Effective date: September 1, 2026

InterStock teaches minors, most of them on their own school campuses. Partner schools trust us with their students and parents trust us with their children. This policy sets out the standards we hold our instructors and staff to, what students can expect, and what to do if something is wrong.

It applies to every InterStock member, employee, instructor, intern, and contractor, in every program — in schools, in private instruction, and online.

1. Screening and vetting

Nobody teaches for InterStock without first being vetted. Before an instructor is placed with students we verify identity and work history, check references, and conduct a criminal background check.

Where a partner school or district requires Level 2 screening under sections 1012.32 and 1012.465 of the Florida Statutes — the fingerprint-based standard that applies to contracted personnel with access to students on school grounds — that screening is completed and cleared before the instructor sets foot on campus. Where a school’s own requirements are stricter than ours, the school’s requirements govern.

2. Supervision and the two-adult standard

• Sessions in schools are held in regular classrooms during or adjacent to the school day, in spaces the school controls, with doors open or windows unobstructed.
• An InterStock instructor is never alone with a single student behind a closed door. If a student needs to speak privately, the conversation happens in an open or observable space, and a school staff member is made aware.
• Instructors sign in through the school’s visitor system and wear identification as the school requires.
• InterStock staff do not transport students, in any vehicle, at any time.
• InterStock staff do not meet students off campus and do not visit a student’s home.

3. Private one-to-one instruction

Our private program is individual instruction, so it needs its own rules. Every private session with a student under 18 must meet at least one of these conditions:

• a parent or guardian is present or within sight and earshot;
• the session takes place in a public or semi-public space such as a library or a school room with visibility; or
• the session is conducted online with the parent’s knowledge, from an account the parent can access, on a platform the parent has approved.

Parents are welcome to observe any private session, at any time, without arranging it in advance.

4. Communication boundaries

• Communication with a student under 18 goes through school channels or through the parent. Instructors use InterStock email accounts, not personal ones.
• InterStock staff do not exchange personal phone numbers with students, and do not communicate with students through personal social media accounts, direct messages, disappearing-message apps, or gaming platforms.
• Instructors do not follow, friend, or privately message students on social media.
• Where a group chat or platform is used for a class, a parent or school staff member has access to it.
• Nothing here stops a student from talking to an instructor — it means those conversations stay visible to the adults responsible for that student.

5. Conduct that is never acceptable

The following result in immediate removal from all programs and, where the conduct may be criminal, a report to law enforcement:

• any sexual, romantic, or grooming conduct toward a student, including sexualized comments or content;
• physical discipline, rough handling, or any use of force other than to prevent immediate harm;
• verbal abuse, humiliation, threats, or bullying;
• discrimination or harassment of a student;
• providing a student with alcohol, tobacco, vaping products, drugs, or anything else unlawful for a minor;
• photographing or recording a student in violation of our Photo and Media Release;
• soliciting money from a student, involving a student in a personal financial arrangement, or accepting anything of value from a student or family beyond the published program fee;
• giving a student individualized investment advice, or helping a student open or operate a real brokerage account. Our teaching uses simulation only.

6. Reporting suspected abuse or neglect

Florida law requires any person who knows or has reasonable cause to suspect that a child is abused, abandoned, or neglected to report it immediately to the Florida Abuse Hotline. This duty is personal, it is not satisfied by telling a supervisor, and InterStock will never ask anyone to route a concern internally first or to wait for permission.

Florida Abuse Hotline: 1-800-962-2873 (1-800-96-ABUSE) — 24 hours a day, every day. Online: reportabuse.myflfamilies.com

If a child is in immediate danger, call 911 first.

Our staff are told this in training and reminded of it in writing. After a report is made, we also notify the partner school in line with its own safeguarding procedures, and we cooperate fully with any investigation.

7. Raising a concern about InterStock

If a student, parent, or school staff member has a concern about the conduct of anyone representing InterStock, contact us directly at info@interstockusa.com, or raise it with the school. Concerns go straight to InterStock’s leadership.

What we commit to:

• we acknowledge every concern within one business day;
• where a concern involves a child’s safety, the person concerned is removed from contact with students while it is reviewed — this is not a finding of wrongdoing, it is what a serious process looks like;
• we tell the person who raised it what we did;
• we do not retaliate against anyone who raises a concern in good faith, and we do not ask anyone to sign anything that would stop them from reporting to an authority.

You never need our permission to contact the Abuse Hotline, law enforcement, or your school. Nothing in this policy or any agreement with us limits that.

8. What we expect from students

Students are expected to attend, participate, treat instructors and classmates with respect, follow the host school’s rules while on its campus, keep their own and their classmates’ work honest, and avoid conduct that endangers or seriously disrupts others. A student may be removed from a program for conduct that puts others at risk; if that happens, we explain the decision to the parent and the school.

9. Review

We review this policy at least once a year and whenever a partner school’s requirements change. Partner schools may request our current screening documentation and insurance certificates at any time.

10. Contact

InterStock LLC — Miami, Florida. Email: info@interstockusa.com