INTRODUCTION
Orbian does not tolerate modern slavery or human trafficking in our organization or in our supply chain. This statement sets out the steps that we have taken to identify the risk of modern slavery and human trafficking taking place within our organization or in our supply chain.
OUR GROUP STRUCTURE AND OUR BUSINESS
Orbian Corporation Limited is the parent company of Orbian Management Limited and Orbian Corp. (collectively, “Orbian”) which has offices and employees in the United Kingdom, the United States and Germany. Orbian is a Supply Chain Finance (“SCF”) company that combines a state-of-the-art SCF technology platform with a universal financing capability and secure, trust-protected payment structure and provides worldwide, multi-currency SCF solutions and services to global corporations.
OUR POLICY ON MODERN SLAVERY AND HUMAN TRAFFICKING
Orbian is adamantly opposed to modern slavery and human trafficking. We are committed to acting ethically in all our business relationships and to implementing and enforcing effective controls to eliminate, as far as possible, the risk of modern slavery and human trafficking that may take place in any part of our business or supply chains. We expect that all Orbian employees, clients, suppliers of goods or services and business partners adhere to the same high ethical standards as Orbian.
OUR DUE DILIGENCE PROCESS FOR MODERN SLAVERY AND HUMAN TRAFFICKING
Orbian takes appropriate steps to identify, evaluate and mitigate the risk of human slavery and human trafficking that may occur in our business or supply chains. As part of this objective, we perform due diligence (“Onboarding Process”) on all clients, suppliers of goods or services and business partners prior to engaging in a business relationship and subsequently thereafter as needed.
Our Onboarding Process includes, but is not limited to, the following:
- Verification of identity;
- Review of the goods or services carried out by the party;
- Review of publicly available information;
- Dow Jones Risk and Compliance check on all organizations which Orbian does business with including screening against the following: OFAC, AML, Consolidated United Nations, European Union Sanctions list and Anti-terrorism worldwide database feeds; and
- PEP (Politically Exposed Person) check for any 25%+ shareholder of a private company.
Our established Onboarding Process adequately assesses the risk of modern slavery and human trafficking before we engage in a relationship with any new client, supplier or business partner and provides Orbian the ability to monitor and audit the party following engagement.
Our Onboarding Process is documented within our policies and procedures which are reviewed and updated by our Legal Department on an annual basis. Through our most recent review of our Onboarding Process, we determined that we are in a low-risk industry characterized by high value work activity, as all our supplier clients are referred to us by creditworthy buyer clients and appropriately vetted.
TRAINING
To ensure employees involved with new business relationships or monitoring existing business relationships have a high level of understanding of the risks of modern slavery and human trafficking as it relates to our business and supply chain, we provide initial and ongoing training on all applicable policies and procedures including the Onboarding Process.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Orbian’s modern slavery and human trafficking statement as approved by the Board on 1 May 2023 for the fiscal year ending 31 December 2022.
Signed on the Board’s behalf by:
Patrick Clark
Chief Legal Officer