Modern Slavery & Human Trafficking Statement

Orno LLC is committed to conducting business ethically, transparently, and in a manner that respects the fundamental human rights and dignity of all persons. We unequivocally condemn slavery, servitude, forced or compulsory labor, human trafficking, and all forms of exploitation as defined by international law and domestic legislation. We recognize that modern slavery is a grave violation of human rights that persists across global supply chains, including within the technology, logistics, merchandise, and content-creation sectors in which we operate.

This Statement sets forth the steps Orno has taken, and continues to take, to ensure that slavery and human trafficking are not occurring within our own business operations or in any part of our supply chain. We acknowledge that no supply chain is immune from the risk of modern slavery, and we are committed to continuous improvement in our due diligence, transparency, and remediation processes.

Orno expects every entity within its supply chain, creator network, and brand-partner ecosystem to share this commitment and to operate in accordance with the principles articulated herein. Failure to do so may result in termination of the commercial relationship and, where appropriate, reporting to competent authorities.

Orno LLC is a Florida limited liability company and wholly-owned subsidiary of Luminary Group Holdings LLC, headquartered at 555 Winderley Place, Maitland, FL 32751, United States. Orno operates a technology platform facilitating sponsored-content partnerships between digital creators (streamers, influencers, and content producers) and consumer brands, with ancillary services including product fulfillment, logistics coordination, merchandise sourcing, and campaign management.

Our supply chain encompasses the following principal categories of suppliers and service providers, each presenting distinct modern-slavery risk profiles:

For purposes of this Statement, the following terms shall have the meanings ascribed below, consistent with their definitions under the Modern Slavery Act 2015, the Palermo Protocol, and ILO Convention No. 29:

Orno conducts annual modern-slavery risk assessments across its operations and supply chain, utilizing a methodology informed by the UN Guiding Principles on Business and Human Rights (UNGPs), the ILO Indicators of Forced Labour, and the Global Slavery Index. The risk assessment evaluates the following dimensions:

• Country risk: Prevalence of modern slavery per the Global Slavery Index; rule-of-law indicators; labor-inspection capacity and enforcement;
• Sector risk: Labor intensity; prevalence of migrant, temporary, or informal workers; multi-tier subcontracting; presence of vulnerable populations;
• Transaction risk: Value and complexity of the supply relationship; degree of visibility into sub-tier suppliers; pricing pressure that may incentivize labor exploitation;
• Entity risk: Supplier governance maturity; existence of worker-voice mechanisms; history of labor violations or adverse media.

Orno maintains and enforces the following policies and procedures to prevent modern slavery and human trafficking within its operations and supply chain:

Orno’s modern-slavery due diligence program is structured in accordance with the six-step OECD Due Diligence Guidance for Responsible Business Conduct (2018) and the UN Guiding Principles on Business and Human Rights. The program encompasses the following elements:

• Supplier mapping: Identification and documentation of first-tier and, where practicable, sub-tier suppliers, including geographic locations, labor profiles, and product/service categories;
• Risk-based screening: Prioritization of suppliers for enhanced due diligence based on the risk-assessment methodology described in Section 5;
• Questionnaires and self-assessments: Administration of detailed modern-slavery questionnaires to high-risk and material suppliers, covering labor practices, recruitment methods, subcontracting arrangements, and grievance mechanisms;
• Audits and inspections: Commissioning of independent, unannounced audits of high-risk suppliers, conducted by qualified social-compliance auditors using recognized frameworks (SMETA, SA8000, or equivalent);
• Worker-voice mechanisms: Where feasible, engagement of worker-voice tools (anonymous surveys, worker hotlines, or technology-enabled feedback platforms) to obtain direct input from workers in supplier facilities;
• Continuous monitoring: Ongoing monitoring of adverse media, government advisories (e.g., U.S. Department of Labor ILAB reports, Withhold Release Orders), and industry intelligence for indicators of forced labor in the supply chain.

Orno provides mandatory modern-slavery awareness training to all employees, with enhanced training for personnel in procurement, supply-chain management, human resources, and operations functions. Training is delivered upon onboarding and refreshed annually, covering:

• Legal definitions of slavery, servitude, forced labor, and human trafficking under applicable legislation;
• ILO Indicators of Forced Labour (11 indicators including abuse of vulnerability, deception, restriction of movement, isolation, physical/sexual violence, intimidation, retention of documents, withholding of wages, debt bondage, abusive working/living conditions, and excessive overtime);
• Red flags and warning signs in supplier relationships, logistics operations, and recruitment practices;
• Reporting obligations and available grievance mechanisms;
• Case studies illustrating modern slavery in technology, logistics, and manufacturing supply chains; and
• Orno’s specific policies, procedures, and expectations regarding supply-chain transparency.

Training completion rates, comprehension assessments, and feedback are tracked and reported to the Board of Managers as part of the annual modern-slavery effectiveness review.

Orno adheres to the “Employer Pays Principle” endorsed by the Institute for Human Rights and Business, which provides that no worker should pay for a job—the costs of recruitment should be borne by the employer, not the worker. Specifically:

• No recruitment fees: Orno does not charge, and requires its suppliers not to charge, recruitment fees or related costs to workers, whether directly or through labor-recruitment agencies, in accordance with ILO General Principles and Operational Guidelines for Fair Recruitment (2019);
• Right-to-work verification: All employees and contractors undergo lawful right-to-work verification in compliance with applicable immigration law, without retention of original identity documents;
• Transparent terms: Employment terms, compensation, working hours, benefits, and termination conditions are communicated clearly, in writing, and in a language understood by the worker, prior to the commencement of employment;
• Freedom to terminate: All workers retain the unrestricted right to terminate their employment upon reasonable notice without penalty, coercion, or forfeiture of earned wages;
• Agency oversight: Where recruitment agencies are used, Orno conducts due diligence on such agencies and requires contractual commitments prohibiting the charging of fees to workers and the use of deceptive recruitment practices.

Where instances or credible indicators of modern slavery are identified within Orno’s operations or supply chain, Orno shall take prompt, victim-centered remedial action in accordance with the UNGPs’ Pillar III (Access to Remedy) and the Dhaka Principles for Migration with Dignity. Remediation measures may include:

• Immediate engagement with the affected supplier to understand the nature, scope, and root causes of the violation;
• Development of a time-bound corrective action plan with measurable milestones and independent verification;
• Provision of remedy to affected workers, which may include repayment of recruitment fees, back-payment of wages, restoration of identity documents, safe repatriation, and access to support services;
• Engagement of specialist NGOs, trade unions, or human-rights organizations to provide victim support;
• Reporting to competent law-enforcement authorities where criminal conduct is suspected;
• Suspension or termination of the commercial relationship where the supplier fails to implement corrective action within the prescribed timeframe or demonstrates unwillingness to remediate.

Orno recognizes that immediate termination of a supplier relationship, while sometimes necessary, may in certain circumstances cause further harm to affected workers. Accordingly, remediation decisions shall be guided by the principle of “do no harm” and shall prioritize the safety and wellbeing of victims above commercial considerations.

Orno maintains accessible, confidential, and effective grievance mechanisms through which workers, community members, and other stakeholders may report concerns regarding modern slavery, forced labor, or human trafficking without fear of retaliation. Reports may be submitted through the following channels:

All reports are taken seriously, investigated promptly, and treated with appropriate confidentiality. Orno prohibits retaliation against any person who makes a good-faith report of suspected modern slavery, regardless of whether the report is ultimately substantiated.

Orno tracks and reports on the following key performance indicators (KPIs) to measure the effectiveness of its modern-slavery program and drive continuous improvement:

KPI data is compiled quarterly and presented to the Board of Managers as part of the annual modern-slavery review. Targets are set annually and calibrated to reflect increasing maturity of the compliance program and evolving best practices.

This Statement has been reviewed and approved by the Board of Managers of Luminary Group Holdings LLC, acting in its capacity as the sole member and governing authority of Orno LLC. In accordance with Section 54(6) of the Modern Slavery Act 2015 and analogous best-practice guidance, this Statement is signed by a director and published on Orno’s website with a direct link from the homepage.

This Statement shall be reviewed, updated, and re-approved annually, no later than six (6) months following the end of each financial year, to reflect (a) changes in Orno’s business structure, operations, or supply chain; (b) developments in applicable legislation and enforcement guidance; (c) findings from risk assessments, audits, and grievance mechanisms; and (d) evolving best practices in modern-slavery due diligence and transparency reporting.

Prior versions of this Statement shall be archived and remain accessible on request. Each annual revision shall identify material changes from the preceding version and report on progress against previously stated commitments and KPIs.

For questions, concerns, or reports relating to modern slavery and human trafficking in Orno’s operations or supply chain, please contact:

This Statement covers the financial year ending December 31, 2026 and is published voluntarily by Orno LLC as a demonstration of our commitment to ethical business practices and supply-chain transparency. The Board of Managers of Luminary Group Holdings LLC approved this Statement on January 1, 2026.