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LEGAL NOTICES

A. General Legal Notice

This legal notice (“Legal Notice”) is issued by Orbian Corporation Limited, its affiliates and subsidiaries (collectively, "Orbian") and applies to the Orbian website located at www.orbian.com (the “Site”).

1. Use of the Site Information and Content. All information and content contained on the Site is for general informational purposes only. All information and content is not to be construed as constituting tax, legal, accounting, financial or investment advice, and neither Orbian, its affiliates nor employees intend to give any such advice. Before making any decision or taking any action relating to any information on the Site, Orbian encourages you to consult professional tax, accounting and legal advisors. The Site may not be used for any purpose that is unlawful. Orbian periodically updates and changes the information and content on the Site and reserves the right to do so at any time without notice to you. Orbian reserves the right to terminate your access or use of the Site at any time.
2. Disclaimers Regarding the Site. While Orbian uses reasonable efforts to include up-to-date and accurate information on the Site, Orbian is not responsible for any errors or omissions, or for the results obtained from the use of this information. All information on the Site is provided "as is" and on an “as available” basis, with no guarantee of completeness, accuracy or timeliness or of the results obtained from the use of this information, and without warranty of any kind, express or implied, including, but not limited to warranties of performance, merchantability and fitness for a particular purpose. The use of the Site is at your own risk. Orbian disclaims any and all liability related to use of the Site or for any decision made or action taken in reliance on the information in the Site or for any consequential, special or similar damages, even if advised of the possibility of such damages.
3. Links to Third-Party Websites. Orbian does not make any representations as to the accuracy or reliability or warrant in any way, the information and/or content on any third party website that may appear on or linked to the Site. Orbian does not accept any responsibility or liability for the information and/or content on any third party website located on or referred to on the Site.
4. No Offer and No Solicitation. Neither the information nor the content on the Site constitutes or forms part of any invitation or offer for any services, including but not limited to financial services.
5. Copyright. All information and content on the Site is the copyright © of Orbian or its licensors. You are permitted to view the information and content of the Site on screen, to print copies of reasonable extracts from the Site and to save reasonable copies on your hard drive solely for the purpose of conducting any legitimate dealings that you may have with Orbian. All other copying, distribution or commercial use of any of the information and/or content of the Site is strictly forbidden.
6. Privacy. Please refer to Orbian’s Privacy Policy to understand what information we collect and how we treat this information.
7. Changes to Legal Notice. Orbian may at its sole discretion amend this Legal Notice from time to time and such amendment will be available via links on the Site. Your continued use of the Site will constitute acknowledgement of the changes and consent to abide by the modified Legal Notice.
8. Use of the Orbian System. Please refer to Orbian’s Terms and Conditions of Use of the Orbian System for specific information regarding the Orbian System.
9. Contact Us. Please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it. with any questions regarding this Legal Notice or the information and/or content of the Sites.

B. Modern Slavery Act Statement


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 world-wide, 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 world-wide database feed; 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 of our supplier clients are referred to us by high 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 on-going 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 18 April 2017.

Signed on the Board’s behalf by:

James D. Houston
Chief Legal Officer