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GLOBAL SAFETY AND DRIVER CONDUCT POLICY

ORO TECHNOLOGIES LLC (GLOBAL HOLDING STANDARD)

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1. GLOBAL SAFETY COMMITMENT

Oro Technologies LLC, together with its affiliates, subsidiaries, independent operators, and related entities (collectively, “ORO”), maintains operational safety-oriented standards and compliance-focused platform governance measures across all jurisdictions in which it operates.

All drivers using the ORO platform are solely responsible for operating their vehicles safely, complying with all applicable traffic laws, regulations, and local legal requirements.

ORO operates exclusively as a technology intermediary platform and does not control or direct drivers’ conduct; however, ORO enforces strict safety standards through its platform governance systems.

The establishment, publication, implementation, or enforcement of safety-related standards, community rules, accessibility expectations, platform requirements, verification procedures, educational materials, safety recommendations, or compliance measures shall not be interpreted as creating any duty of supervision, control, monitoring, inspection, management, employment, agency, transportation responsibility, public-safety obligation, or heightened duty of care on the part of ORO.

ORO does not supervise, monitor, direct, or control drivers in real time and does not guarantee the conduct, decisions, actions, qualifications, licensing status, safety practices, or legal compliance of independent third-party providers.

Failure to comply with these standards may result in immediate restriction, suspension, or permanent deactivation of access to the platform, without prior notice, where legally permitted.

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2. NO EMPLOYMENT OR CONTROL RELATIONSHIP

Drivers using the ORO platform are independent service providers and are not employees, agents, representatives, or partners of ORO.

Nothing in this policy shall be interpreted as creating any employment, agency, joint venture, or fiduciary relationship.

Drivers retain full responsibility for:

  • Compliance with accessibility obligations applicable under local law

  • Interactions with elderly passengers, vulnerable individuals, or passengers requiring accommodations

  • Operation of any assistive, accessibility-related, or mobility-support equipment

  • Their conduct

  • Compliance with laws

  • Operation of their vehicles

  • Personal and third-party safety

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2A. NO TRANSPORTATION PROVIDER STATUS

ORO is not a transportation carrier, common carrier, motor carrier, taxi company, limousine service, shuttle operator, logistics provider, delivery company, public transportation provider, emergency transportation provider, medical transportation provider, or transportation network operator.

ORO does not own, lease, operate, manage, maintain, dispatch, control, or provide vehicles, drivers, transportation services, transportation routes, transportation equipment, transportation personnel, or transportation operations.

All transportation services are offered exclusively by independent third-party providers who operate independently from ORO and assume sole responsibility for transportation activities, regulatory compliance, vehicle operation, passenger interactions, and service delivery.

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2B. NO GUARANTEE OF DRIVER AVAILABILITY OR SERVICE FULFILLMENT

ORO does not guarantee the availability, acceptance, performance, timeliness, suitability, proximity, qualifications, responsiveness, accessibility accommodations, service completion, or continued participation of any independent driver, transportation provider, or third-party service provider.

Driver availability may vary based on geographic location, market conditions, regulatory restrictions, accessibility requirements, technological limitations, operational factors, user demand, or independent provider decisions.

ORO makes no representation, warranty, or guarantee that any transportation request will be accepted, fulfilled, completed, or successfully matched with an independent provider.

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3. DANGEROUS DRIVING

Dangerous driving is strictly prohibited and includes any behavior that endangers passengers, pedestrians, or other road users.

This includes, but is not limited to:

  • Distracted driving (use of mobile devices, eating, interacting with devices)

  • Failure to maintain attention on the road

  • Erratic driving behavior

  • Excessive speeding

  • Harsh braking or acceleration

  • Failure to comply with traffic signals or laws

Driving while fatigued or impaired in any way is considered a form of dangerous driving.

Unsafe interaction with accessibility-dependent passengers or failure to exercise reasonable care toward vulnerable users may also be considered a violation of platform safety standards.

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4. DRIVER FATIGUE AND DROWSINESS

Driving while fatigued presents a significant safety risk and is strictly prohibited.

Indicators of Driver Fatigue

  • Visible exhaustion

  • Frequent yawning

  • Difficulty keeping eyes open

  • Lane drifting

  • Slow reaction times

  • Head nodding or repeated blinking

Risks

  • Reduced response time

  • Impaired judgment and concentration

  • Microsleep episodes

  • Increased likelihood of accidents

Preventive Measures

Drivers are solely responsible for ensuring fitness to drive, including:

  • Adequate rest (adequate rest consistent with safe driving practices)

  • Taking breaks every 2 hours or approximately every 160 km

  • Avoiding alcohol or substances that impair alertness

  • Not relying on stimulants (e.g., caffeine) as a substitute for rest

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5. ZERO TOLERANCE POLICY

ORO enforces a strict zero tolerance policy for the following conduct:

  • Driving under the influence of alcohol, drugs, or controlled substances

  • Reckless or aggressive driving

  • Harassment, intimidation, or threatening behavior

  • Discrimination of any kind

  • Use of offensive or abusive language

  • Sexual misconduct, harassment, or assault

Any violation may result in immediate and permanent deactivation, and may be reported to competent authorities where required by law.

Discrimination involving disability status, service animals, assistive devices, age, accessibility accommodations, or vulnerable-user conditions

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6. USER REPORTING AND SAFETY CHANNELS

Passengers and users may report unsafe behavior through:

  • The ORO mobile application

  • Customer support channels

In emergency situations, users must contact local emergency authorities immediately.

In the United States: dial 911
Where available, users may also utilize the in-app emergency (SOS) feature.

ORO does not replace or act as an emergency response provider.

Where available, emergency alerts generated through the Platform may be transmitted to independent third-party emergency-coordination providers, security vendors, monitoring companies, or emergency-assistance partners operating independently from ORO.

Such third parties are not employees, agents, representatives, affiliates, subsidiaries, or controlled entities of ORO.

ORO does not control, supervise, direct, monitor, guarantee, or assume responsibility for any action, omission, escalation decision, response time, communication outcome, dispatch determination, emergency assessment, or intervention performed by any independent emergency-coordination provider or governmental authority.

Emergency-related tools, S.O.S. systems, voice-trigger functionalities, and safety features are provided on an “AS IS” and “AS AVAILABLE” basis and depend on third-party infrastructure, connectivity, device functionality, and external emergency-response systems.

Users expressly acknowledge that activation of an SOS feature does not guarantee transmission, receipt, review, escalation, response, intervention, rescue, law-enforcement involvement, emergency assistance, medical assistance, security assistance, or successful communication with any third party.

Technical failures, device limitations, connectivity interruptions, software malfunctions, human error, third-party infrastructure failures, telecommunications disruptions, jurisdictional limitations, or external emergency-response failures may prevent the successful operation of emergency-related functionalities.

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7. INVESTIGATION AND ENFORCEMENT

All reports are subject to internal review and risk assessment.

ORO reserves the right, at its sole discretion and to the maximum extent permitted by law, to:

  • Issue warnings

  • Temporarily suspend accounts

  • Permanently deactivate accounts

  • Restrict access to platform features

Actions may be taken without prior notice, particularly in cases involving safety risks, suspected fraud, or legal requirements.

Repeated or severe violations will result in permanent removal from the platform.

ORO reserves sole and absolute discretion regarding whether, how, or to what extent any report, complaint, allegation, or safety concern is reviewed, escalated, investigated, or acted upon.

Nothing in this Policy shall be interpreted as creating an obligation for ORO to investigate, verify, resolve, adjudicate, monitor, intervene in, or prevent any reported conduct, safety concern, dispute, criminal activity, transportation incident, accessibility-related event, or alleged violation.

​ORO may cooperate with governmental authorities, regulatory agencies, law-enforcement bodies, courts, administrative agencies, emergency-response organizations, or legally authorized third parties where required by applicable law, legal process, court order, subpoena, regulatory request, governmental inquiry, or legitimate safety-related necessity.

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8. FALSE REPORTING AND PLATFORM ABUSE

All reports are evaluated under internal verification protocols.

  • ORO implements internal review procedures intended to reduce the impact of knowingly false, malicious, or abusive reports.

  • Users submitting fraudulent, malicious, or misleading reports may be subject to account suspension or permanent removal

Any abuse of safety reporting mechanisms is strictly prohibited.

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9. ACCOUNT DEACTIVATION CRITERIA

Drivers may lose access to the platform due to:

  • Expired, invalid, or fraudulent documentation

  • Failed or negative background verification

  • Engagement in illegal or fraudulent activity

  • Unsafe, inappropriate, or prohibited conduct

  • Repeated or severe complaints

  • Persistently low performance ratings

  • Violation of platform terms or policies

  • Accessibility-related misconduct

  • Refusal to comply with applicable service-animal requirements

  • Repeated accessibility complaints

  • Threatening behavior toward elderly or vulnerable users

Account restrictions may be temporary during investigation processes.

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10. VEHICLE SAFETY AND COMPLIANCE

Drivers must ensure that any vehicle used on the platform:

  • Is authorized and registered within the platform

  • Meets all applicable legal and safety requirements

  • Is maintained in safe operating condition

  • Has valid and up-to-date documentation

Non-compliance includes, but is not limited to:

  • Defective brakes, tires, or safety systems

  • Ignoring vehicle safety warnings

  • Failure to update vehicle information

ORO does not independently inspect, certify, guarantee, verify, supervise, or continuously monitor the mechanical condition, roadworthiness, safety status, legal compliance, maintenance quality, inspection history, or operational suitability of vehicles used by independent providers.

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10A. LOST PROPERTY DISCLAIMER

Users acknowledge that ORO does not possess, store, transport, recover, secure, inventory, manage, or control personal property left inside vehicles operated by independent third-party providers.

Any recovery of lost items is solely a matter between the user and the independent provider.

ORO may, but is under no obligation to, facilitate communication between users and providers regarding lost property.

To the maximum extent permitted by law, ORO disclaims all liability arising from lost, stolen, damaged, misplaced, abandoned, or unrecovered personal property.

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11. BACKGROUND CHECKS AND CONTINUOUS VERIFICATION

Drivers agree to ongoing verification processes, where permitted by law.

Drivers may be disqualified for:

  • Serious criminal convictions

  • Violent or sexual offenses

  • Driving under the influence (DUI/DWI)

  • History of dangerous driving

  • Submission of false or incomplete information

Verification standards may vary by jurisdiction in accordance with local laws.

Background verification procedures may involve third-party screening providers and may vary depending on jurisdictional availability, regulatory restrictions, and applicable laws.

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NO GUARANTEE OF BACKGROUND CHECK COMPLETENESS

11A. LIMITATIONS OF BACKGROUND VERIFICATION SYSTEMS

ORO utilizes commercially reasonable third-party verification providers, screening technologies, and compliance procedures where permitted by applicable law.

However, users expressly acknowledge that background checks, identity verification systems, driving history reviews, criminal database searches, and compliance screenings may be limited by:

jurisdictional restrictions;

data availability limitations;

government reporting delays;

sealed or expunged records;

cross-border verification limitations;

third-party reporting inaccuracies;

or legal restrictions applicable in certain territories.

Accordingly, ORO does not guarantee the completeness, accuracy, real-time availability, or ongoing validity of any background verification process.

Nothing in this Policy shall be interpreted as a guarantee of future conduct, safety outcome, behavioral reliability, or risk-free interactions involving independent Providers or users.

Users expressly acknowledge that background-screening procedures are risk-mitigation tools only and are not intended to predict future behavior, guarantee personal safety, eliminate criminal risk, verify ongoing compliance, or certify the suitability of any individual.

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12. PLATFORM CONDUCT AND USER BEHAVIOR

All users are required to maintain respectful and lawful behavior when using the platform.

Prohibited behavior includes:

  • Aggressive or unsafe conduct

  • Sharing inappropriate or harmful content

  • Creating unsafe situations for others

  • Harassment, abuse, discrimination, intimidation, or exploitation involving elderly individuals, persons with disabilities, or vulnerable users

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13. FRAUD, MISUSE AND SYSTEM MANIPULATION

Any attempt to:

  • Manipulate platform systems

  • Circumvent safeguards

  • Commit fraud

  • Exploit platform vulnerabilities

may result in immediate suspension or permanent account termination, and potential legal action.

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14. LIMITATION OF LIABILITY AND RISK ALLOCATION

To the maximum extent permitted by applicable law:

  • ORO shall not be liable for the conduct of drivers or users

  • ORO does not guarantee safety outcomes

  • ORO does not guarantee the prevention of accidents, criminal conduct, misconduct, assault, theft, harassment, accessibility-related incidents, medical emergencies, transportation disputes, communication failures, emergency-response outcomes, property damage, personal injury, or death.

  • ORO does not control real-world interactions

  • ORO operates solely as a technology intermediary platform connecting independent users.

ORO shall not be liable for:

  • Indirect, incidental, consequential, or punitive damages

  • Loss of income, data, goodwill, or reputation

  • Personal injury or property damage arising from third-party conduct

ORO shall not be liable for criminal acts, alleged criminal acts, intentional misconduct, violent acts, assault, battery, theft, robbery, kidnapping, harassment, sexual misconduct, fraud, property crimes, personal injury, death, or any other unlawful conduct committed by independent third parties.

ORO does not guarantee uninterrupted platform availability, emergency response effectiveness, accessibility compatibility, successful voice-recognition processing, or the operational continuity of third-party systems.

​ORO shall not be liable for criminal acts, intentional misconduct, violent acts, assault, battery, theft, robbery, kidnapping, harassment, sexual misconduct, fraud, property crimes, personal injury, death, or any other unlawful conduct committed by independent third parties.

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15. PLATFORM PROTECTION AND DISCRETIONARY ACTIONS

ORO reserves the right, at its sole discretion and without prior notice, to:

  • Suspend or terminate accounts

  • Restrict access to services

  • Investigate suspicious activity

when necessary to protect:

  • User safety

  • Platform integrity

  • Legal compliance

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16. ACCESSIBILITY, ELDERLY USERS & VULNERABLE INDIVIDUALS DISCLAIMER

ORO operates a voice-first, accessibility-oriented technology platform intended to improve usability and digital inclusion for elderly users, individuals with disabilities, visually impaired users, mobility-impaired individuals, users relying on assistive technologies, and vulnerable populations.

Accessibility-oriented functionalities, voice-enabled technologies, assistive interaction systems, communication tools, AI-assisted features, accessibility prompts, service-animal accommodations, and related technological resources are intended solely to facilitate technological accessibility and user inclusion and shall not be interpreted as guarantees of accessibility outcomes, safety outcomes, transportation suitability, caregiving assistance, supervision, monitoring, protection, or individualized accommodation.

However, ORO does not provide:

medical supervision;

caregiving services;

assisted-living services;

mental-health services;

mobility assistance services;

custodial supervision;

or emergency monitoring services.

Drivers remain independent third-party providers solely responsible for complying with applicable accessibility obligations under local law.

ORO does not guarantee that all accessibility features, voice-recognition technologies, assistive systems, service-animal accommodations, GPS systems, AI-assisted tools, or third-party technologies will operate uninterrupted or without error.

Voice-recognition systems, speech-to-text systems, AI-assisted accessibility technologies, voice-trigger functionalities, language-processing systems, contextual interpretation engines, and accessibility automation tools may generate errors, omissions, delays, inaccurate outputs, unintended activations, misunderstood commands, or failed executions.

Such technologies are assistive tools only and are not intended to replace human judgment, emergency decision-making, professional assistance, transportation safety obligations, or legally required accessibility accommodations.

Users requiring continuous supervision, medical assistance, physical support, or caregiving services must rely on qualified caregivers, guardians, companions, or emergency services, and not on the Platform or independent drivers.

To the maximum extent permitted by law, ORO disclaims liability arising from accessibility misunderstandings, voice-processing errors, assistive-device disputes, service-animal conflicts, or third-party conduct involving vulnerable users.

​Elderly users, vulnerable individuals, persons with disabilities, visually impaired users, mobility-impaired users, and users requiring ongoing supervision acknowledge that the Platform is not a substitute for caregivers, guardians, medical personnel, personal assistants, family supervision, emergency-response services, or professional support providers.

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16A. NO DUTY TO MONITOR, SUPERVISE OR PROTECT

ORO does not undertake, assume, create, or accept any duty to monitor, supervise, review, inspect, evaluate, prevent, detect, investigate, intervene in, protect against, or respond to the conduct of users, drivers, providers, passengers, third parties, emergency situations, criminal acts, transportation incidents, accessibility-related events, or real-world interactions.

The existence of safety tools, reporting systems, accessibility technologies, voice-interaction systems, emergency functionalities, account-verification procedures, community standards, educational materials, fraud-prevention systems, or platform-enforcement mechanisms shall not be interpreted as creating any special relationship, protective obligation, rescue duty, fiduciary duty, public-safety responsibility, transportation obligation, or heightened duty of care on the part of ORO.

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16B. THIRD-PARTY TECHNOLOGY AND INFRASTRUCTURE

The Platform depends upon third-party technologies, telecommunications providers, cloud-service providers, mapping services, GPS providers, mobile-device manufacturers, operating systems, accessibility technologies, emergency-coordination providers, internet-service providers, and other external infrastructure.

ORO does not control and shall not be responsible for failures, interruptions, inaccuracies, outages, delays, security incidents, service degradations, or operational limitations arising from third-party systems or infrastructure.

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16C. FORCE MAJEURE AND UNCONTROLLABLE EVENTS

ORO shall not be liable for any delay, interruption, degradation, failure, inaccessibility, data loss, service disruption, emergency-functionality failure, communication failure, accessibility-system failure, matching failure, or inability to perform arising directly or indirectly from circumstances beyond ORO’s reasonable control.

Such circumstances include, without limitation:

natural disasters;

floods;

earthquakes;

fires;

epidemics;

pandemics;

governmental actions;

regulatory restrictions;

civil unrest;

terrorism;

war;

labor disputes;

internet outages;

telecommunications failures;

cyberattacks;

cloud-service interruptions;

electrical outages;

satellite failures;

GPS disruptions;

third-party infrastructure failures;

or any similar event beyond ORO's reasonable control.

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17. REGULATORY COMPLIANCE

Drivers are solely responsible for complying with:

  • Local transportation laws

  • Licensing requirements

  • Tax obligations

  • Insurance requirements

ORO does not assume responsibility for regulatory compliance by drivers.

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18. GLOBAL ENFORCEMENT STANDARD

This policy applies globally and may be enforced differently depending on jurisdiction, regulatory requirements, and risk factors.

ORO reserves the right to adapt enforcement measures to comply with local laws without prior notice.

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19. MODIFICATIONS

ORO may modify this policy at any time.

Continued use of the platform constitutes full acceptance of any updated version.

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20. GOVERNING LAW

This policy shall be governed by the laws of the State of Florida, United States, without prejudice to the mandatory application of local laws in relevant jurisdictions.

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21. INTEGRATION WITH OTHER POLICIES

This policy forms an integral part of ORO’s global compliance framework and must be read in conjunction with:

  • Terms and Conditions

  • Privacy Policy

  • Community Guidelines

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FINAL LEGAL NOTICE

By accessing or using the ORO platform, all users acknowledge and agree to be bound by this policy in its entirety.

Failure to comply may result in immediate and irreversible loss of access to the Platform, without liability to ORO Technologies LLC, its affiliates, subsidiaries, licensors, contractors, officers, directors, employees, shareholders, technology providers, or related entities, to the maximum extent permitted by applicable law.

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