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📄 CORPORATE COMPLIANCE POLICY

RISK MANAGEMENT AND BUSINESS ETHICS

Last Updated: May 2026

This Policy establishes the comprehensive framework for regulatory compliance, corporate risk management, business integrity, and ethical conduct applicable to all operations of Oro Technologies LLC (hereinafter, “ORO”), a global technology company operating digital mobility, accessibility, voice, and artificial intelligence platforms through interactions between users and independent service providers.

This document forms an essential part of the Company's global corporate governance system and shall be interpreted together with the Terms and Conditions, Privacy Policy, and all other legal documents within the ORO ecosystem.

REGULATORY AND COMPLIANCE FRAMEWORK

Oro Technologies LLC conducts its activities under a global compliance framework aligned with applicable laws of the United States, including the laws of the State of Florida, as well as mandatory regulatory requirements of jurisdictions where the Platform may operate or be made available.

The Company adopts international standards relating to corporate governance, data protection, cybersecurity, digital accessibility, consumer protection, enterprise risk management, technology compliance, and responsible artificial intelligence development, seeking to maintain operations consistent with global best practices applicable to international digital platforms.

COMPREHENSIVE CORPORATE RISK MANAGEMENT

The Company implements a structured system for identifying, assessing, mitigating, and monitoring risks, including operational, technological, legal, reputational, and financial risks.

Such system is intended to prevent adverse impacts arising from Platform use, user or third-party conduct, and external events that may affect business continuity.

Oro Technologies LLC reserves the right to adopt immediate corrective measures, including account suspension, access limitations, or termination of commercial relationships whenever risks are identified that may compromise Platform integrity or regulatory compliance.

CORPORATE GOVERNANCE AND COMPLIANCE OVERSIGHT

ORO maintains an internal corporate governance system designed to identify, evaluate, monitor, and mitigate legal, technological, operational, regulatory, financial, reputational, and security risks.

Measures adopted by the Company are intended to strengthen regulatory compliance and the operational integrity of the Platform and shall not be interpreted as assuming regulatory, law-enforcement, judicial, medical, supervisory, or direct-control functions over users or independent third parties.

TECHNOLOGY, VOICE, AI, AND SOS SYSTEM MANAGEMENT

ORO operates a technology platform based on voice systems, artificial intelligence, automation, and digital accessibility tools designed to facilitate user interactions, including interactions involving older adults and persons with disabilities.

Users acknowledge and agree that:

Voice-recognition systems may contain errors or inaccurate interpretations.

Artificial-intelligence functionalities may generate inaccurate responses or results.

Voice activation features and commands may depend on user-device settings and third-party technologies.

ORO does not guarantee continuous availability, accuracy, or uninterrupted operation of its technological systems.

ORO may facilitate safety functions and S.O.S. alerts through the transmission of signals to independent security providers or emergency-response partners acting autonomously and under their own operational responsibility.

ORO is not an emergency-services provider, does not dispatch authorities, and does not guarantee response times or intervention outcomes.

USER AUTONOMY AND ACCESSIBILITY TECHNOLOGY

Accessibility functionalities, voice commands, hands-free systems, automated notifications, quick-message features, arrival estimates, coordination tools, and other features designed to facilitate Platform interaction are intended solely to improve accessibility, inclusion, convenience, and user autonomy.

The existence of such functionalities does not create any special duty of protection, supervision, custody, personal assistance, continuous monitoring, medical care, fiduciary duty, duty of vigilance, or expanded liability on the part of ORO.

Users remain solely responsible for evaluating their surroundings, making independent decisions, and taking reasonable safety precautions appropriate to their circumstances.

The use of accessibility tools does not eliminate or reduce risks inherent to real-world interactions.

TECHNOLOGICAL LIMITATIONS AND DEPENDENCE ON THIRD-PARTY INFRASTRUCTURE

Operation of the Platform depends upon technological infrastructure, telecommunications services, mobile networks, operating systems, geolocation services, cloud-service providers, artificial-intelligence services, and other technologies operated by independent third parties.

Accordingly, ORO does not guarantee continuous availability, accuracy, compatibility, performance, coverage, speed, stability, or uninterrupted functionality of any technological feature.

Interruptions, delays, errors, communication failures, geolocation inaccuracies, or operational limitations arising from third-party systems shall not create liability for ORO to the maximum extent permitted by applicable law.

TECHNOLOGICAL NATURE OF THE S.O.S. SYSTEM

The S.O.S. functionality constitutes exclusively a technological communication and information-transmission tool.

Activation of an S.O.S. alert does not create any obligation of rescue, custody, personal protection, surveillance, supervision, emergency response, law-enforcement intervention, medical assistance, continuous monitoring, or special duty of care on the part of ORO.

The effectiveness of any alert depends upon factors beyond ORO’s reasonable control, including connectivity, device availability, technological infrastructure, independent security operators, telecommunications providers, and competent authorities.

ABSENCE OF SPECIAL DUTY OF PROTECTION OR CUSTODY

The implementation of accessibility functionalities, voice systems, safety tools, S.O.S. alerts, automated communications, artificial intelligence, verification mechanisms, geolocation features, or any other functionality intended to improve the user experience shall not create and shall not be interpreted as creating any special duty of protection, custody, supervision, surveillance, personal care, guardianship, accompaniment, continuous monitoring, or fiduciary duty on the part of ORO.

Users acknowledge that the Platform constitutes exclusively a technological intermediary and communication tool.

The existence of functionalities intended to facilitate access for older adults, persons with disabilities, persons with reduced mobility, or users with technological limitations does not increase, expand, or modify ORO’s legal obligations beyond those expressly required by applicable law.

Each user remains fully responsible for their own decisions, movements, interactions, communications, and activities conducted on or off the Platform.

GLOBAL CODE OF CONDUCT

All users, independent service providers, and third parties interacting with the Platform agree to act in accordance with principles of good faith, respect, legality, and ethical conduct.

Any conduct involving fraud, identity misrepresentation, misuse of the Platform, harassment, discrimination, transportation of illegal goods, or any unlawful activity is strictly prohibited.

Violation of these obligations may result in immediate termination of Platform access, without prejudice to any additional legal actions.

RESPONSIBLE USE OF VOICE FUNCTIONALITIES

Users acknowledge that voice-based functionalities are technological assistance tools intended to improve accessibility, inclusion, operational safety, and ease of use.

Users remain responsible for verifying critical information, confirming important actions, complying with applicable laws, and exercising independent judgment regarding decisions made through voice interaction.

Voice functionalities do not replace human attention, professional advice, emergency services, or individual legal obligations.

ABSENCE OF CONTROL OVER OPERATIONAL DECISIONS

Voice functionalities, accessibility tools, quick messaging, meeting-point coordination features, automated arrival announcements, communication tools, time or distance estimates, and other technological functionalities available through the Platform are intended solely for informational and coordination purposes.

ORO does not control, determine, approve, supervise, or direct decisions made by users or independent third parties regarding routes, meeting points, schedules, locations, communications, movements, service acceptance, or any activity conducted outside the technological infrastructure of the Platform.

All operational decisions remain exclusively the responsibility of participating parties.

ANTI-FRAUD POLICY AND PREVENTION OF ILLEGAL ACTIVITIES

Oro Technologies LLC adopts technological, operational, and legal measures to prevent, detect, and manage fraudulent or unlawful activities within the Platform.

The Company may monitor usage patterns, validate user information, and cooperate with competent authorities when suspicious conduct is detected.

Although the Company is not a financial institution and is not legally required to implement anti-money laundering programs, it adopts general due-diligence principles to mitigate risks associated with unlawful activities.

INTERNATIONAL COOPERATION AND CROSS-BORDER COMPLIANCE

Due to the international nature of ORO’s operations, the Company may cooperate with competent regulatory, judicial, administrative, or security authorities across multiple jurisdictions when a valid legal obligation exists or when a request is issued pursuant to applicable due-process requirements.

Such cooperation may include the preservation, review, or disclosure of information to the extent permitted by applicable law and in accordance with ORO’s Privacy Policy.

Due to the international nature of the Platform, ORO may cooperate with regulatory, administrative, judicial, and compliance authorities located in different jurisdictions, provided that applicable legal requirements are satisfied.

Such cooperation may include the preservation, analysis, review, or disclosure of information when legally required or reasonably necessary to protect rights, prevent fraud, investigate unlawful activities, or comply with regulatory obligations.

COMPLIANCE WITH INTERNATIONAL SANCTIONS AND REGULATORY RESTRICTIONS

ORO may restrict, suspend, or deny access to the Platform whenever reasonably necessary to comply with applicable laws, international economic sanctions, trade restrictions, governmental orders, regulatory requirements, corporate-compliance obligations, fraud-prevention measures, or risks associated with unlawful activities.

Nothing in this Policy shall require ORO to provide access to services, technologies, or functionalities where such access could result in legal, regulatory, or corporate-compliance violations.

BUSINESS ETHICS AND CORPORATE TRANSPARENCY

The Company conducts its activities under principles of integrity, transparency, and social responsibility, avoiding any practice that may be considered corrupt, deceptive, or unlawful.

Oro Technologies LLC promotes an organizational culture based on trust, inclusion, respect for users—including users with diverse accessibility needs, older adults, persons with disabilities, and users with varying levels of digital literacy—and strict compliance with applicable laws.

LIMITED LIABILITY REGARDING COMPLIANCE

Users acknowledge that despite the Company’s reasonable efforts to implement control, security, and compliance systems, Oro Technologies LLC does not guarantee the complete elimination of risks arising from Platform use, including risks generated by users, independent providers, technological systems, third parties, or external events.

Use of the Platform remains at the user’s sole responsibility, to the maximum extent permitted by applicable law.

ORO may cooperate with local and international authorities, including requests related to safety, emergencies, or investigations, provided such requests satisfy legal requirements regarding jurisdiction, proportionality, and due process.

LIMITATION PERIOD FOR CLAIMS

To the maximum extent permitted by applicable law, any claim, action, proceeding, or dispute relating to the Platform, services, technologies used, or this Policy must be initiated within one (1) year from the date of the event giving rise to the claim.

After expiration of such period, any claim shall be permanently barred.

NO GUARANTEE OF THIRD-PARTY COMPLIANCE

Although ORO may implement corporate policies, technological mechanisms, verification processes, operational controls, monitoring tools, compliance measures, or risk-management programs, ORO does not guarantee that users, independent providers, business partners, advertisers, contractors, or other third parties will continuously comply with applicable laws, this Policy, or any contractual obligations.

The acts, omissions, violations, unlawful conduct, errors, negligence, or misconduct of third parties remain solely their responsibility.

NO GUARANTEE OF ABSOLUTE PREVENTION

No compliance program, risk-management system, technological tool, artificial-intelligence system, verification mechanism, monitoring process, corporate policy, or security measure can guarantee the absolute elimination of risks, fraud, human error, unlawful conduct, technological incidents, or external events.

Implementation of compliance measures by ORO shall not be interpreted as a guarantee of absolute prevention or as an assumption of responsibility for actions performed by independent third parties.

COOPERATION WITH AUTHORITIES

Oro Technologies LLC shall cooperate with administrative, judicial, or regulatory authorities whenever required by law, including the disclosure of information necessary for investigations relating to Platform use.

NATURE OF THE PLATFORM AND INDEPENDENT SERVICES

ORO is a global technology platform acting exclusively as a digital intermediary.

ORO does not provide transportation services, logistics services, physical-security services, medical services, or emergency services.

All services are performed exclusively by independent third parties acting under their own legal, operational, and regulatory responsibility.

No employment, agency, partnership, joint-venture, or representative relationship is created between ORO and such third parties.

ABSENCE OF OPERATIONAL CONTROL

ORO does not supervise, direct, control, manage, or assume responsibility for the physical execution of services performed by independent third parties.

Decisions relating to routes, schedules, meeting points, request acceptance, service performance, communications between participants, and other operational activities remain exclusively the responsibility of participating users and independent providers.

No technological functionality offered by ORO shall be interpreted as evidence of operational control over independent third parties.

GOVERNING LAW AND DISPUTE RESOLUTION

This Policy shall be governed by and interpreted in accordance with the laws of the State of Florida, United States of America, without regard to conflict-of-law principles.

Any dispute arising from this Policy shall be resolved pursuant to the dispute-resolution mechanisms established in ORO’s Global Terms and Conditions.

To the maximum extent permitted by law, users waive any right to participate in class actions, representative proceedings, mass arbitrations, or consolidated claims.

EFFECTIVENESS AND UPDATES

This Policy may be modified at any time to adapt to regulatory, technological, or strategic changes affecting the Company.

Continued use of the Platform constitutes acceptance of such modifications.

RESERVATION OF CORPORATE RIGHTS

Failure by ORO to exercise any right, power, or remedy provided under this Policy shall not constitute a waiver of such right.

All rights and remedies of ORO shall be cumulative and may be exercised simultaneously or independently as permitted by applicable law.

ORO Technologies LLC is a limited liability company organized under the laws of the State of Florida, United States of America, identified by EIN 92-2555357, with its principal corporate address at 16425 Greenwood Forest Dr, Clewiston, Florida 33440, United States.

The Company operates as a global technology platform for digital intermediation, accessibility, voice technologies, and artificial intelligence, with international operational presence through users, independent service providers, and non-subordinate third parties.

GLOBAL LEGAL INTEGRATION NOTICE

These Terms form part of the unified global legal framework governing the ORO Marketplace Platform, including the Privacy Policy, Accessibility & Voice Policy, Community Guidelines, Safety Framework, Refund Policy, and all related legal disclosures published by Oro Technologies LLC.

Continued access to or use of the Platform constitutes legally binding acceptance of all applicable policies and future updates.

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