Effective date: September 26, 2025

ProctorEdu Inc. dba OctoProctor ("we," "us," "our," or "OctoProctor") is committed to conducting our business in an environmentally responsible manner. This Environmental Policy ("Policy") outlines our commitment to minimizing our environmental impact, promoting sustainability, and complying with applicable environmental regulations.
As a Software-as-a-Service (SaaS) company providing online proctoring solutions, we recognize our responsibility to address the environmental impacts of our digital infrastructure, business operations, and the broader effects of our services on the environment.

1. Scope and application

1.1 Who this Policy applies to

This Policy applies to:

• OctoProctor employees: All staff members, contractors, and consultants
• Business partners: Vendors, suppliers, and service providers
• Testing Institutions: Clients using our Services
  
• Stakeholders: Investors, board members, and other interested parties
  

1.2 Areas covered

This Policy addresses environmental considerations in:

• Digital infrastructure and data center operations
• Office operations and facilitiesBusiness travel and remote work
  
• Procurement and supply chain
• Product development and service delivery
• Waste management and resource use
• Corporate culture and employee engagement

2. Environmental commitments

2.1 Core principles

OctoProctor is committed to:

• Minimizing environmental impact: Reducing our carbon footprint and resource consumption across all operations
• Sustainable technology: Leveraging efficient, environmentally responsible infrastructure and technologies
• Continuous improvement: Regularly assessing and improving our environmental performance
  
• Compliance: Meeting or exceeding applicable environmental laws, regulations, and standards
  
• Transparency: Openly communicating our environmental performance and goals
• Responsible partnerships: Working with vendors and partners who share our environmental values
  
• Education and awareness: Promoting environmental consciousness among employees, clients, and partners
  

2.2 Environmental objectives

OctoProctor recommends that Testing Institutions implement the following break guidelines:Our key environmental objectives include:

• Carbon neutrality: Working toward carbon-neutral operations
• Energy efficiency: Maximizing energy efficiency in our digital infrastructure
  
• Waste reduction: Minimizing waste generation and maximizing recycling
  
• Sustainable procurement: Prioritizing environmentally responsible suppliers and products
  
• Digital efficiency: Optimizing our software and services to reduce computational resource requirements
  
• Remote-first benefits: Leveraging our digital nature to reduce transportation-related emissions
  
• Awareness and engagement: Fostering environmental responsibility throughout our organization
  

3. Digital infrastructure and data centers

3.1 Cloud infrastructure strategy

OctoProctor operates entirely on cloud infrastructure, specifically Amazon Web Services (AWS) in the Ireland (eu-west-1) region. This strategic decision provides significant environmental benefits:

Energy efficiency:

• AWS data centers are among the most energy-efficient in the world
• Shared infrastructure model reduces per-customer energy consumption
  
• Advanced cooling and power management systems minimize energy waste
  
• Continuous optimization of server utilization rates
  

Renewable energy:

• AWS is committed to powering operations with 100% renewable energy
• Amazon's Ireland data centers increasingly source renewable energy
  
• We benefit from AWS's investment in wind and solar projects
  
• We support AWS's goal of reaching net-zero carbon by 2040
  

Infrastructure efficiency:

• Cloud infrastructure allows for dynamic resource allocation
• Reduces need for over-provisioning of computing resources
  
• Eliminates idle server capacity common in on-premises data centers
  
• Enables efficient scaling based on actual demand
  

3.2 Our cloud environmental practices

Right-sizing resources:

• We continuously monitor and optimize our cloud resource usage
  
• Regular audits identify and eliminate over-provisioned resources
  
• Auto-scaling ensures resources match actual demand
  
• We decommission unused or redundant services promptly
  

Data storage optimization:

• Efficient data storage strategies minimize storage footprint
  
• Data compression reduces storage space requirements
  
• Intelligent data lifecycle management archives or deletes obsolete data
  
• Backup strategies balance data protection with storage efficiency
  

Compute efficiency:

• Optimized code reduces computational requirements
• Efficient algorithms minimize processing time and energy consumption
  
• Caching strategies reduce redundant computations
  
• We leverage AWS's latest, most efficient instance types
  

Network optimization:

• Content delivery strategies minimize data transfer distances
• Efficient data transmission protocols reduce bandwidth requirements
  
• We optimize API calls and data transfers
  
• Compression and efficient protocols reduce network energy consumption
  

3.3 Data center transparency

We are committed to transparency regarding our infrastructure's environmental impact:

• Location disclosure: All data is hosted in AWS Ireland (eu-west-1)
• Vendor transparency: We publicly disclose our primary infrastructure provider
  
• Energy sources: We monitor AWS's renewable energy progress and report significant milestones
  
• Carbon footprint: We track and report on our infrastructure carbon footprint
  

AWS environmental credentials:

• AWS Sustainability: https://sustainability.aboutamazon.com/
• AWS Customer Carbon Footprint Tool provides visibility into our infrastructure emissions
  
• Carbon footprint: We track and report on our infrastructure carbon footprint
  

4. Office operations and facilities

4.1 Office location

Primary office: ProctorEdu Inc. 111 Pier Ave STE 100 Hermosa Beach, CA 90254 United States

4.2 Sustainable office practices

Energy conservation:

• Use of energy-efficient lighting (LED bulbs throughout office)Smart thermostats and HVAC management systems
• Computers and equipment set to energy-saving modes when not in use
• Natural lighting maximized to reduce artificial lighting needs
  
• Energy-efficient appliances in break rooms and common areas
  

Water conservation:

• Low-flow fixtures in restrooms and kitchens
• Water-efficient appliances
• Prompt repair of leaks and water waste
  
• Employee awareness programs on water conservation
  

Waste reduction and recycling:

• Comprehensive recycling program (paper, plastic, glass, metal, electronics)
• Composting of organic waste where available
• Reduction of single-use plastics in office
  
• Digital-first approach minimizing paper usage
  
• Reusable dishware and utensils in break rooms
  
• Proper disposal of hazardous materials (batteries, electronics)
  

Sustainable procurement:

• Preference for recycled and recyclable office supplies
• Environmentally certified cleaning products
• Energy Star certified equipment and appliances
  
• Locally sourced products when possible to reduce transportation emissions
  
• Sustainable and ethically sourced coffee, tea, and food items
  

Green office culture:

• "Print less" policy encouraging digital document management
• Double-sided printing as default setting
• Reusable water bottles and coffee cups encouraged
  
• Bike parking and alternative transportation support
  
• Educational materials on environmental best practices
  

4.3 Remote work environmental benefits

As a technology company, we embrace remote and hybrid work models, which provide significant environmental benefits:

Reduced commuting emissions:

• Remote work eliminates daily commute for many employees
• Estimated reduction of X tons of CO2 annually (based on average commute distances)
• Reduced traffic congestion in local communities
• Decreased demand for parking infrastructure
  

Reduced office footprint:

• Smaller office space requirements reduce energy consumption
• Reduced heating, cooling, and lighting needs
• Less water consumption
• Lower overall building environmental impact
  

Digital collaboration:

• Video conferencing replaces business travel
• Digital document sharing eliminates paper and printing
• Cloud-based collaboration tools reduce need for physical meetings
• Lower overall resource consumption per employee
  

Supporting remote work:

• We provide guidance on home office energy efficiency
• Encourage employees to use energy-efficient equipment
• Support for public transportation and carpooling for in-office days
• Flexible schedules to reduce peak-hour commuting
  

5. Business travel

5.1 Travel reduction strategies

Digital-first approach:

• Video conferencing for meetings whenever possible
• Virtual participation in conferences and events
• Remote training and onboarding programs
  
• Digital customer support and relationship management
  

When travel is necessary:

• Prioritize direct flights (more fuel-efficient than multi-leg journeys)
• Choose economy class over business/first class (lower per-passenger emissions)
• Consolidate trips to reduce frequency of travel
  
• Select accommodations with environmental certifications when available
  
• Utilize public transportation at destinations
  
• Consider train travel for shorter distances where feasible
  

Travel policy:

• Employees must justify business travel and consider virtual alternatives
• Approval process includes environmental impact consideration
• Travel booking tools highlight lower-emission options
  
• Track and report travel-related emissions annually
  

5.2 Carbon offset programs

• We evaluate and participate in credible carbon offset programs
• Priority given to projects with verified environmental benefits
• Focus on renewable energy, reforestation, and conservation projects
  
• Annual review of offset program effectiveness
  
• Transparency in reporting offset purchases and impact
  

6. Product and service environmental impact

6.1 Digital proctoring environmental benefits

Our core service — online proctoring — provides significant environmental advantages compared to traditional in-person examination models:

Elimination of physical infrastructure:

• No need for dedicated testing centers with associated energy consumption
• Reduced heating, cooling, and lighting for examination facilities
• Less physical construction and building materials
  
• Reduced maintenance and janitorial services
  

Reduced transportation:

• Test takers avoid travel to testing centers
• Eliminates hundreds or thousands of individual commutes per examination cycle
• Particularly impactful for institutions with distributed student populations
  
• Reduces need for specialized transportation for individuals with disabilities
  

Paper reduction:

• Digital examination materials eliminate paper printing
• Digital proctoring reports replace paper documentation
• Electronic record-keeping reduces physical file storage
  
• Overall reduction in paper production, transportation, and waste
  

Scalability efficiency:

• Digital platform serves unlimited users without proportional resource increase
• Marginal environmental impact of each additional user is minimal
• Efficient use of computing resources through shared infrastructure
  
• No physical capacity constraints requiring facility expansion
  

6.2 Sustainable software development

Efficient coding practices:

• Code optimization reduces computational requirements
• Efficient algorithms minimize processing time and energy
• Regular code reviews identify performance improvements
  
• Legacy code refactoring to improve efficiency

Green DevOps:

• Automated testing reduces redundant manual processes
• Continuous integration/deployment minimizes resource waste
• Development and staging environments sized appropriately
  
• Decommissioning of unused development resources

Sustainable design:

• User interface designs that minimize data transfer
• Efficient media encoding and compression
• Progressive loading strategies
  
• Optimized assets (images, videos, scripts)

Product lifecycle:

• Regular updates extend product life and improve efficiency
• Backward compatibility reduces need for infrastructure upgrades
• Smooth deprecation processes for outdated features
  
• Long-term support reduces need for premature replacements

6.3 Data retention and environmental impact

Responsible data retention:

• Default 6-month retention period minimizes long-term storage impact
• Optional 12-month retention only with explicit consent
• Automatic deletion reduces ongoing storage requirements
  
• Efficient data compression during storage period
  

Data minimization:

• Collect only necessary data for proctoring purposes
• Avoid storing redundant or unnecessary information
• Regular data audits identify opportunities for reduction
  
• Efficient database schemas minimize storage footprint
  

See our Terms of Service and Regional Data Protection Policy for detailed data retention information.

7. Supply chain and vendor management

7.1 Sustainable procurement policy

Vendor selection criteria:

• Environmental policies and practices are part of vendor evaluation
• Preference for vendors with environmental certifications (ISO 14001, etc.)
• Assessment of vendor carbon footprint and sustainability commitments
  
• Local vendors preferred to reduce transportation emissions when quality is comparable
  

Key supplier expectations:

• Compliance with environmental regulations
• Transparent reporting of environmental practices
• Continuous improvement in environmental performance
  
• Alignment with our environmental values and goals
  

Major vendors and partners:

• Amazon Web Services (AWS): Primary infrastructure provider with strong environmental commitments
• Office suppliers with sustainable product offerings
• Service providers with documented environmental policies
  

7.2 Electronic equipment and e-waste

Equipment procurement:

• Energy Star certified computers and equipment
• Preference for manufacturers with take-back and recycling programs
• Durable, repairable equipment over disposable alternatives
  
• Equipment sized appropriately for intended use
  

Equipment lifecycle management:

• Regular maintenance extends equipment life
• Repair vs. replace evaluation for malfunctioning equipment
• Donation of functional used equipment to nonprofits or schools
• Responsible recycling through certified e-waste recyclers
  

E-waste disposal:

• Never dispose of electronics in regular trash
• Use certified e-waste recyclers (R2 or e-Stewards certified)
• Data security procedures before equipment disposal
  
• Tracking and documentation of e-waste disposal
  
• Priority given to recyclers that maximize component recovery and minimize landfill
  

Battery and small electronics:

• Collection points for batteries and small electronics in office
• Proper disposal of rechargeable and single-use batteries
• Recycling of peripherals (keyboards, mice, cables)
  
• Reduction of single-use batteries through rechargeable alternatives
  

8. Environmental compliance

8.1 Applicable regulations

OctoProctor complies with environmental regulations in jurisdictions where we operate, including:

United States:

• Clean Air ActClean Water Act
• Resource Conservation and Recovery Act (RCRA)
• Electronic waste disposal regulations
  
• State-specific environmental regulations (California, etc.)Energy efficiency standards and building codes
  

European Union:

• Waste Electrical and Electronic Equipment Directive (WEEE)
• Restriction of Hazardous Substances Directive (RoHS)
• EU Energy Efficiency Directive
  
• EU Ecodesign DirectiveGeneral waste management regulations
  

International:

• Basel Convention on hazardous waste
• Relevant environmental regulations in client jurisdictions
• Industry-specific standards and guidelines

8.2 Environmental certifications and standards

Current certifications:

• Our infrastructure provider (AWS) maintains ISO 14001 Environmental Management certification
• We benefit from AWS's compliance with energy efficiency standards

Target certifications:

• We are evaluating pursuing direct ISO 14001 certification for our operations
• Consideration of B Corporation certification recognizing social and environmental performance
• Industry-specific environmental certifications as they become available

Compliance monitoring:

• Regular review of applicable environmental regulations
• Updates to policies and practices to maintain compliance
• Employee training on environmental compliance requirements
• Documentation and record-keeping for compliance demonstration

9. Monitoring, measurement, and reporting

9.1 Environmental metrics

We track and measure the following environmental indicators:

Energy and emissions:

• Cloud infrastructure energy consumption (via AWS reports)
• Office energy consumption (electricity, heating, cooling)
• Business travel emissions (flights, ground transportation)
• Employee commuting patterns and emissions (estimated)
• Total carbon footprint (Scopes 1, 2, and 3)

Resource consumption:

• Water usage at office facilities
• Paper consumption and recycling rates
• Electronic equipment purchases and disposal
• Office supplies and consumables

Waste management:

• Total waste generated
• Recycling rates by material type
• E-waste properly recycled
• Hazardous waste disposed of safely

Operational efficiency:

• Cloud resource utilization rates
• Data storage growth and optimization
• Software performance and efficiency metrics
• Virtual vs. in-person meeting ratio

9.2 Data collection and analysis

Measurement procedures:

• Monthly utility bill tracking for office energy and water
• AWS Customer Carbon Footprint Tool for infrastructure emissions
• Travel booking system reports for business travel emissions
• Facilities management data for waste and recycling
• Regular audits and spot checks for data accuracy

Analysis and reporting:

• Quarterly review of environmental metrics
• Annual environmental impact report
• Trend analysis identifying areas for improvement
• Benchmarking against industry standards
• Public reporting of key environmental indicators

9.3 Transparency and public reporting

Annual environmental report:

• Summary of environmental performance
• Progress toward environmental goals
• Challenges and lessons learned
• Plans for continued improvement
• Published on our website and shared with stakeholders

Continuous disclosure:

• Environmental policy published on website
• Key metrics included in company communications
• Updates on significant environmental initiatives
• Plans for continued improvement
• Response to stakeholder inquiries about environmental practices

10. Environmental goals and targets

10.1 Short-term goals (1-2 years)

Infrastructure efficiency:

• Achieve 15% reduction in cloud resource waste through optimization
• Implement comprehensive monitoring of all cloud resources
• Children's Online Privacy Protection Act (COPPA)

Office operations:

• Achieve 75% waste diversion from landfills through recycling and composting
• Reduce office energy consumption by 10% through efficiency measures
• Transition to 100% renewable energy for office electricity (where available)

Corporate practices:

• Reduce business travel emissions by 25% through virtual alternatives
• Display Screen Equipment (DSE) regulations in the UK and EU
• Implement comprehensive e-waste recycling program
• Establish sustainable procurement guidelines for all departments

Awareness and culture:

• ChilTrain 100% of employees on environmental best practices
• Launch internal environmental awareness campaign
• Establish "green team" of employee environmental champions

10.2 Medium-term goals (3-5 years)

Carbon reduction:

• Achieve 30% reduction in overall carbon footprint from baseline year
• Transition majority of business operations to carbon-neutral status
• Implement comprehensive carbon offset program for unavoidable emissions

Operational excellence:

• Achieve ISO 14001 Environmental Management System certification
• Implement closed-loop systems for office waste where possible
• Develop circular economy approaches for equipment and materials

Industry leadership:

• Publish best practices guide for environmental responsibility in SaaS industry
• Collaborate with industry partners on environmental initiatives
• Advocate for environmental standards in our sector

Product innovation:

• Develop features that help clients measure and reduce their own environmental impac
• tCreate reporting tools showing environmental benefits of online vs. in-person proctoring
• Optimize platform efficiency to achieve 20% reduction in computational requirements

10.3 Long-term vision (5+ years)

Carbon neutrality:

• Achieve carbon-neutral operations across all Scopes (1, 2, and 3)
• Work toward net-zero emissions through reduction and verified offsets
• Support broader industry transition to sustainable practices

Circular economy:

• Eliminate waste to landfill from office operations
• Establish product take-back programs where applicable
• Create closed-loop systems for all major resource streams

Positive impact:

• Quantify and publicize environmental benefits our services provide to clients
• Develop tools helping education sector understand and reduce environmental impact
• Support reforestation or conservation projects exceeding our carbon footprint

11. Employee engagement and training

11.1 Environmental training

New employee orientation:

• Introduction to OctoProctor's environmental policy and commitments
• Overview of individual employee responsibilities
• Training on office environmental practices (recycling, energy conservation, etc.)
• Resources for continued learning

Ongoing education:

• Annual environmental awareness training for all employees
• Departmental training on specific environmental considerations
• Updates on new environmental initiatives and practices
• Access to environmental resources and information

Specialized training:

• Procurement staff trained on sustainable purchasing practices
• Facilities and operations staff on environmental compliance
• Development teams on green coding and efficient software development
• Leadership on environmental strategy and decision-making

11.2 Employee participation programs

Green team:

• Volunteer employee group promoting environmental initiatives
• Organizing awareness events and educational activities
• Identifying improvement opportunities
• Serving as environmental ambassadors

Incentive programs:

• Recognition for employees demonstrating environmental leadership
• Awards for innovative environmental improvement suggestions
• Support for employee environmental volunteering
• Public transportation and bike commuting incentives

Feedback and suggestions:

• Open channels for environmental improvement ideas
• Awards for innovative environmental improvement suggestio
• Regular review and implementation of employee suggestions
• Communication of actions taken based on feedback
• Celebration of successful environmental initiatives

11.3 Remote work support

Home office environmental guidance:

• Tips for energy-efficient home offices
• Recommendations for sustainable equipment
• Guidance on e-waste disposal
• Support for remote work best practices

Equipment and resources:

• Energy-efficient equipment for home offices
• Support for ergonomic and sustainable office setups
• Resources for home recycling and waste reductionResources for home recycling and waste reduction

12. Client and partner engagement

12.1 Supporting client environmental goals

Environmental benefits communication:

• Providing data on emissions reduced through online vs. in-person proctoring
• Case studies demonstrating environmental advantages
• Tools for clients to measure their own environmental impact reduction
• Marketing materials highlighting sustainability benefits

Sustainable service delivery:

• Efficient platform minimizes client IT resource requirements
• Case studies demonstrating environmental advantages
• Tools for clients to measure their own environmental impact reduction
• Marketing materials highlighting sustainability benefits

Partnership in sustainability:

• Sharing best practices with Testing Institutions
• Collaborating on environmental initiatives
• Supporting client sustainability reporting needs
• Joint advocacy for environmental responsibility in education sector

12.2 Partner and vendor expectations

Vendor requirements:

• All major vendors must have documented environmental policies
• Preference for vendors with third-party environmental certifications
• Regular assessment of vendor environmental performance
• Collaboration on continuous improvement

Shared responsibility:

• Clear communication of our environmental expectations
• Support for vendors in meeting environmental standards
• Recognition of partners demonstrating environmental leadership
• Collective action on industry-wide environmental challenges

Financial risks:

• Rising energy costs
• Carbon pricing and environmental taxes
  
• Costs of environmental compliance
  
• Potential penalties for non-compliance
  

Risk mitigation:

• Regular environmental risk assessments
• Climate adaptation and resilience planning
  
• Diversification of infrastructure and suppliers
  
• Compliance monitoring and preventive measures
  
• Insurance coverage for environmental liabilities
  

13.2 Environmental incident response

Incident types:

• Hazardous material spills or releases
• Non-compliance with environmental regulations
  
• Significant increase in resource consumption or waste
  
• Vendor environmental violations affecting our operations
  

Response procedures:

• Immediate response: Contain and address immediate environmental threat
• Notification: Inform relevant authorities and stakeholders as required
  
• Investigation: Determine root cause and contributing factors
  
• Remediation: Take corrective action to address environmental impact
  
• Prevention: Implement measures to prevent recurrence
  
• Documentation: Record incident and response for future reference
  

Reporting:

• Internal reporting to management
• External reporting to regulatory authorities when required
  
• Communication with affected stakeholders
  
• Public disclosure when appropriate
  

Appendix B: Environmental metrics dashboard

[To be populated with actual metrics]

Carbon Emissions (CO2e):

• Total annual emissions: [TBD]
• Scope 1: [TBD]
  
• Scope 2: [TBD]
  
• Scope 3: [TBD]
  
• Per employee: [TBD]
  
• Per customer: [TBD]
  

Energy Consumption:

• Total energy use (kWh): [TBD]
• Renewable energy percentage: [TBD]
  
• Office energy per sq ft: [TBD]
  
• Cloud infrastructure efficiency: [TBD]
  

Resource Use:

• Water consumption: [TBD]
• Paper consumption: [TBD]
  
• E-waste recycled: [TBD]
  
• Recycling rate: [TBD]
  

Travel:

• Total business travel emissions: [TBD]
• Virtual meeting percentage: [TBD]
  
• Average commute distance: [TBD]
  

Target Progress:

• Progress toward carbon neutrality: [TBD]
• Goal achievement rate: [TBD]
  

OctoProctor is committed to regular reporting on these metrics. Updated environmental performance data will be published annually.