Modern Slavery Statement

1. About this Statement

This statement is published by Orbit Technologies Limited (trading as Orbit Commerce) in the spirit of section 54 of the Modern Slavery Act 2015 (the “Act”). Our annual turnover is below the £36 million statutory threshold, so we are not currently legally required to publish a statement. We publish one voluntarily because we consider it good practice and because our customers, partners, and suppliers increasingly expect it.

This statement sets out the steps we have taken, and intend to take, to identify and prevent modern slavery, human trafficking, forced labour, and child labour in our own operations and our supply chain. It is approved by the directors of Orbit Technologies Limited.

2. Our Business

Orbit Commerce is an ecommerce platform that lets businesses build, host, and operate online stores. We are headquartered in Northampton, England, and operate the platform through cloud infrastructure provided by tier-1 hosting partners. Our workforce is small, predominantly office-based, and located in the United Kingdom. Our suppliers are mostly software and cloud-service providers, professional services firms, and office support providers.

3. Our Risk Assessment

Given the nature of our business, we assess our direct modern slavery risk as low. Our highest-risk areas are:

• physical-goods Suppliers who sell through Vendor Storefronts on the platform (we are not the seller but we operate the connecting platform);
• outsourced or low-paid services we procure, such as office cleaning, security, or offshore support contractors;
• hardware procurement (laptops and peripherals) where extraction or assembly may involve higher-risk regions.

4. Our Policies

We maintain the following policies that contribute to addressing modern slavery risk:

• Acceptable Use Policy — prohibits using the platform to facilitate or promote modern slavery, human trafficking, or forced labour;
• Supplier Program Agreement — requires Suppliers to comply with the Act and use reasonable due diligence in their direct supply chain;
• Anti-Bribery and Corruption Policy — covers integrity expectations for partners and suppliers;
• Internal whistleblowing and grievance procedures that let staff raise modern slavery concerns confidentially without fear of reprisal.

5. Due Diligence

For our own staff:

• we verify right-to-work documents before employment begins, in line with Home Office guidance;
• we pay at or above the National Living Wage and do not engage in deductions that push pay below the threshold;
• we do not use unpaid trial shifts, retain identity documents, or impose recruitment fees on candidates.

For Suppliers and Partners on the platform:

• modern slavery clauses in our Supplier Program Agreement;
• a reporting route at support@orbitcommerce.net for staff, partners, customers, and members of the public to report concerns;
• action under our enforcement framework where a Supplier or Partner is reasonably suspected of breaching the Act, including suspension, removal of products, and referral to the relevant authorities where appropriate.

6. Training and Awareness

We include modern slavery awareness in our onboarding for new staff and in our annual compliance training, focused on recognising the indicators of modern slavery and the reporting routes available.

7. Measuring Effectiveness

Because our direct exposure is low, we have not yet adopted formal key performance indicators. We track and review: the number of modern slavery concerns reported, the outcome of those reports, completion rates for compliance training, and any audit findings raised by major customers in respect of modern slavery. We will introduce formal KPIs as our business scales.

8. Future Steps

In the next financial year we plan to:

• refresh our supplier onboarding questionnaire to include explicit modern slavery questions for higher-risk vendor categories;
• publish modern slavery reporting guidance in the help centre for Vendors and Suppliers;
• review this statement annually and republish with updates.

9. Approval

This statement is approved by the board of directors of Orbit Technologies Limited and signed by a director on the board’s behalf. A digital copy with director signature is available on request from support@orbitcommerce.net.

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