Code of Conduct

We all play a role in maintaining a workplace built on integrity and trust. Associates are expected to follow company policies, applicable laws, and our shared ethical standards. 

Actions that go against these expectations are not acceptable, as they can impact our workplace and the trust we build with one another. If a concern arises, it will be reviewed carefully and addressed appropriately. 

Depending on the situation, this may result in disciplinary action, up to and including termination of employment. 

Scope and Applicability 

This policy applies to all officers, directors, and Associates of ORR, as well as anyone acting directly or indirectly on ORR’s behalf, including consultants, contractors, temporary employees, agents, and other third parties (collectively, “Engaged Third Parties”). If this Policy applies to you, you are required to read, understand, and comply with it. Failure to do so may violate applicable law and may result in serious consequences for you and ORR, including criminal penalties (fines and/or imprisonment). 

Core Requirements 

• Never solicit, encourage, offer, give, authorize, or receive any improper payment, benefit, or gift. 

• Maintain transparency and keep complete and accurate books and records. 

• Ensure Engaged Third Parties know, understand, and comply with this Policy. 

• Speak up and promptly report known or suspected violations of this Policy. 

Prohibition on Improper Payments, Benefits, and Gifts 

ORR policies, as well as the laws and regulations of most jurisdictions where we do business, prohibit you from directly or indirectly soliciting, encouraging, offering, giving, authorizing, or receiving any payment, benefit, or gift that could improperly influence—or appear to improperly influence—any individual, entity, or organization (public or private). Improper advantages may include personal or business benefits such as securing a contract, license, access to information, or any other favorable treatment. This prohibition applies to all third-party dealings, including interactions with customers, external business associates, and government officials. 

It makes no difference whether a payment, benefit, or gift is declined, or accepted but the recipient does not act as expected. Providing or receiving any such item is prohibited if it could reasonably be perceived as creating an obligation, influencing decisions, or rewarding a person for acting—or failing to act—in a certain way. You must always follow the strictest applicable requirement. 

Transparency and Accurate Recordkeeping 

ORR’s books and records, including expense reports, must be complete and accurate, including for immaterial amounts. This requirement applies equally to third parties acting on ORR’s behalf. All payments, benefits, and gifts over $100 must be properly documented and transparent to both the provider’s and the recipient’s employer and/or organization. Transparency is essential to legal compliance and to protecting ORR’s reputation. 

Engaged Third Parties 

ORR may be legally responsible for the actions of Engaged Third Parties. You must take appropriate steps to ensure Engaged Third Parties know, understand, and comply with this Policy. Watch for indicators of potentially corrupt behavior (see “Red Flags” below) and follow ORR procedures for conducting appropriate due diligence when entering into contracts with any third party who will be acting on ORR’s behalf. 

Reporting Concerns 

If you believe that you—or someone else—may be in violation of this Policy, you must report your concerns promptly. Contact your direct manager or supervisor, Associate Services, or Legal. 

Guidelines on Gifts, Travel, and Entertainment 

This section provides practical guidance on how the Policy applies to gifts, travel, entertainment, and hospitality. Use good judgment, and when in doubt, seek guidance in advance from your direct manager or supervisor, Associate Services, or Legal. 

Practical Considerations 

Improper payments, benefits, and gifts (including bribes) can take many forms, including: 

• Direct cash payments 

• Kickbacks 

• Unexplained rebates or discounts 

• Invoices for disguised or false expenses 

• Charitable or political contributions intended to influence decisions 

• Excessive goods or services for personal use (including gifts, travel, entertainment, and hospitality) 

• Paid or unpaid internships 

• Offers of employment 

The questions below may help you determine whether it is appropriate to offer or accept a payment, benefit, or gift: 

• What is the intention behind the payment, benefit, or gift? 

• Would you feel uncomfortable if the transaction became known to your manager, the organization, or the public? 

• Is the payment, benefit, or gift offered or presented to you or by you at the office, or away from the workplace so others will not know about it? 

• If you are providing a payment, benefit, or gift, does the person to whom you are planning to provide it have a policy that would prohibit it? When in doubt, check. 

• Does it seem right? If not, do not offer or accept it, or ask for guidance in advance.  

• Does the offer or timing create the appearance that the offer is improperly trying to influence an individual or an organization. 

When Gifts and Hospitality May Be Acceptable 

Payments, benefits, and gifts may be acceptable and comply with the ORR Code of Conduct only if they: 

• Comply with applicable laws and regulations. 

• Are promptly and accurately recorded in ORR’s books and records. 

• Are infrequent and not excessive in value in light of the recipient’s position and income. 

• Are connected to a legitimate business promotional activity or the performance of an existing contract. 

• Do not place the recipient under any obligation to the provider. 

• Are not tied to influencing any pending or recently concluded contractual negotiations. 

• Do not include cash. 

• Do not include cash equivalents (e.g., gift cards, gift certificates, and honorariums). exceeding $100 unless approved by your manager, Associate Services, or the Executive Leadership Team. 

• Are transparent to the employer or organization of both the provider and the recipient. 

Examples of Acceptable Gifts and Hospitality 

The following are examples of items you can usually offer or accept, provided they meet the criteria above: 

• Promotional items with the provider’s company or brand logo (e.g., a mug, travel diary, or pen) 

• Prizes randomly given or received in raffles or contests at industry conferences. 

• Routine tickets to a local sporting or cultural event 

• Meals and entertainment of reasonable value when business is being conducted. 

• Modest expressions of gratitude or gifts acknowledging personal events (e.g., weddings and births) 

• Seasonal or holiday gifts of nominal value 

• Free or reduced admission passes to events that showcase ORR offerings (when giving prizes in contests or raffles, consult your manager, Associate Services, or Legal to confirm the value is reasonable and not excessive) 

Examples of Unacceptable Gifts and Hospitality 

The following are examples of items you generally may not offer or accept: 

• Cash gifts or gift certificates in any amount exceeding $100. 

• Luxury goods 

• Payment for shopping trips 

• Education costs for clients or affiliated individuals 

• Travel per diems or cash allowances that can be spent at will during trips or entertainment outings. 

• Side recreational, vacation, or sightseeing trips that are disproportionate to the primary business trip. 

• Standalone recreational, vacation, or sightseeing trips 

• Gambling and adult entertainment 

Public Officials 

Dealing with public officials carries a higher risk of corruption (or the perception of corruption). We must be especially careful when communicating with public officials and when providing travel, gifts, entertainment, or any other in-kind assistance to public officials. 

Facilitation Payments 

In certain jurisdictions, public officials may request small payments—sometimes called “facilitation payments”—to expedite or secure routine governmental actions (e.g., issuing permits or licenses; processing visas; providing customs clearances; providing police protection; providing utility services; or handling cargo). Facilitation payments are a form of bribery, and ORR never pays—or authorizes the payment of—facilitation payments. If you are asked to make a facilitation payment, you must refuse and immediately inform your manager, Legal, and Associate Services. 

Red Flags 

Examples of anti-corruption and anti-bribery red flags include: 

• Questionable or significant cash withdrawals. 

• Unusually high dollar payments to individuals or organizations. 

• Miscellaneous, unexplained, or undocumented expenses or payments. 

• Payments to parties other than those contracted with to provide goods or services. 

• Invoices that lack detail, have descriptions that appear false, or do not match the goods or services provided. 

• Doing business with people or entities that are known to engage in or are suspected of engaging in bribery. 

• Requests for false or misleading documentation (side letters, fake invoices, altered receipts). 

• Requests for urgent payments or “special handling” to win/keep business. 

• Third party is connected to a government official (family/business ties) relevant to the deal. 

International Relations 

ORR Associates involved in international business operations must follow applicable United States and local laws, including the Foreign Corrupt Practices Act of the United States and applicable Import/Export laws. The Foreign Corrupt Practices Act (FCPA) prohibits offering anything of value to a foreign official for the purpose of improperly influencing an official decision and the making of false records or accounts in the conduct of foreign business. International transfers of certain equipment and technology are subject to complex federal export control laws and regulations which may contain prior approval and reporting requirements. Importation of goods and technology into certain countries is subject to local laws of the jurisdiction, treaties, and laws of the United States. If you participate in this type of business activity, you must know, understand, and strictly comply with these regulations or contact the Legal Division for advice. 

Antitrust 

ORR’s programs and decisions for the distribution and sale of products and services must comply with the antitrust laws of the state and federal government. At a minimum, all Associates should be aware that serious legal consequences, including in some cases criminal fines and penalties, may result from (i) setting prices with competitors or resale prices for distributors, (ii) agreeing with competitors on bidding terms or whether or not to submit a bid, (iii) agreeing with competitors to allocate customers or territories. 

The purpose of antitrust laws is to create a level playing field in the marketplace, as well as to promote fair competition. ORR Associates must always follow all applicable laws and regulations designed to regulate competition. Questions regarding antitrust issues should be directed to Legal. 

We encourage all Associates to speak up if they have concerns about conduct that may be unethical, illegal, or inconsistent with our values. This includes, but is not limited to, concerns about fraud, corruption, harassment, safety issues, human rights, labor standards, working conditions or misuse of company resources. 

The organization is committed to creating a workplace where individuals feel safe and supported in raising concerns. Reports may be made to an immediate manager and/or to Associate Services. Matters that require additional review or involve legal or regulatory risk are escalated to Associate Services leadership and Legal. All concerns will be taken seriously, reviewed promptly, and handled as confidentially as possible. 

We strictly prohibit retaliation against anyone who raises a concern or participates in an investigation in good faith. Individuals who come forward will be treated with respect and supported throughout the process. 

By speaking up, you help protect our organization, your colleagues, and our shared commitment to integrity and accountability.

We are committed to maintaining a workplace where everyone is treated with dignity, respect, and fairness. Our goal is to provide an environment that is free from unlawful discrimination and harassment. 

Discrimination or harassment of any kind is not acceptable. This includes discriminatory behavior based on characteristics such as race, religion (including dress and grooming practices), color, sex (including pregnancy, childbirth, breastfeeding, and related conditions), gender identity, sexual orientation, national origin, citizenship status, military or veteran status, age (40 and over), genetic information, or physical or mental disability, as well as any other status protected by applicable law.  

These expectations apply to all Associates. For more detailed information, please refer to the Harassment and Discrimination Policy in the ORR Protection Associate Handbook. 

We are committed to fostering a positive, respectful, and professional work environment where everyone can do their best work. Each of us plays a role in creating and maintaining this culture. 

Associates are expected to treat others with courtesy, respect, and professionalism at all times. This includes communicating constructively, valuing diverse perspectives, and working collaboratively. 

Examples of Positive Workplace Behavior 

• Treating colleagues, customers, and partners with respect and kindness 

• Communicating openly and professionally 

• Listening to different viewpoints and being open to feedback 

• Taking accountability for your actions and following through on commitments 

• Supporting team members and contributing to a collaborative environment 

• Addressing concerns in a constructive, solution-focused way 

• Demonstrating reliability, punctuality, and preparedness 

• Following company policies and helping maintain a safe and inclusive workplace 

Examples of Unacceptable Workplace Behavior 

• Using disrespectful, offensive, or inappropriate language or tone 

• Bullying, intimidation, or threatening behavior 

• Harassment, discrimination, or exclusion of others 

• Ignoring or refusing to follow company policies or safety requirements 

• Misuse of company time, property, or resources 

• Gossiping, spreading rumors, or engaging in disruptive conduct 

• Failing to cooperate with colleagues or undermining teamwork 

• Retaliating against someone who raises a concern in good faith 

Behavior that disrupts the workplace or negatively impacts others is not acceptable. Concerns will be reviewed thoughtfully and addressed in a fair and consistent manner in line with company policies. 

We encourage open communication and addressing concerns early. By maintaining positive workplace behavior, we strengthen our culture, support one another, and create a productive and respectful environment for all.

We are committed to protecting the confidentiality of company information, as well as the privacy of our Associates, customers, and business partners. During the course of your work, you may have access to sensitive or proprietary information, and it is important that this information is handled with care and discretion. 

Confidential information may include, for example: 

• Customer or client information (names, contact details, account data) 

• Associate records (personnel files, compensation, medical or benefits information) 

• Financial information (budgets, forecasts, payroll, revenue data) 

• Business plans, strategies, or internal reports 

• Pricing, contracts, and vendor agreements 

• Trade secrets, processes, or proprietary methods 

• IT systems, passwords, or security-related information 

• Any non-public information about ORR or its operations 

Associates are expected to: 

• Safeguard confidential information and use it only for legitimate business purposes. 

• Share information only with individuals who have a business need to know. 

• Follow company policies and procedures for storing, accessing, and transmitting information. 

• Protect sensitive information from unauthorized access, disclosure, or loss. 

Confidential information should not be discussed in public places or shared outside the organization without proper authorization. This responsibility continues even after employment ends. 

Failure to maintain confidentiality may result in disciplinary action, up to and including termination of employment. If you are unsure whether information is confidential or how it should be handled, please seek guidance from your manager or Associate Services.

We are committed to protecting the privacy and security of personal information entrusted to us by our Associates, customers, and business partners. Safeguarding this information is an important part of maintaining trust and meeting our legal and ethical responsibilities. Confidential information may be used by ORR Associates to perform their job, and it is the responsibility of every ORR Associate to keep this information securely. Confidential information includes personnel data maintained by ORR, customer lists and customer information, pricing and cost data, Trade Secrets, proprietary information, and confidential information entrusted to ORR by others. It also includes, but is not limited to, information pertaining to acquisitions, divestitures, affiliations and mergers, financial data, research data, strategic plans, marketing strategies/techniques, employee lists, and data maintained by ORR, supplier and subcontractor information, and proprietary computer software. Confidential information is a valuable asset, and once it is lost it cannot be regained. ORR prohibits sharing confidential information with persons outside of ORR. To ensure confidentiality, ORR Associates are expected to follow commercially acceptable security practices. 

Examples of personal data include: 

• Names, addresses, phone numbers, and email addresses 

• Social Security numbers or government identification numbers 

• Financial information (bank details, payment information) 

• Associate records (compensation, benefits, performance information) 

• Health or medical information 

• Online identifiers such as usernames, IP addresses, or system access details 

Associates are expected to: 

• Collect, use, and share personal information only for legitimate business purposes. 

• Access only the information necessary to perform their job responsibilities. 

• Protect personal data from unauthorized access, loss, or disclosure. 

• Follow company policies and procedures for handling, storing, and transmitting data. 

• Report any suspected data breach or privacy concern promptly. 

We take data privacy seriously and strive to comply with all applicable data protection laws and regulations. Failure to follow these expectations may result in disciplinary action, up to and including termination of employment. 

If you have questions about handling personal data or believe there has been a privacy concern, please contact your manager or Associate Services.  

Except where an Associate is expressly authorized to communicate on behalf of ORR as part of their assigned job responsibilities, Associates are expected not to access, post to, or otherwise utilize social media platforms during scheduled working time. For purposes of this policy, “working time” does not include bona fide meal periods, authorized rest breaks, or time outside of an Associate’s scheduled work hours. 

Associates are further prohibited from accessing social media platforms or other non-business-related online services through Company-owned or Company-provided equipment, systems, or networks, unless such access is directly related to legitimate business purposes and has been expressly authorized by the Associate’s manager. 

Under no circumstances shall Associates use Company-issued or Company-affiliated email addresses to create, register for, or maintain personal accounts on social networking sites, blogs, forums, or any other online platforms intended for non-business use. 

Any violation of this policy may result in disciplinary action, up to and including termination of employment, in accordance with applicable Company policies and governing law.

Conflicts of interest can occur when personal interests interfere with an individual’s ability to perform their job responsibilities objectively. Such conflicts may be personal, financial, or competitive in nature, and they can raise concerns about an individual’s integrity, judgment, or commitment to ORR. Even the appearance of a conflict can undermine trust and should be avoided to ensure that business decisions are made in the best interests of ORR. 

Here are examples of different types of conflicts of interest: 

Personal Conflicts 

• Hiring or promoting a family member or close friend without following standard procedures. 

• Supervising or evaluating the performance of someone you have a personal relationship with. 

• Allowing personal relationships to influence workplace decisions or objectivity. 

Financial Conflicts 

• Owning stock or having a financial stake in a company that is a vendor, supplier, or competitor. 

• Accepting gifts, payments, or favors from a vendor in exchange for favorable treatment. 

• Steering business to a company in which you or a family member have a financial interest. 

Competitive Conflicts 

• Working for or consulting with a competitor while employed by ORR. 

• Sharing confidential or proprietary information with a competing organization. 

• Using Company resources or knowledge to start or support a competing business. 

Use of Company Assets or Position 

• Using Company time, equipment, or resources for personal business activities. 

• Using your role or influence to secure personal benefits (discounts, special treatment, etc.). 

Appearance of Conflict (Even if not intentional) 

• Participating in a decision that could benefit a personal acquaintance, even if you believe you can remain unbiased. 

• Accepting frequent or high-value gifts from a vendor, creating the perception of favoritism. 

Outside Activities 

• Taking on outside employment that interferes with your ability to perform your job. 

• Serving on a board or advisory group that conflicts with ORR’s interests. 

A conflict of interest may constitute a high-risk situation requiring prompt disclosure and appropriate resolution. Associates are required to disclose any actual, potential, or perceived conflicts of interest in accordance with Company policy. Associate Services is available to provide confidential guidance to assist in identifying, evaluating, and managing such conflicts. 

Failure to disclose or appropriately manage a conflict of interest may result in disciplinary action, up to and including termination of employment. Additional consequences may include reassignment of duties, removal from decision-making responsibilities, or other corrective actions deemed appropriate. Violations may also expose the individual and tORR to legal or regulatory risk. 

To maintain a professional and productive work environment, ORR prohibits unauthorized solicitation and distribution activities in the workplace. 

Associates may not solicit other Associates for non-business purposes — including, but not limited to, fundraising, the sale of goods or services, or membership in organizations—during working time. “Working time” does not include scheduled meal periods or rest breaks. 

Associates may not distribute non-business-related materials in work areas at any time. Distribution of such materials is permitted only in non-working areas (such as break rooms or other designated common spaces) and only during non-working time. 

Non-Associates are prohibited from engaging in solicitation or distribution activities on Company premises at any time, unless expressly authorized by management. 

The use of Company systems—including email, messaging platforms, and other communication tools—for non-business solicitation or distribution is prohibited unless specifically authorized. 

ORR is committed to conducting business lawfully, ethically and with respect for fundamental human rights. We strictly prohibit child labor and are committed to protection the safety, health, education, and development of young workers across all locations where we operate. 

Prohibition of Child Labor 

ORR does not employ children below the minimum legal working age as defined by applicable local, national, and international laws. Where multiple legal standards apply. ORR follows the most stringent requirement. 

Child labor includes any work that interferes with compulsory education, harms physical or mental development, or exposes a child to hazardous or exploitative conditions. Such practices are strictly prohibited. 

Young Workers 

A young worker is any individual who is legally permitted to work but is under the age of 18. 

ORR permits the employment of your workers only in compliance with applicable labor laws and with appropriate safeguards in place. Young workers must not be assigned work that is hazardous, physically demanding or otherwise harmful to their health, safety, or development. Young workers must not work overtime or night shifts where prohibited by law. 

Employment of young workers must not interfere with school attendance or educational requirements. Total daily time spent on work and schooling must comply with legal limits and, in all cases, must not exceed 10 hours per day. 

Wages, Hours, and Working Conditions 

Young workers are compensated in accordance with applicable wage and hours laws and are provided working conditions that meet legal and safety requirements. ORR ensures that working hours, rest periods and compensation practices for your workers comply with all working regulations.

ORR is committed to fair, lawful, and open compensation practices. We ensure that all associates are paid in accordance with applicable wage and hour laws and that wages and benefits support a decent standard of living consistent with legal requirements and prevailing industry practices. 

Fair and Lawful Compensation 

ORR provides wages and benefits that meet or exceed applicable legal requirements in every country, state, or locality where we operate. Where multiple laws apply, we follow the most stringent applicable standard. 

Wages and benefits include base pay or salary and all additional compensation or entitlements provided directly or indirectly, whether in cash or in kind, arising from employment. 

Minimum Wage and Overtime 

ORR complies with all applicable minimum wage, overtime, and premium pay laws. Nonexempt associates are compensated for overtime hours in accordance with applicable legal requirements. Associate classifications are determined based on job duties and legal criteria, not job titles alone. 

Benefits and Leave 

ORR provides legally mandated benefits, including medical leave, paid or unpaid leave, and other statutory benefits required by applicable law. Benefits practices comply with local, national, and international legal requirements. 

Working Hours and Wage Payments 

Working hours, rest periods, and wage payment practices comply with applicable laws and regulations. Wages are paid accurately, on time, and with appropriate documentation. ORR maintains payroll and timekeeping records as required by law. 

Decent Standard of Living 

Where required by law or applicable standards, ORR considers prevailing wage requirements and industry practices. Compensation should be sufficient to meet basic needs and support a reasonable standard of living for associates and their families, consistent with applicable legal frameworks. 

ORR is committed to responsible working hour practices that protect associate health, safety, and wellbeing while complying with applicable laws and regulations in all jurisdictions where we operate. 

Standard Working Hours 

ORR seeks to ensure that regular working hours do not exceed forty-eight (48) hours per week, consistent with applicable laws and internationally recognized labor standards. 

Overtime 

Overtime is permitted only in accordance with applicable laws and must be voluntary, except where otherwise permitted by law. Total working hours, including overtime, should not exceed sixty (60) hours per week except in emergency or exceptional business circumstances. 

Overtime is compensated in accordance with applicable wage and hour laws. Associates will not be required or pressured to work overtime in violation of legal limits. 

Rest Periods and Time Off 

Associates are entitled to appropriate rest periods and time off as required by law. ORR seeks to ensure that associates receive at least one full day off in every seven-day period, unless otherwise permitted by applicable law. 

Daily and weekly rest periods are provided in accordance with local legal requirements to support associate health and safety. 

Compliance With Laws 

ORR complies with all applicable laws and regulations governing working hours, overtime, rest periods, and time off. Where multiple legal standards apply, the most stringent requirement is followed.

ORR is committed to respecting fundamental human rights and maintaining ethical business practices. We have zero tolerance for modern slavery, forced labor, or human trafficking in any form, whether within our operations or throughout our supply chain. 

Prohibition of Modern Slavery 

Modern slavery includes all work or service exacted from any person under the threat of penalty and for which the individual has not offered themselves voluntarily. This includes, but is not limited to, forced or compulsory labor, human trafficking, debt bondage, forced overtime, retention of identity documents, deceptive recruitment practices, and restrictions on freedom of movement. 

ORR strictly prohibits all forms of modern slavery and human trafficking. 

Voluntary Employment and Freedom of Movement 

Employment with ORR must be voluntary. Associates are free to leave employment or change employers in accordance with applicable laws and contractual obligations. 

ORR prohibits the confiscation, withholding, or destruction of personal identification or immigration documents, including passports, visas, or government-issued identification. 

Ethical Recruitment and Fair Treatment 

ORR is committed to ethical recruitment practices. Recruitment must be transparent and lawful, with clear and understandable employment terms. Associates must not be charged recruitment fees or related costs as a condition of employment. 

Wages, Working Conditions, and Dignity 

Associates must be paid agreed wages and benefits accurately, on time, and in accordance with applicable laws. Illegal wage deductions are prohibited. ORR is committed to providing safe and healthy working conditions and to treating all individuals with dignity, respect, and fairness. 

Legal Compliance and Transparency 

ORR complies with all applicable laws prohibiting modern slavery and human trafficking. Where required by law, including under the United Kingdom Modern Slavery Act 2015, ORR will publish a slavery and human trafficking statement describing the steps taken to prevent modern slavery in its operations and supply chains.

ORR is committed to ethical, lawful, and transparent recruitment practices that respect human rights and align with internationally recognized labor standards. We prohibit deceptive, coercive, or exploitative recruitment practices and are committed to ensuring that all employment relationships are entered into voluntarily and with informed consent. 

Lawful and Fair Recruitment 

ORR recruits and hires workers in compliance with applicable local, national, and international laws and in a manner consistent with International Labor Standards. Recruitment decisions are based on job-related qualifications and business needs and are conducted fairly and transparently. 

Transparency and Informed Consent 

Candidates and workers must receive accurate, truthful, and complete information about the nature of the work prior to employment. This includes job duties, work location, working hours, compensation, benefits, and applicable terms and conditions. 

Workers must receive written notification at the start of recruitment or prior to employment in a language they understand, clearly describing their rights, responsibilities, and employment terms. 

Prohibition of Misleading or Fraudulent Practices 

ORR strictly prohibits misleading, deceptive, or fraudulent recruitment practices. This includes misrepresenting job duties, wages, benefits, working conditions, housing arrangements if applicable, or the hazardous nature of the work. 

Recruitment Fees and Worker Costs 

Workers must not be required to pay recruitment fees or related costs as a condition of employment. Recruitment fees must not be charged directly or indirectly, including through labor brokers, recruiters, or third parties acting on ORR’s behalf. 

Protection of Identity Documents and Freedom of Movement 

ORR prohibits the confiscation, destruction, concealment, or denial of access to worker passports, visas, or other government-issued identity documents. Workers must retain possession and control of their personal documents at all times, except where temporary custody is required by law and provided with informed consent. 

Workers must have freedom of movement and must be free to leave employment in accordance with applicable laws and contractual obligations. 

Ethical Use of Recruiters and Agents 

ORR works only with recruitment agencies, labor brokers, and service providers that adhere to ethical recruitment standards consistent with this policy. Third parties engaged in recruitment must comply with applicable laws and must not engage in coercive, deceptive, or exploitative practices.

ORR respects and supports the right of associates to freedom of association and peaceful assembly. We recognize the right of workers to form and join organizations of their choosing, including trade unions, for the purpose of protecting their interests and engaging in collective bargaining, in accordance with applicable laws. 

Freedom of Association 

Associates have the right to freely associate, organize, and participate in lawful trade union, associate representative, or worker organization activities without fear of discrimination, intimidation, or retaliation. 

Associates also have the right to refrain from joining or participating in such activities, consistent with applicable laws and agreements. 

Collective Bargaining 

ORR respects the right to collective bargaining as a legitimate and constructive process for negotiating terms and conditions of employment. Where associates are represented by a lawfully recognized union or representative body, ORR engages in good-faith dialogue and bargaining in accordance with applicable laws and agreements. 

Collective bargaining is recognized as an important mechanism for promoting fair working conditions, managing change, and fostering respectful and productive employer-associate relationships. 

Non-Interference and Non-Retaliation 

ORR prohibits interference with, restraint of, or coercion against associates exercising their rights to freedom of association or collective bargaining. Associates will not be disciplined, discriminated against, or otherwise disadvantaged for exercising these rights in good faith. 

Legal Compliance 

ORR complies with all applicable local, national, and international laws governing freedom of association, collective bargaining, and peaceful assembly. Where local laws restrict these rights, ORR seeks to respect internationally recognized labor standards to the extent permitted by law.

ORR is committed to respecting the rights of individuals and communities affected by our operations and supply chain. We seek to avoid actions that result in forced eviction or the unlawful or unjust deprivation of land, forests, or water resources. 

Prohibition of Forced Eviction 

ORR prohibits forced eviction and involuntary displacement of individuals or communities in connection with the acquisition, development, or use of land, forests, or water resources. 

Forced eviction includes the removal of individuals or communities from land or resources they occupy or use, without lawful justification, meaningful consultation, or fair compensation. 

Respect for Land, Forest, and Water Rights 

ORR recognizes the importance of land, forest, and water resources to the livelihoods, culture, and wellbeing of local and Indigenous communities. We seek to conduct our operations in a manner that respects legally recognized land tenure rights and customary land-use rights, consistent with applicable laws and internationally recognized standards. 

Consultation and Consent 

Where ORR activities or business relationships may impact land, forest, or water rights, we seek to ensure meaningful engagement with affected communities. Where required by law or applicable standards, projects must be based on free, prior, and informed consent, obtained through transparent and culturally appropriate processes. 

Compensation and Resettlement 

In the rare event that land use changes or resettlement are agreed to voluntarily, such actions must be based on fair, adequate, and timely compensation. Any resettlement must be conducted lawfully, respectfully, and in a manner that seeks to minimize adverse social, economic, and environmental impacts. 

ORR recognizes that the use of private or public security forces to protect business operations or assets may present human rights risks if not properly managed. We are committed to ensuring that any use of security forces is conducted responsibly, lawfully, and with respect for human rights. 

Responsible Use of Security Forces 

ORR will not engage private or public security forces unless their use is necessary, lawful, and appropriate for the specific circumstances. Where security forces are engaged, ORR seeks to ensure that they are adequately trained, supervised, and controlled to prevent human rights violations. 

Human Rights Standards 

Security forces engaged to protect ORR operations must act in a manner consistent with applicable laws and internationally recognized human rights principles. The use of excessive force, intimidation, harassment, or abuse is prohibited. 

ORR does not tolerate conduct by security personnel that infringes on the dignity, safety, or rights of associates, contractors, community members, or other stakeholders. 

Oversight and Accountability 

Where ORR has influence over the engagement of security forces, we seek to implement appropriate oversight measures to promote responsible conduct. Any credible allegations of misconduct or human rights violations involving security personnel must be reported and addressed promptly.

ORR is committed to fostering an environment and culture that allows opportunities for every Associate to thrive. It goes without saying that all Associates who align with ORR’s values will have equal opportunity for success and advancement regardless of gender, race, color, national origin or ancestry, religion, sexual preference, disability, or background.  

ORR will comply with all local and national regulations related to any protected class of individual in any geography of operation and will provide equal treatment to all individuals for employment-related decisions, irrespective of characteristics including but not limited to those mentioned above. ORR expects suppliers, contractors, and business partners to similarly comply with all regulations related to any protected class of individual in any geography of operation and to provide equal treatment to all individuals for employment-related decisions. Failure to comply with applicable law in matters such as these may result in corrective action or termination of the business relationship.

ORR requires its suppliers, contractors, and business partners to comply with this Code of Conduct, including but not limited to, standards related to human rights, health and safety, data protection, anti-corruption, and ethical business practices, as well as all applicable local, state, federal, and other relevant laws and regulations. Third parties are expected to maintain appropriate controls, provide information reasonably requested to demonstrate compliance, and ensure that their own subcontractors and agents meet the same standards. Failure to comply may result in corrective action, up to and including termination of the business relationship.