Modern slavery – commonly called ‘slavery’, ‘child labour’ and/or ‘human-trafficking’ – is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. These are heinous activities that we will never engage in or condone as a business, and that we condemn in others who engage in them.

We have a zero-tolerance approach to modern slavery and will not engage in business of any description with any business who does so. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains (which include airlines and hotel chains across the world), consistent with our disclosure obligations under the Modern Slavery Act 2015.

If we discover that any business or individual associated in any way with our business is engaged in, or otherwise supporting, and/or condoning or failing to prevent such activities, when such activities are within their control and/or influence, we will cease all connection with them. We will also consider whether we are under any reporting or other legal duty in respect of this disassociation and our reasons for it.

Our policy and statement applies to all persons that work for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

The following policies help us ensure modern slavery is not taking place in our supply chain or business:

Diversity and Inclusion Policy: ensures we foster a fair and inclusive workplace, where our people are valued, their differences are respected, and discrimination is eliminated.

Code of Conduct: Our Code of Conduct policy sets out what is expected from every person working for our businesses. These policies are available to all employees via our intranet site and website and managed our senior management.

Our people:

To ensure we recruit and treat employees fairly, we ensure that we follow the procedures below with respect to how we recruit and treat our employees:

• Recruit and select employees in a fair, lawful and professional manner, both for internal and
• external candidates.
• Treat all employees fairly during their employment and have in place procedures to raise a
• grievance or a involve local trade union, where they exist, or where this is a legal requirement
• to do so, if an employee feels they have been treated unfairly.
• Manage the exit of an employee in a fair and consistent manner.
• To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff

Our Human Rights Policy: This details our commitments to labour and workplace rights. We provide fair working conditions for all our employees including terms and conditions of employment, remuneration, working hours, health and safety, resting time, holiday entitlements and benefits.

The key principles are that:

• Our employees’ pay will not be lower than that required by local law or, in the absence of a
• law, the level paid generally within that industry.
• Hours of work will be in line with local law or, in the absence of a law, the norm within that
• industry, and shall not be excessive.
• Employees shall not be contractually required to work more than 48 hours per week and
• overtime will only be worked on an optional basis. Forced or compulsory labour is prohibited.
• Employees will not be forced into involuntary labour and coercion at work is not acceptable.
• Financial penalty as a disciplinary sanction is prohibited.
• The employment models deployed will be in line with territory-specific law and practices.
• Under these practices there will not be excessive use of alternative models, such as subcontracting or labour-only contracting.

All employees can raise concerns using the Whistle blowing policy, including concerns about slavery and human trafficking. This Whistle Blowing policy sets out the channels available to any person who works for us and employees can raise these concerns openly and at any time in confidence.