Governance & Strategy

Q4 Oct-Dec 2022: California "Do Not Sell " Notice

As discussed in more detail in our Privacy Notice we do not sell our users’ personal information in the traditional sense (i.e., in exchange for payment).

However, the California Consumer Privacy Act (“CCPA”) defines the term “sale” very broadly, including in such a way that transfers of information relating to advertising cookies could be considered a sale.  As described in our cookie policy [available on request] we work with certain third party services to assist us in delivering interest-based services to you.  

If you are a California resident, and to the extent that any of these services are considered a “sale” of personal information under the CCPA, then you have the right to opt out of the sale.  Below please find a description of the ways in which you may do so.  For further information on how California residents may exercise their rights, please see our Privacy Notice California residents’ CCPA sale opt-outs include:

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• By Selecting the “Cookie Preferences” Link Within Our Website Footer.  This empowers you to choose whether you would like to allow certain categories of cookies and similar technologies to collect information about your usage of our website. Please note that your selections are specific to the particular web browser and device that you use to make them, and so would need to be separately submitted on different browsers or devices. 
• By Using Industry-Developed Opt-Out Tools.  The Digital Advertising Alliance’s CCPA tool allows California consumers to opt out of the sale of personal information by some or all of that framework’s participating companies by accessing the DAA’s tool here: https://www.privacyrights.info/.  Please note that your selections are specific to the particular web browser and device that you used to make them.
  
• By Blocking Web Browser Cookies.  Many browser manufacturers provide helpful information about cookie management, including, but not limited to:
• Google Chrome
• Mozilla Firefox
• Safari (Desktop) or Safari (Mobile)
• Android Browser
• Opera
• Internet Explorer
  
• By Blocking Mobile Advertising Identifiers.  Your mobile device settings may provide you the ability to limit use of the advertising ID associated with your device for interest-based advertising purposes. Additional information can be found here: https://www.networkadvertising.org/mobile-choice.

This communication is approved by the Strategy Advisory & Leadership Team of Arabant Group.

Spokesperson

On behalf of the Arabant Group

Strategy Advisory & Leadership Team (SALT)

Q4 Oct-Dec 2022: Review of corporate structure 

Risk mitigation: Although the health and stability of group operations were largely unaffected by the 2008 financial crisis, the subsequent recession, and the pandemic - these extraordinary global factors gave rise to reviewing our exposure to a repeat or similar circumstances. Although having sufficient liquidity, after stress-testing our operating model, a decision was made to adopt further appropriate and robust measures to mitigate general uncertainty and the known and unknown economic risks. Ultimately, putting in place safeguards to protect financial security and stability.

Currency diversification and banking security: Our purpose and business model propose services worldwide. As a truly global entity subject to multi-jurisdictional regulatory requirements, there are significant and obvious benefits to handling corporate finances in a jurisdiction and with the protections of institutions with legal frameworks that better accommodate globalised operations.

Access to global investment: Having access to overseas/international financial institutions ensures we, as stewards of your interests, are not dependent upon one bank or institution. Therefore, it has been concluded that, on merit, diversification in holding multiple currencies helps mitigate our exposure to potential future risk.

The structure of the group and moving its registered location to a favourable jurisdiction seeks to safeguard our existence and reputation and supports the exploration of innovative products, services, and growth and expansion plans across all group interests. This aligns with the direction of our strategy advisory and leadership team and accounting and legal advisors.

Timing: Consultation started while pandemic travel restrictions were in force. This included dialogue with PriceWaterhouseCoopers the second-largest global accounting firm as well as Maples and others. Scheduling business migration needed to be at a time of minimal disruption. A difficult undertaking given all the factors. With all core elements considered, having migration coincide with the migration of our web presence presented the most opportune timing.

Location: In determining an appropriate jurisdiction, our review and ultimate selection have primarily been guided by the intelligence provided by Transparency International,  Organisation for Economic Co-operation and Development (OECD) as well as Bloomberg, Economist Intelligence, Fitch, Global Economy, International Monetary Fund, Lowy Institute, Office of National Statistics (ONS), Statista, Verisk Maplecroft - Environmental, Social, and Governance (ESG) data, World Bank - World Governance Indicators (WGIs)

This communication is approved by the Strategy Advisory & Leadership Team of Arabant Group.

Spokesperson

On behalf of the Arabant Group

Strategy Advisory & Leadership Team (SALT)

Q1 Jan-Mar 2023: Compliance and conduct in relation to United Nations Modern Slavery Acts 

Arabant Group is committed to combatting slavery and human trafficking. Arabant Group recognises that slavery and human trafficking are still a reality in our society and will not tolerate slavery and human trafficking in our business or supply chain.

Arabant Group is committed to acting ethically and with integrity in all its dealings and relationships and has taken steps to implement safeguards, measures, and controls to ensure that any form of slavery is not taking place in our operation or across our vendors, suppliers, operational partners (“VSOP”).
 

Our commitment to integrity and ethical behaviour is of the utmost importance, without which we would be unable to provide the experiences that have become our hallmark. In the spirit of this commitment, our conduct is in strict compliance with all applicable laws and regulations of the United States, United Kingdom, European Union, countries and regions in which we operate. We also manage our activities in accordance with our high standards of conduct and civilised societal expectations.
 

Organisation’s structure: Arabant Group currently operates worldwide across four regions; the Americas, the Middle East, Europe, and Asia.

Headquarters and place of effective management is currently in transition from the Middle East to an offshore jurisdiction – refer to our Governance and strategy statement.
 

Our activities: Activities include Non-scheduled passenger air transport, Management consultancy activities other than financial management, support services, and community membership activities.

Relevant policies and practices: Arabant Group operates a number of internal policies to ensure that its business is conducted in an ethical and transparent manner.

These include:

• Arabant Group operates a robust recruitment policy, including conducting eligibility to work for any and all employees to safeguard against human trafficking or individuals being forced to work against their will.
• Arabant Group is committed to compliance with all laws in every country where it operates. We require all our vendors, suppliers, and operational partners (“VSOP”) to manage their activities to comply with all laws, rules, safety regulations, and operating policies.
• Prohibited Practices – Arabant Group holds an unwavering position against corruption (USA Foreign Corrupt Practices Act of 1977) and bribery (UK Bribery Act 2010) and expects aligned compliance with anti-bribery and anti-corruption laws.
• Health and Safety – Arabant Group’s approach is to ensure provide and support a safe, equitable, and healthy working environment for those who are engaged in activities either acting for or on behalf of Arabant      Group interests and the entities that it governs.
• Whistle-blowing and Reporting – all vendors, suppliers, and operational partners are obliged to raise observations or concerns about treatment or practices in connection with the Arabant Group without fear of reprisal. This includes from or in relation to our VSOPs.
• Arabant Group's VSOPs’ are based throughout the world and include, but are not limited to aircraft operators, accommodations,      health and wellbeing establishments, retailers, providers of various services,      and support functions. The Group conducts due diligence on all suppliers before allowing them to start rendering any service or deliver any product. This due diligence includes assessing regulatory licences and certificates, compliance with such regulatory bodies, checks to determine the financial stability and ethics of the supplier as well as carrying out other audits, where appropriate.

Further steps
Arabant Group intends to continue to take the following further steps to combat slavery and human trafficking:

1. Notify all existing suppliers of Arabant Group expectations and their obligations in relation to the prohibition of modern slavery while asking them to complete a Code of Conduct questionnaire/disclosure before engaging in any contracts;
2. Require our suppliers to complete a Code of Conduct questionnaire/disclosure before engaging in any contracts;
3. Include appropriate measures in Arabant Group due diligence processes for sourcing suppliers, subcontractors and acquisitions on a risk-assessed basis;
4. Provide training across Arabant Group interests and the entities that it governs to ensure a high-level understanding of the risks of modern slavery and human trafficking; and
5. Where appropriate Arabant Group will include a reference to the Modern Slavery Acts in our policies and procedures.

[Awaiting release approval]

Spokesperson

On behalf of the Arabant Group

Strategy Advisory & Leadership Team (SALT)

Q1 Jan-Mar 2023: Declaration of Intent

Arabant Group's top-level ethos, applicable to all group entities, is to maximise shareholder value in a socially responsible manner by paying all required taxes in the jurisdictions in which we operate. We execute our strategy based on a set of principles that enable Arabant Group interests and the entities that it governs to align our commitments to our shareholders and our obligation to the tax authorities and communities around the world in which Arabant Group operates.

Arabant Group Holdings LLC regards the publication of this tax strategy as complying with its obligations under paragraph 16(2) of Schedule 19 of the Finance Act 2016 of the United Kingdom.

Arabant Group Holdings LLC is publishing this strategy in its capacity as centralised governance which includes Europe, Luxembourg, the Kingdom of Saudi Arabia, and the United Arab Emirates, (subject to change without notice).

This statement, approved by the strategy, advisory & leadership Team (SALT), sets out the Group’s intended approach to conducting its tax affairs and dealings with tax risks for the year ending 31 December 2023.

The  Group is exposed to a variety of tax risks as follows:

Compliance and reporting risks: These are risks associated with non-compliance such as submission of late or inaccurate returns, or where systems and processes do not adequately support tax compliance and reporting requirements.

Transactional risks: Risks associated with undertaking transactions without appropriate consideration of the potential tax consequences or where advice taken is not correctly implemented.

Reputational risks: Non-financial tax risks that may have an impact on our relationships with our clients, audiences, shareholders, tax authorities, and the general public. Tax risks are assessed on a case-by-case basis, in order to arrive at well-reasoned conclusions on how each individual risk should be managed. In assessing tax risks associated with any specific situation, we will consider the legal and fiduciary duties of directors and employees; the requirement of related internal policies, the financial and commercial consequences; and the impact on relationships with our clients, audiences, shareholders & tax authorities. Where there is uncertainty in how the relevant tax law should be applied, external professional advice will be sought to support the decision-making process. The accountable group official or Risk and Capital representative is responsible for identifying and monitoring tax risks across the group and keeps the board updated with significant matters on a regular basis.

We believe in safeguarding our reputation and relationships with members, audiences, shareholders, and tax authorities alike. Therefore, we do not promote abusive tax practices which would contravene our ethics and culture or the legislation in any jurisdiction.

The Group does not engage in tax planning in circumstances where it expects the planning to lead to an abusive result. We only engage in reasonable tax planning aligned with the interests of our stakeholders and economic activity. Where alternative routes exist to achieve the same commercial results, the most tax-efficient approach in compliance with all relevant laws will be followed. We always seek to interpret relevant tax laws and apply exemptions & incentives in a reasonable way taking external professional advice on these in appropriate cases.

The Group’s appetite for tax risk is governed by our overriding commitment to observing all applicable laws, rules, regulations, and reporting and disclosure requirements when there is a requirement to do so as a result of our business transactions. We aim to pay the right amount of tax in accordance with the spirit of the law in all jurisdictions. Where there is a level of uncertainty regarding the interpretation of a point of tax legislation, we would always seek professional tax advice and as much as possible take a position that if challenged, is more likely than not, to be seen by the tax authorities as a reasonable application of the law.

The Group is committed to the principles of openness and transparency in our approach to our dealings with tax authorities. All dealings with tax authorities and other relevant bodies will be conducted in a collaborative manner and will seek to achieve agreement and certainty on a real-time basis wherever practicable. We aim to work positively, proactively, and transparently with tax authorities, to achieve early agreement on disputed issues wherever possible.

This communication is approved by the strategy, advisory & leadership team of Arabant Group.

Spokesperson

On behalf of the Arabant Group