Modern Slavery Statement
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Introduction
Al Banyan Tree is committed to upholding the highest standards of ethics and integrity in our business operations. We have a zero-tolerance approach to modern slavery and human trafficking in any form 26. Although Hong Kong law may not mandate a formal modern slavery statement for our company, we choose to make this statement voluntarily in alignment with global best practices (such as the UK Modern Slavery Act 2015) and to meet the expectations of our international clients who value supply chain transparency and human rights. This statement sets out the steps we take to ensure that slavery and human trafficking do not occur in our business or supply chains.
Our Business and Supply Chain
Al Banyan Tree is a Software-as-a-Service company providing commodity market analytics and consulting services globally. Our core business involves delivering digital reports, data analysis, and expert insights through an online platform. We operate primarily out of Hong Kong, with clients and partners worldwide. The nature of our business model – centered on technology and professional services – means that the risk of modern slavery in our direct operations is low 27. We do not produce physical goods, and we do not engage in manufacturing or large-scale logistics. Our workforce consists of skilled professionals (such as analysts, engineers, and consultants) who are directly employed or contracted in jurisdictions with strong labor protections.
Our supply chain is relatively straightforward and primarily involves procurement of software, IT infrastructure, and professional services. For example, we rely on data center or cloud service providers for hosting our platform, software vendors for analytics tools, office suppliers for equipment, and occasionally consulting or research subcontractors for specialized expertise. These suppliers are typically reputable firms in the technology or professional services sectors, often headquartered in lowrisk countries for labor exploitation. We do not have an extensive network of suppliers in industries known for labor abuses, and none of our current suppliers are known to operate in areas or sectors with a high incidence of forced labor 27. Nonetheless, we remain vigilant. We recognize that modern slavery can occur in any country and industry, and hidden risks might exist (for example, in the sourcing of electronics or other equipment we use).
Our Policies and Commitments
We have implemented internal policies that reflect our commitment to ethical business conduct and human rights:
Risk Assessment and Management
Given our industry and supply chain, our assessment is that the overall risk of modern slavery connected to our business is low 29. However, we do not become complacent:
Training and Awareness
We believe awareness is key to prevention. We provide training to our staff – particularly those involved in procurement or HR – about the risks of modern slavery and how to spot red flags. This training covers: the definition of modern slavery and human trafficking, industries and signs where it might occur, our company policies, and how to report concerns. New employees learn about our values and policies during induction. Procurement managers are instructed to be mindful of labor standards when selecting vendors. Although we are a smaller company, we foster a culture where ethical concerns can be openly discussed.
Continuous Improvement
Our commitment to combating modern slavery is ongoing. Each year (or on a regular review cycle), we will:
Statement Approval
This Modern Slavery Statement is approved by Al Banyan Tree’s senior management and, if applicable, Board of Directors. We affirm that we will make this statement available publicly on our website footer, and we will refresh it as required (at least annually, if not more frequently, to reflect updates in our efforts).
We understand that modern slavery is a heinous crime and a violation of fundamental human rights, and we are committed to ensuring it has no place in or around Al Banyan Tree. In line with our zerotolerance stance, if any evidence of modern slavery were to be found, we would act immediately to address it, report it to the proper authorities, and support any victims involved 26. Our ethos is one of continuous vigilance and improvement, and we strive to be a responsible business that our clients, employees, and partners can trust.
Contact and Feedback: If you have questions about this statement or wish to report a concern regarding modern slavery or human trafficking related to our company, please contact [compliance@companydomain.com]. All bona fide communications will be taken seriously and handled with appropriate confidentiality.
Al Banyan Tree is committed to upholding the highest standards of ethics and integrity in our business operations. We have a zero-tolerance approach to modern slavery and human trafficking in any form 26. Although Hong Kong law may not mandate a formal modern slavery statement for our company, we choose to make this statement voluntarily in alignment with global best practices (such as the UK Modern Slavery Act 2015) and to meet the expectations of our international clients who value supply chain transparency and human rights. This statement sets out the steps we take to ensure that slavery and human trafficking do not occur in our business or supply chains.
Our Business and Supply Chain
Al Banyan Tree is a Software-as-a-Service company providing commodity market analytics and consulting services globally. Our core business involves delivering digital reports, data analysis, and expert insights through an online platform. We operate primarily out of Hong Kong, with clients and partners worldwide. The nature of our business model – centered on technology and professional services – means that the risk of modern slavery in our direct operations is low 27. We do not produce physical goods, and we do not engage in manufacturing or large-scale logistics. Our workforce consists of skilled professionals (such as analysts, engineers, and consultants) who are directly employed or contracted in jurisdictions with strong labor protections.
Our supply chain is relatively straightforward and primarily involves procurement of software, IT infrastructure, and professional services. For example, we rely on data center or cloud service providers for hosting our platform, software vendors for analytics tools, office suppliers for equipment, and occasionally consulting or research subcontractors for specialized expertise. These suppliers are typically reputable firms in the technology or professional services sectors, often headquartered in lowrisk countries for labor exploitation. We do not have an extensive network of suppliers in industries known for labor abuses, and none of our current suppliers are known to operate in areas or sectors with a high incidence of forced labor 27. Nonetheless, we remain vigilant. We recognize that modern slavery can occur in any country and industry, and hidden risks might exist (for example, in the sourcing of electronics or other equipment we use).
Our Policies and Commitments
We have implemented internal policies that reflect our commitment to ethical business conduct and human rights:
- Code of Conduct: Our company Code of Conduct explicitly prohibits any form of forced labor, child labor, human trafficking, or exploitation. It commits us to fair employment practices, including voluntary employment, fair wages, and safe working conditions. All employees and officers are expected to uphold these values, and compliance is a condition of employment.
- Supplier Code of Ethics: We extend our stance to our suppliers via a Supplier Code of Ethics (or equivalent contractual clauses). When engaging new suppliers or renewing contracts, we communicate our expectation that they comply with all applicable labor and human rights laws, including prohibitions on modern slavery. We reserve the right to audit or request information from key suppliers regarding their labor practices. Suppliers found to be in violation of antislavery principles will face consequences, up to termination of the business relationship 28.
- Whistleblower Policy: We maintain a whistleblower policy that encourages employees to report any unethical conduct or concerns, including any suspicion of forced labor or trafficking, without fear of retaliation. Reports can be made confidentially to senior management or the board, and each report is investigated.
- Due Diligence: In our onboarding of suppliers, especially those that might present higher risk (for instance, if we ever engage an outsourcing firm in a country with weaker labor protections), we conduct due diligence. This may involve inquiries into the supplier’s labor standards, checking for any past violations or controversies, and ensuring there are contractual commitments to ethical practices. We prioritize working with suppliers who themselves have made commitments to combat modern slavery.
Risk Assessment and Management
Given our industry and supply chain, our assessment is that the overall risk of modern slavery connected to our business is low 29. However, we do not become complacent:
- We periodically review our supplier list to identify any that operate in higher-risk regions or industries. If identified, those relationships are reviewed more closely. Thus far, our major suppliers (cloud hosting, software, etc.) are large multinational companies with their own strict anti-slavery policies.
- For any future expansion into regions or partnerships where the risk might be higher, we plan to incorporate specific risk assessment steps. For example, if we were to outsource certain operations to a third party in a region with prevalent labor issues, we would conduct a thorough audit of that third party’s labor practices and require adherence to our standards.
- Internally, we ensure all our employees are legally employed under fair terms. We conduct reference and background checks in recruitment to ensure candidates are joining willingly and have the legal right to work. We also ensure no part of our business operations (including any cleaning, security, or maintenance services we might contract for our offices) engages workers under coercion or exploitative conditions.
Training and Awareness
We believe awareness is key to prevention. We provide training to our staff – particularly those involved in procurement or HR – about the risks of modern slavery and how to spot red flags. This training covers: the definition of modern slavery and human trafficking, industries and signs where it might occur, our company policies, and how to report concerns. New employees learn about our values and policies during induction. Procurement managers are instructed to be mindful of labor standards when selecting vendors. Although we are a smaller company, we foster a culture where ethical concerns can be openly discussed.
Continuous Improvement
Our commitment to combating modern slavery is ongoing. Each year (or on a regular review cycle), we will:
- Reassess our policies and update them if needed to strengthen protections.
- Review any reports or incidents (if any occur) to learn from them and improve our processes.
- Set goals if appropriate, such as ensuring 100% of key suppliers affirm our Supplier Code of Ethics, or enhancing our due diligence questionnaires.
- Stay informed about global and local developments in anti-slavery efforts, including any changes in laws (e.g., if Hong Kong, the UK, or other jurisdictions where we operate introduce new requirements). We are aware that legislation and best practices evolve, and we aim to meet or exceed the current standards.
Statement Approval
This Modern Slavery Statement is approved by Al Banyan Tree’s senior management and, if applicable, Board of Directors. We affirm that we will make this statement available publicly on our website footer, and we will refresh it as required (at least annually, if not more frequently, to reflect updates in our efforts).
We understand that modern slavery is a heinous crime and a violation of fundamental human rights, and we are committed to ensuring it has no place in or around Al Banyan Tree. In line with our zerotolerance stance, if any evidence of modern slavery were to be found, we would act immediately to address it, report it to the proper authorities, and support any victims involved 26. Our ethos is one of continuous vigilance and improvement, and we strive to be a responsible business that our clients, employees, and partners can trust.
Contact and Feedback: If you have questions about this statement or wish to report a concern regarding modern slavery or human trafficking related to our company, please contact [compliance@companydomain.com]. All bona fide communications will be taken seriously and handled with appropriate confidentiality.