ORN/Responsibility / Compliance

The highest standard, in every jurisdiction we serve.

ORN operates in forty-plus countries. Compliance is the price of admission to that work — and the foundation under every promise NX/OS makes to a traveller, a partner, or a regulator.

01 / The framework

Programmes built for global scale.

ORN maintains a tier-one compliance programme spanning anti-bribery and corruption, sanctions and export controls, anti-money-laundering, data protection, consumer protection, competition, and tax integrity.

The programme is owned by the Group General Counsel and overseen by the Audit & Risk Committee of the Board. It is independently reviewed annually.

A

Anti-bribery & corruption

Zero tolerance. Aligned with the UK Bribery Act, US FCPA, OECD Convention.

B

Sanctions & export controls

Real-time screening of partners, payments, and itineraries against global lists.

C

Anti-money-laundering

Risk-based KYC, transaction monitoring, suspicious-activity reporting.

D

Data protection

GDPR, CCPA, India DPDP, and equivalents. Privacy by design in NX/OS.

E

Consumer protection

Clear pricing, fair terms, and transparent dispute resolution at point of sale.

F

Tax integrity

Tax paid where value is created. No artificial structures. Country-by-country reporting.

02 / Training & culture

Policy is paper. Culture is practice.

Every ORN employee completes annual training in the Code of Conduct and the substantive compliance domains relevant to their role. Completion is tracked, audited, and tied to performance.

Senior leaders complete additional, in-person training on judgement-driven topics: bribery hospitality boundaries, conflicts of interest, insider-information handling, government-affairs conduct.

03 / Speak up

If something looks wrong, say so.

ORN protects every good-faith reporter. Retaliation is itself a violation of the Code of Conduct and is treated as such, without exception.

ethics@orn.com

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