Compliance and Ethical Commitments

Orion Trading Industrie Limited maintains a formal compliance program reflecting Hong Kong’s legal requirements and global best practices. We affirm the following commitments:

• Anti-Money Laundering: Full compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615, effective from 2012), meaning we implement strict anti-money laundering controls and reporting duties. Our procedures meet or exceed the CDD (Customer Due Diligence) standards set by law.

• Anti-Bribery and Corruption: Zero tolerance for bribery or corrupt acts. We abide by the Prevention of Bribery Ordinance (Cap. 201, enacted in 1971), prohibiting any offering or acceptance of illicit advantages. All employees and agents are expected to uphold this principle unfailingly.

• Sanctions Compliance: Adherence to all international sanctions regimes and applicable trade controls. This includes obeying United Nations sanctions, U.S. OFAC restrictions, European Union and UK sanctions programs, as well as Hong Kong’s own sanctions lists. We do not engage in business with any sanctioned parties or regions.

• Modern Slavery Prevention: Upholding the principles of the UK Modern Slavery Act 2015. We condemn all forms of forced labor and human trafficking.

• Due Diligence and Training: Implementation of rigorous KYC (Know Your Customer) and CDD processes for all clients, partners, and other counterparties, to ensure we only do business with reputable and lawful entities. We also maintain ongoing employee training programs and robust internal controls to monitor compliance, prevent misconduct, and foster an ethical corporate environment.

These commitments are integral to how we conduct our daily business, reflecting our unwavering dedication to ethical conduct and legal compliance.