2021 Modern Slavery Statement

This statement addresses the California Transparency in Supply Chains Act (2010), the UK Modern Slavery Act (2015) and the Australia Modern Slavery Act 2018 (Cth) and sets out the steps Orveon Global Holdings Limited and its subsidiaries (collectively hereafter “Orveon Global”) have taken and will take to prevent modern slavery and human trafficking in our business operations and supply chain. This statement describes the actions planned for FY2022 and beyond.

Orveon Global is committed to being responsible in its global business practices and takes steps with its product suppliers to ensure compliance with its standards of conduct as set forth in Orveon Global’s Supplier Code of Conduct and all applicable laws. Orveon Global has made the following efforts to ensure compliance by its product suppliers:

•    Certification: Orveon Global requires all product suppliers to confirm in writing that they understand and will adhere to the Orveon Global’s Supplier Code of Conduct. The Orveon Global Supplier Code of Conduct specifically requires product suppliers to certify that all goods are manufactured in compliance with the wage and hour, slavery and human trafficking laws of the country of manufacture and without the use of children or prison, indentured, exploited, bonded, forced or slave labor.

•    Training: The Orveon Global’s global procurement and supply chain management teams are trained on the Orveon Global Supplier Code of Conduct and how to identify possible indicators of human trafficking and slavery in the supply chain to ensure that no risk factors are present.

•    Audits & Verification: Orveon Global’s global procurement and supply chain management teams have the ability to audit product suppliers either itself or conduct an independent third party assessment, including conducting on-site inspections to assess factory conditions and ensure that management is not in violation of slavery and human-trafficking laws.

•    Accountability: Orveon Global will not do business with any supplier who will not agree to comply with the Orveon Global’s Supplier Code of Conduct or its other accountability standards. Orveon Global will issue a warning to any supplier, employee or contractor who willfully or knowingly fails to comply with these standards and, if the supplier, employee, or contractor fails to take prompt corrective action, Orveon Global will enforce disciplinary action including termination of the business relationship.

Orveon Global is dedicated to conducting its business with integrity and the highest standard of ethics and seeks the same level of integrity and ethical standards with its vendor and supplier partners. Orveon Global will continue to assess all risks and opportunities to ensure that its approach will prevent any injustice or violation of human rights within its supply chain.

Pascal Houdayer

Chief Executive Officer

Orveon Global

December 23, 2021