Modern Slavery Statement

1. Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach and are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing procedures to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

2. Structure of the organisation

OrbExperts provides a broad range of business and technical skills courses to public and private sector clients. In order to provide services to clients, we work with a range of suppliers including but not limited to professional service firms, utility suppliers, IT vendors, consultants, industry business partners and technology platform providers.

3. Policies and due diligence

As part of our efforts to combat, monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have implemented and adopted the following due diligence procedures:

• the OrbExperts Modern Slavery Policy;
• our Whistleblowing Policy;
• supplier questionnaires and self-declarations.

We also make sure our suppliers are aware of our policies and adhere to the same high standards. These policies are developed and reviewed with the involvement of the relevant functions, in particular legal, HR, finance and IT.

Suppliers may be required to complete questionnaires setting out their compliance with all applicable legislation and their own measures against slavery and human trafficking. Our standard contracts include appropriate provisions requiring compliance with applicable legal requirements.

Where the risk profile or other circumstances make it necessary, we may carry out periodic audits of individual suppliers or request additional evidence of compliance.

Our procedures are designed to:

• establish and assess areas of potential risk in our business and supply chains;
• monitor identified and potential risk areas in our business and supply chains;
• reduce the risk of slavery and human trafficking occurring in our business and supply chains; and
• provide adequate protection for people who report a possible violation in good faith.

4. Risk and compliance

Given the nature of the services we provide and the location and composition of our suppliers and business partners, we do not currently consider that we operate predominantly in sectors or regions with a particularly high risk of modern slavery or human trafficking.

Nevertheless, we expect all suppliers, contractors and business partners to comply with our Modern Slavery Policy and with all applicable legal requirements.

We do not tolerate slavery or human trafficking within our supply chains. Where there are indications that a supplier or business partner has breached our requirements or the corresponding legal provisions, we will investigate the matter promptly and take appropriate action.

Depending on the nature and severity of the breach, this may include requiring immediate corrective action, introducing additional control measures, suspending the relationship, or terminating the business relationship.

5. Training

We raise awareness among our employees of the risks of modern slavery and human trafficking, and we invest continuously in appropriate training and information measures.

The aim is to enable our employees to recognise possible indicators and risks within our business and our supply chains and to report them appropriately.

Training is generally provided annually and is adapted as necessary to reflect new legal requirements, findings and developments, so that awareness of potential risks is maintained over time.

6. Further actions

As part of our ongoing commitment to preventing slavery and human trafficking within our business and our supply chains, we review our related policies and procedures regularly.

In doing so, we assess whether the existing measures remain effective and appropriate and whether adjustments are required as a result of changed legal requirements, new risks or practical experience.