This Slavery and Human trafficking statement (“Statement”) applies to all companies within Orbit360 Series LLC (“ORBIT360”) that are required to have a modern slavery statement in accordance with s54 of the UK Modern Slavery Act 2015 Act (“the Relevant Companies”).
1. OUR POLICIES AND CONTROLS
ORBIT360 and the Relevant Companies are committed to ensuring that there is no modern slavery or human trafficking in their supply chains or any part of their business.
The ORBIT360 Modern Slavery Policy reflects this commitment to acting ethically and with integrity in all ORBIT360 business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. ORBIT360 is committed to maintaining systems and processes that protect its employees and avoid any issue that can be perceived as a human rights violation. ORBIT360 implements policies related to non-discrimination, equal opportunity, and non-harassment. ORBIT360 unequivocally supports the continuation of compulsory anti-workplace harassment and anti-sexual harassment training for all employees across the ORBIT360 Group.
ORBIT360 believes that its approach to professionalism, respect and integrity has served ORBIT360 well, and continues to ensure that the rights of employees and applicants are protected around the world. ORBIT360 complies with all applicable laws and regulations on forced or child labor, and the rights of employees to organize a union. The ORBIT360 Global Code of Business Conduct, which applies to all Directors and all employees of the ORBIT360 group, is designed to ensure compliance with our core values that focus on professionalism and integrity.
2. ASSESSMENT OF MODERN SLAVERY RISK
It is ORBIT360’s view that it operates within an industry where the risk of modern slavery is low, based on the nature of the relevant products and services as well as the location of significant operations.
Notwithstanding this, ORBIT360 unequivocally supports the drive to eradicate modern slavery and fully supports the requirements of the Act. Relevant Companies continuously undertake broad “Modern Slavery Risk” reviews of their current vendor base, focusing on the vendors that make up the top 75% of spend and identified relevant third parties.
The Relevant Companies use the ORBIT360 Vendor Management Policy, in place since March 2024 to categorise vendors, based on defined criteria, into High, Medium or Low-risk categories. As part of their annual Modern Slavery Risk review, these vendors and relevant third parties are evaluated for Modern Slavery risk using the guidance published by the Walk Free Foundation (and other sources) on tackling modern slavery in supply chains. These reviews categorize relevant entities as low, moderate, or high-risk in terms of their likely involvement in and/or connection to modern slavery. The Relevant Companies are committed to sending out the Modern Slavery Statement and Policy to all Relevant Company vendors that make up the top 75% of spend, as well as the relevant third parties that have been identified.
Any vendors or relevant third parties that receive a rating of medium or higher in any annual Modern Slavery Risk review will also receive a mid-year review aimed at identifying if any further information about the vendor or relevant third party concerning modern slavery is made available after any review. The category of relevant third parties has also been expanded.
3. VENDOR DUE DILIGENCE PROCESSES
As part of ORBIT360’s initiative to identify and mitigate relevant risks, the ORBIT360 Vendor Management Policy framework comprises two main elements: (i) Due Diligence and (ii) Risk Assessment. These procedures include but are not limited to:
3.1 Due Diligence and Initial Risk Assessment
All vendors must complete a vendor profile. The Vendor Management Office performs an initial qualification of the vendor to generate the relevant risk assessments (including but not limited to factors such as information security, HR, Financial, BCP, physical security and compliance with applicable law which includes modern slavery legislation). The depth of the assessments is driven by the criticality, scope of engagement as well as the initial risk qualification. Reviews entail inquiry into legal, regulatory, and reputational public and non-public records. Each vendor is evaluated using the vendor rating scorecard as defined within the Vendor Management System).
ORBIT360 continues to review the vendor risk assessment process to ensure that it can identify vendors that may be affected by modern slavery practices.
3.2 Risk Assessment
Each vendor is evaluated and Vendor Management Office is responsible for evaluating vendors based on defined criteria and assigning vendors to an appropriate risk class. Risk ratings are reviewed when a material change in the vendor relationship is identified or if the vendor’s ability to provide services to ORBIT360 is impacted by an external or internal event. The Vendor Management Office updates the data in the Vendor Management System and a recalculation of the tier is automatically generated. If a recalculation results in the change of a risk tier, a communication is sent to the business owner and respective risk partners notifying them of the change in frequency with which the Vendor Management Office assesses the vendor relationship.
The Vendor Management Office and business units will periodically consider and review vendors in the highest risk category no less than annually. This takes into account various considerations, including but not limited to changes with the vendor, industry-wide changes (regulatory, legal, or other industry-wide changes) or changes within ORBIT360 Vendor Management Office (for example information security, BCP, KPI changes).
3.3 Complaint Reporting Procedures
Complaints or concerns related to ORBIT360 accounting, auditing, internal controls, or financial reporting can be submitted anonymously and confidentially, or with full disclosure. Our employees around the world have access to a hotline that can be easily found on the company’s internal website and is part of ORBIT360’s Global Reporting and Anti-Fraud Policy. For external parties wishing to access the hotline, they can refer to the Global Code of Business Conduct policy.
3.4 Vendor Adherence to Our Values
ORBIT360 has zero tolerance for slavery and human trafficking. To ensure all those in our supply chain and vendors comply with our values, we ensure when entering a contract with a vendor, our standard terms and conditions require vendors to adhere to all applicable laws, which will include relevant anti-slavery legislation.
Updated with effect from 20 March 2024