Modern slavery & human trafficking statement

Our commitment

Orchard28 has a zero-tolerance approach to modern slavery, servitude, forced or compulsory labour, and human trafficking, in any part of our business or supply chain. This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015, the California Transparency in Supply Chains Act of 2010, and the Australian Modern Slavery Act 2018 (Cth), and describes the steps we take to ensure slavery and trafficking have no place in what we do.

Our business and structure

Orchard28 builds and operates a platform of autonomous AI agents that shop, book and transact on behalf of consumers and businesses. We are headquartered in Limerick, Ireland, with offices in Palo Alto, California and Melbourne, Australia. Our workforce is made up of directly employed staff in skilled technology, design and operations roles across those three locations.

Our supply chain

As a software company, our supply chain is comparatively short and low-risk. Our principal suppliers are:

• cloud infrastructure and data-centre providers;
• software, payment-network and professional-services vendors;
• office landlords, facilities services and IT-hardware suppliers.

We recognise that risk is never zero: hardware manufacturing, facilities services (cleaning, catering, security) and outsourced customer-support services are sectors with documented exposure to labour exploitation, and we treat suppliers in those categories with heightened scrutiny.

Policies and contractual standards

• Our supplier code of conduct requires compliance with all applicable labour laws, prohibits forced, bonded and child labour, and requires that workers are free to leave employment and retain their own identity documents.
• Supplier contracts include anti-slavery clauses giving us audit rights and the right to terminate immediately for breach.
• Our whistleblowing policy lets staff and suppliers’ workers raise concerns confidentially and without retaliation.
• Recruitment is direct or through vetted agencies; we never charge workers recruitment fees and verify the same of our agencies.

Due diligence and risk assessment

Before onboarding, suppliers are screened against our code of conduct, with risk weighted by sector and geography. Higher-risk suppliers are asked to evidence their own modern-slavery controls, and we review our supplier base annually. Where we find a problem, our first response is remediation with the supplier; where remediation fails or the breach is egregious, we exit the relationship.

Training and awareness

Staff who select or manage suppliers receive training on recognising the signs of modern slavery and on our escalation process. All staff are made aware of this statement and the whistleblowing channel during onboarding.

Measuring effectiveness

We track and review annually:

• the proportion of suppliers who have accepted our code of conduct;
• the number of concerns raised and their time to resolution;
• completion rates for supplier-facing staff training.

Reporting a concern

If you suspect modern slavery or human trafficking in connection with Orchard28 or any of our suppliers, contact us at hello@orchard28.com. Reports can be made anonymously and are investigated promptly. If someone is in immediate danger, contact local law enforcement first.

Approval

This statement was approved by the board of directors of Orchard28 Limited and is reviewed and republished annually. It applies to Orchard28 Limited and its subsidiaries operating in the United States and Australia.