Supply Chain Management

Security

Vantor’s Cybersecurity Program protects the assets, data and information of our team members, business, customers and partners on our network. We strive to educate our supply chain on the importance of adhering to cybersecurity controls and solicit questionnaire responses from our partners and subcontractors regarding their security posture.

Our Supplier Code of Conduct and contractual terms and conditions set clear expectations for suppliers to protect our confidential, proprietary and personal information. We prohibit suppliers from using Vantor information for any purpose beyond the scope and purpose of the parties’ supply agreement. Suppliers must also respect the rights of third parties, including third-party intellectual property. Third-party risk is assessed prior to a supplier processing, storing or transmitting Vantor information.

Vantor expects suppliers will implement practices and procedures to ensure the security of their supply chain. Suppliers and their upstream suppliers who either ship directly or package goods for shipment must comply with all requirements of SAFE Framework security programs of the destination country. Such programs include, for example, the Customs-Trade Partnership Against Terrorism Initiative of the U.S. Department of Homeland Security and other Authorized Economic Operator programs.

We also expect suppliers to develop, implement and maintain methods and processes appropriate to their products and services to minimize the risk of introducing counterfeit parts and materials into deliverable products. Effective processes should be in place to detect counterfeit parts and materials, as well as to mark parts obsolete as appropriate.

Vantor’s suppliers are responsible for safeguarding and protecting all information provided by Vantor, as well as information generated or developed in support of Vantor programs, from unauthorized access, destruction, use, modification or disclosure. Critical suppliers must have risk-based cybersecurity programs designed to mitigate threats to their information systems, products, services and supply chains and to comply with all applicable contractual and legal requirements. Vantor requires suppliers to self-certify their status related to recognized standards.

Human Rights and Conflict Minerals

We protect human rights across our company, and we expect the same of our partners, vendors and suppliers. Vantor’s policies, practices and procedures reflect a strong commitment to human rights as set forth in the United Nations Universal Declaration of Human Rights. As communicated in our Anti-Human Trafficking and Slavery Statement as well as our Human Rights Statement, we prohibit harassment, bullying, discrimination, use of child or forced labor or trafficking in persons for any purpose.

Vantor will not tolerate human trafficking, child labor or slavery in any part of our global organization or that of our suppliers. Additionally, Vantor expects suppliers to provide a healthy, safe and productive workplace where their team members and representatives are treated with respect, appreciation and dignity.

Supplier Due Diligence

Vantor monitors active third parties and suppliers to assess business risks, including the ability to comply with global anti-corruption and anti-bribery laws, such as the Foreign Corrupt Practices Act, the UK Bribery Act, Canada’s Corruption of Foreign Public Officials Act and the OECD Anti-Bribery Convention.Vantor conducts additional due diligence on suppliers that the business deems high-risk. During the screening process, high-risk third-parties are required to submit business information designed to better understand the potential risks associated with the supplier. For example, Vantor asks suppliers to identify if the organization conducts business in any countries that Vantor has determined to have heightened exposure to compliance, security and human rights risks.

Upon receipt of submitted responses, Vantor’s Compliance team will review a risk assessment report and apply risk-based criteria. Finally, the Compliance Office will advise of its recommended approval or denial based on risk. Due diligence renewals are based on risk; however, all third parties are continuously monitored for changes impacting their risk categorization. Higher-risk third parties should be reviewed annually while medium- to low-risk third parties should be reviewed prior to contract renewal.

Responsible Space Operations

We have entered an era where all nations and people benefit from the responsible use of space. It is critical for all operators to use the space environment responsibly by following best practices for space traffic management and advocating for sound policies. Vantor aims to be a leader in responsible space operations by promoting flight safety and helping mitigate the risks of space debris.

Flight Safety

Vantor publishes daily flight plans for our satellites on Space-Track, a website that supports space flight safety. These flight plans are predicted satellite trajectories that help satellite operators position satellites’ future locations to avoid collisions. We likewise use data from other satellite operators to avoid collisions with their satellites. We have automated processes to respond around the clock to close approaches with other satellites and cataloged space debris. Vantor encrypts commands to lock out hackers who might seek to control a satellite. We support efforts to require satellite providers to share position location data in a central repository. Any Vantor spacecraft operating above an altitude of 400 kilometers carries propulsion capabilities to execute timely and effective avoidance maneuvers and to allow safe disposal at the end of the satellite’s life.

Space Debris

Space debris poses a risk to satellites and humans in space. It is imperative that debris objects are tracked for the safety of all satellites and that creation of additional space debris is avoided whenever possible. Vantor encourages all satellite operators to help preserve the space environment by acting responsibly and following guidelines such as the World Economic Forum’s Space Industry Debris Statement.

Vantor is a founding member of the Space Safety Coalition, an ad hoc coalition of government and industry stakeholders that actively promotes responsible space safety practices. This coalition has published a comprehensive set of best practices for sustainable space operations which has been endorsed by 60 space organizations around the globe.

Vantor is actively involved in space object identification and tracking, including participating in workshops, working groups and conferences. We continue to support LeoLabs, a commercial provider of high-performance tracking and mapping data for low Earth orbit (LEO) satellites. LeoLabs’ cloud-based software platform turns radar data into real-time, actionable information on where debris is located. In 2022, the Federal Communications Commission approved a rule that aims to minimize space debris by requiring LEO satellites to be disposed of within five years after being taken out of service. The new rules shorten the previous 25-year guideline for deorbiting satellites post-mission. Vantor supports this change to keep space free of derelict satellites that could cause harmful space debris.

Non-Earth Imaging

Space technology has become an important part of our lives and the global economy. But our growing dependence on an ever-expanding array of space-based tools also creates a challenge: space congestion. To ensure that we can all continue to benefit from the growing reliance on space-based solutions, it is critical that industry and governments work together to sustainably manage the risks of orbital traffic.

Vantor has been at the forefront of that effort by setting high standards of responsibility for its own satellite operations, helping to unite the space industry behind a code of best practices, and calling for regulation that protects this essential resource. And we are not stopping there.

In 2022, the National Oceanic and Atmospheric Administration modified Vantor’s remote sensing license to commercialize non-Earth imaging (NEI) for its constellation. NEI can help address space debris challenges by bringing more transparency to the near-Earth space domain, thus helping operators better protect and maintain their assets. Vantor will work closely with government and commercial customers to effectively utilize our NEI capabilities.

Through this new license authority, Vantor can collect images of space objects across LEO—the area ranging from 200 kilometers up to 1,000 kilometers in altitude—and distribute them to both government and commercial customers. Vantor’s constellation is capable of imaging objects at resolutions of less than 6-inches at these altitudes and can support tracking of objects across a much wider volume of space. Taken together, these capabilities can provide customers with accurate information to assist with mission operations and help address important space domain awareness and space traffic management needs.