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 websites located at orbian.com, orbiansupplier.com, orbianclient.com and any other Orbian websites maintained by Orbian now or in the future (the “Orbian Websites”).
- Use of Orbian Websites Information and Content. All information and content contained on the Orbian Websites is for general informational purposes only. All information and content are 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 Orbian Websites, Orbian encourages you to consult professional tax, accounting and legal advisors. The Orbian Websites may not be used for any purpose that is unlawful. Orbian periodically updates and changes the information and content on the Orbian Websites 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 Orbian Websites at any time.
- Disclaimers Regarding the Orbian Websites. While Orbian uses reasonable efforts to include up-to-date and accurate information on the Orbian Websites, Orbian is not responsible for any errors or omissions, or for the results obtained from the use of this information. All information on the Orbian Websites 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 Orbian Websites is at your own risk. Orbian disclaims all liability related to use of the Orbian Websites or for any decision made or action taken in reliance on the information in or on the Orbian Websites or for any consequential, special or similar damages, even if advised of the possibility of such damages.
- 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 websites that may appear on or be linked to the Orbian Websites. Orbian does not accept any responsibility or liability for the information and/or content on any third-party websites located on or referred to on the Orbian Websites.
- No Offer and No Solicitation. Neither the information nor the content on the Orbian Websites constitutes or forms part of any invitation or offer for any services, including but not limited to financial services.
- Copyright. All information and content on the Orbian Websites is the copyright © of Orbian or its licensors. You are permitted to view the information and content of the Orbian Websites on screen, to print copies of reasonable extracts from the Orbian Websites and to save reasonable copies on your hard drive solely for 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 Orbian Websites is strictly forbidden.
- 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 Orbian Websites. Your continued use of the Orbian Websites will constitute acknowledgement of the changes and consent to abide by the modified Legal Notice.
- 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.
- Contact Us. Please contact us at email@example.com with any questions regarding this Legal Notice or the information and/or content of the Orbian Websites.
B. Underaged Users
Orbian does not offer or anticipate use of any Orbian Websites by anyone under the age of 21.
C. Modern Slavery Act Statement
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 high creditworthy buyer clients and appropriately vetted.
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 26 October 2017.
Signed on the Board’s behalf by:
James D. Houston
Chief Legal Officer