Q4 Oct-Dec 2022: Special Category Processing & Safeguarding Controls

Arabant Group – AMERA Private Network: Family Mobility & Assistance Division

This Annexe supplements the Privacy Policy of Arabant Group and AMERA Private Network and sets out the internal governance framework governing:

• Lawful basis determination
• Special category and criminal record data processing
• Safeguarding-related administration
• Cross-border data handling controls
   

Processing activities are conducted in accordance with:

• UK GDPR
• EU GDPR (where applicable)
• Data Protection Act 2018
• Applicable safeguarding legislation
• Relevant cross-border data transfer frameworks
   

This Annexe is intended for regulatory, audit, and legal review purposes.

• Identity data (passport, national ID)
• Contact data
• Employment and professional history
• Professional qualifications
• References
• Right-to-work documentation
   

Where necessary and proportionate, the Division may process:

• Criminal record data (DBS or equivalent)
• Professional regulatory standing
• Health-related credentials (for medical practitioners)
   

Such processing is limited strictly to safeguarding, compliance, and professional integrity assessment.

The Division relies upon the following lawful bases:

Processing is necessary to take steps at the request of the data subject prior to entering into a registry agreement.

Applies to:

• Application review
• Credential verification
• Suitability assessment
• Registry admission determination
   

Without such processing, entry into a registry agreement is not possible.

Processing is necessary for legitimate interests, including:

• Safeguarding children and vulnerable persons
• Protecting diplomatic and private households
• Maintaining registry standards
• Risk mitigation in cross-border mobility engagements
   

A Legitimate Interests Assessment (LIA) framework is applied where appropriate to confirm proportionality and balance against data subject rights.

Where criminal record or special category data is processed, the Division relies on:

Processing necessary for employment, social protection, or professional placement-related obligations, where relevant.

Processing is necessary for the safeguarding of children and vulnerable individuals and for ensuring trust within high-security domestic, diplomatic, and private office environments. Schedule 1, Part 2 of the Data Protection Act 2018 is relied upon where applicable.

• DBS certificates are reviewed for verification purposes.
• Full certificates are not retained longer than strictly necessary.
• Where feasible, only:
  • Certificate number
  • Date of issue
  • Outcome status
    are retained for compliance records.
     

Retention of full copies is avoided unless operationally justified.

• Documentation retained solely for review determination.
• Secure deletion within defined review period (maximum 14 days post-determination unless legally required otherwise).
• Deletion logged internally.
   

• Credentials retained only for the duration necessary to maintain registry standing and safeguarding compliance.
• Periodic review cycle applied (12 / 24 / 36-month tiers where relevant).
• Expired credentials removed or refreshed as required.
   

• Role-based access restrictions applied within HubSpot and associated systems.
• No distribution of credential documentation via unsecured email.
• No local desktop storage outside a secure environment.
• Encrypted storage where applicable.
• Limited authorised personnel access only.
   

Internal access logs are maintained where technically feasible.

Given the international scope of:

• Diplomatic households
• Family Offices
• Cross-border relocations
  

Data may be accessed across jurisdictions.

Where international transfers occur:

• Adequacy regulations are relied upon where applicable.
• Standard Contractual Clauses (SCCs) or equivalent safeguards are implemented where required.
• Data minimisation principles apply to cross-border access.
   

No unnecessary duplication of sensitive documentation occurs across jurisdictions.

Applicants and Registry Members retain:

• Right of access
• Right to rectification
• Right to erasure (subject to safeguarding or compliance constraints)
• Right to restriction
• Right to object (where processing is based on legitimate interests)
   

Requests are processed in accordance with statutory timelines.

Given the safeguarding and criminal record elements involved, the Division maintains an internal DPIA addressing:

• Risk to data subjects
• Safeguarding sensitivity
• Diplomatic household confidentiality
• Cross-border processing risk
• Retention and deletion controls
   

The DPIA is reviewed periodically or when material operational changes occur.

The Family Mobility & Assistance Division operates within environments requiring heightened trust and discretion, including:

• Diplomatic residences
• Internationally mobile UHNW households
• Family offices managing vulnerable family members
• Cross-border relocation structures
   

Data processing is structured to:

• Protect minors and vulnerable individuals
• Maintain professional registry integrity
• Reduce reputational and operational risk
• Ensure proportionate and legally defensible credential administration
   

This Annexe is:

• Reviewed periodically
• Subject to internal compliance oversight
• Available for legal counsel review
• Updated where regulatory frameworks evolve

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: 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:

‍

• 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 delivering 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

Q2 Apr-Jun 2025: Dubai "Website use"

Arabant Group Limited

Effective: June 8, 2025 [Accessed here]

Updated: February 20, 2026
Approved by: Strategy Advisory & Leadership Team (SALT)

This website (the “Website”) is owned and operated by Arabant Group Limited, a company incorporated in England and Wales (Company Number: 08055793) (the “Company”), together with its subsidiaries, affiliated entities and controlled undertakings (collectively, “Arabant Group” or the “Group”).

These Terms of Use (the “Terms”) govern access to and use of the Website and all materials made available through it.

By accessing or using the Website, you agree to be legally bound by these Terms. If you do not accept these Terms, you must cease use immediately.

The Group reserves the right to amend these Terms at any time in accordance with applicable corporate governance procedures.

The Website is provided solely for corporate, informational, and strategic communication purposes.

Nothing on the Website constitutes:

• An offer to sell or solicitation to buy securities
• A financial promotion
• A prospectus
• Regulated investment advice
• Asset management services
• Aviation brokerage
• Air carriage services
• Fiduciary or advisory services
   

Where regulated activities are undertaken, they are conducted exclusively by appropriately authorised subsidiaries in accordance with applicable licensing requirements.

The Website does not constitute regulated activity in any jurisdiction.

The Website is not intended to constitute, and does not constitute, a financial promotion for the purposes of Section 21 of the Financial Services and Markets Act 2000 (“FSMA”).

No Content constitutes:

• An invitation or inducement to engage in investment activity
• An offer of securities
• A recommendation relating to investments
   

The Website is provided solely for general informational purposes.

Arabant Group Limited is not authorised or regulated by the UK Financial Conduct Authority unless expressly stated in relation to a specific regulated subsidiary.

Any regulated activities are conducted only by entities holding the required regulatory permissions.

Where Content could be regarded as a financial promotion in any jurisdiction, it is directed only at persons who may lawfully receive such communications, including professional clients or eligible counterparties, where applicable.

The Website is not directed at retail investors.

All materials available on the Website, including but not limited to:

• Articles
• Research papers
• Aviation analysis
• Structuring models
• Strategic frameworks
• Advisory methodologies
• Business models
• Documents
• Images and aircraft photography
• Logos and trademarks
• Graphics and design
• Databases
• Downloadable materials
   

(collectively, the “Content”) are the exclusive property of Arabant Group or its licensors.

All rights are reserved.

The Content is protected by copyright, database rights, trademark law, design rights, trade secret protections, and international intellectual property conventions.

The Group’s proprietary methodologies, aviation access structures, capital frameworks, asset-liability models, and advisory concepts constitute confidential intellectual property.

Unauthorised replication, reverse engineering, competitive benchmarking, derivative modelling, or commercial exploitation is strictly prohibited and may give rise to injunctive relief and damages.

Users may not:

• Deploy bots, crawlers, scraping tools, or automated extraction technologies
• Conduct data mining or systematic harvesting
• Use Content to train artificial intelligence or machine learning systems
• Reproduce proprietary research for algorithmic modelling
• Store Content for competitive commercial exploitation
   

The Group reserves the right to pursue technical and legal remedies.

References to aircraft acquisition, leasing, charter, fractional ownership, air mobility solutions, or aviation structuring are informational only.

The Website does not:

• Constitute an Air Operator Certificate (AOC)
• Provide air carrier services
• Act as principal in charter contracts unless expressly disclosed
• Guarantee aircraft availability or regulatory approval
   

All aviation operations are conducted by appropriately licensed operators holding valid regulatory authorisations.

Aircraft transactions remain subject to civil aviation regulations, bilateral agreements, airworthiness directives, sanctions compliance, export controls, customs permissions, and operational safety determinations.

Users must obtain independent aviation, legal, tax, and regulatory advice.

The Group recognises and adheres, where applicable, to sanctions regimes administered by:

• The United Nations Security Council
• The United Kingdom (OFSI)
• The European Union
• The United States (OFAC)
• The United Arab Emirates
• Other competent authorities with jurisdiction
   

The Website does not constitute an invitation to transact with sanctioned persons or jurisdictions.

The Group recognises the potential extraterritorial application of secondary sanctions, including under US law.

Nothing on the Website constitutes endorsement of activity that could trigger secondary sanctions exposure.

Aircraft, avionics, components, and technical data may be subject to export control regimes including:

• UK export control legislation
• EU Dual-Use Regulation
• US Export Administration Regulations (EAR)
• US International Traffic in Arms Regulations (ITAR)
• UAE export control laws
   

The Group does not guarantee export approvals or regulatory clearances.

Users are responsible for compliance with applicable export laws.

The Group operates a risk-based compliance framework consistent with:

• UK Money Laundering Regulations
• EU AML Directives
• UAE AML/CFT legislation
• FATF recommendations
• Applicable US AML statutes
   

The Group may conduct identity verification, beneficial ownership checks, sanctions screening, and enhanced due diligence.

Engagement is conditional upon satisfactory compliance verification.

The Group operates in accordance with:

• The UK Bribery Act 2010
• The US Foreign Corrupt Practices Act (FCPA)
• Applicable anti-corruption laws
   

Bribery, facilitation payments, or improper inducements are strictly prohibited.

The Group supports responsible governance, environmental stewardship, and human rights principles.

The Group may publish separate Modern Slavery and ESG statements in accordance with applicable legislation.

The Website is provided for general information only. It does not constitute financial, legal, aviation, tax, or strategic advice.

Forward-looking statements involve risks and uncertainties. Actual results may differ materially.

To the fullest extent permitted by law:

• The Website is provided “as is” and “as available”.
• All warranties, express or implied, are disclaimed.
   

The Group shall not be liable for direct or indirect losses, loss of profit, business interruption, aviation operational losses, regulatory penalties incurred by third parties, or cybersecurity incidents beyond reasonable control.

Nothing excludes liability that cannot lawfully be excluded under the laws of England and Wales.

The Website may reference third-party operators, regulators, or service providers.

Such references do not constitute endorsement.

The Group accepts no responsibility for third-party content or compliance.

The Group employs enterprise-level cybersecurity safeguards but does not guarantee uninterrupted or error-free access.

Users are responsible for implementing appropriate security protections.

The Group operates within a formal governance and compliance framework overseen by its Board and Strategy Advisory & Leadership Team (SALT).

Public representations on the Website are supported by internal policies, which may include:

• Sanctions Compliance Policy
• Export Controls Policy
• AML/CFT Manual
• KYC Procedures
• Anti-Bribery & Corruption Policy
• Aviation Regulatory Compliance Framework
• Data Protection Policy
• ESG and Responsible Governance Policy
• Modern Slavery Statement
• Whistleblowing Procedures
   

Access to or use of the Website does not waive or limit the Group’s compliance requirements.

Any prospective engagement remains subject to compliance verification, regulatory clearance, and appropriate approval thresholds.

The Group reserves the right to:

• Restrict or suspend access
• Amend or withdraw Content
• Enforce intellectual property rights
• Pursue injunctive or equitable remedies
   

without prior notice.

These Terms are governed by the laws of England and Wales.

The courts of England and Wales shall have exclusive jurisdiction.

Publisher:
Arabant Group Limited
Registered in England and Wales
Company Number: 08055793
Registered Office: United Kingdom

Hosting Provider:
GoDaddy
100 S. Mill Ave, Suite 1600
Tempe, Arizona 85281, USA

Legal and compliance enquiries:
group@arabantgroup.com

Q2 MAY 2025: Merit, Excellence, and Intelligence (MEI)

At our core, we believe in hiring the best possible person for every role, regardless of demographics. We do not use quota-based hiring or adjust our workforce composition to meet demographic targets.

That does not mean we undervalue diversity. On the contrary, we actively cultivate diverse pipelines and ensure a broad, inclusive candidate pool for every position. But when it comes to the final decision, merit, capability, and potential are what matter most.

We operate in a highly competitive industry that demands exceptional intelligence, skill, and adaptability. Our success depends on surrounding ourselves with individuals who are not only talented, but also driven to excel at the highest level.

Here, excellence isn’t just encouraged. It’s expected.

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

Spokesperson

On behalf of the Arabant Group

Q2 June 8 2025: INTER-ORGANISATION LICENSING AGREEMENT 

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

Spokesperson

On behalf of Arabesque International