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We are deeply passionate about the places we travel to and ensuring that our customers’ trips have a positive impact on the destinations they visit. We are committed to respecting and supporting human rights throughout our operations. We firmly adhere to the principles of ethical travel as set out in our  policy and as reflected in the conduct of our business dealings and relationships with our business partners. In accordance with the Modern Slavery Act 2015, we are committed to taking steps to ensure that slavery and human trafficking does not occur within our business or that of our partners and have upheld our commitment as shown by the steps below.

The Ïã¸ÛÁùºÏ²Ê¿ª½±¼Ç¼ Group

We provide bespoke tailor-made travel experiences for our customers and work with organisations across the world to do this. The Ïã¸ÛÁùºÏ²Ê¿ª½±¼Ç¼ Group includes: Ïã¸ÛÁùºÏ²Ê¿ª½±¼Ç¼ Group Limited; Ïã¸ÛÁùºÏ²Ê¿ª½±¼Ç¼ US, Inc; Ïã¸ÛÁùºÏ²Ê¿ª½±¼Ç¼ Services Limited; Boketto Holdco Limited; Boketto Midco Limited; Boketto Midco 2 Limited; Boketto Midco 3 Limited; Boketto Newco Limited; and Boketto Bidco Limited.

Due diligence in our business and supply chain

We have offices in London, Witney and Boston, and around 900 employees worldwide. We are passionate about fairness, equality and inclusion and place explicit positive value on our employees’ points of difference. As part of our commitment to this, in April 2022 we introduced Unify, our global Diversity, Equity and Inclusion (DE&I) group, which will gather employee feedback and help guide the business towards delivering its DE&I objectives. We also apply high standards in the recruitment and employment of our people, which includes a focus on an individual's right to work in the relevant country in which they will be engaged.

In order for our customers to benefit from truly local knowledge and have the very best experience, we have partnerships with suppliers across the world who provide travel services, transport (including cruises and airlines), and accommodation. We also partner with suppliers of IT and other office facilities and communication equipment, and professional services such as legal advisers, insurers and auditors.

In recognition of our extensive product supply chain, we have specialist regional product teams based in our offices, who oversee this and are responsible for selecting and managing our relationships with the very best local suppliers. We have clear and detailed guidelines in place for tenders in relation to modern slavery and human trafficking, and compliance with the Modern Slavery Act is a requirement in our land supplier contracts. In 2020, we made improvements to our standard ground handler contracts, which are accompanied by a Supplier Code of Conduct, and these continue to be rolled out.

The Supplier Code of Conduct, which was last updated in 2023, sets out our expectations of our suppliers, including obligations to ensure that no forced or child labour is taking place in their business, that their processes ensure all workers are legally permitted to work, and that their employees are paid at least the legal minimum wage. We also ask our ground handlers to place the same obligations on subcontractors they work with. In addition, we have the ability to audit our ground handlers' adherence to the Modern Slavery Act and ethical practices, and are able to take action if terms have been breached. In June 2023, we proudly announced certification as a B Corporation, which together with our Travelife Partner status, recognises our commitment to operate responsibility.

In early 2021 we launched our Environmental Social and Governance (ESG) Framework, which further demonstrates our commitment to sustainability by focusing on five key areas: community; environment, marketplace, workplace and governance. For each of these areas, we have set goals that either align with the UN Sustainable Development Goals or with our own commitments to ensure that each year we make a positive impact internally within our business and externally with suppliers and communities. Specifically, our human rights goal focuses on our commitment to reduce the risk of our activities harming the rights of others, and taking the necessary steps to avert, mitigate or remedy potential, actual or perceived abuses. Our ESG Framework and related commitments were approved by the board of Boketto Holdco Ltd, who continue to have oversight. Progress made against our commitments can be viewed by visiting the Policies page of our website.

In 2023, we launched an online Supplier Resource Centre, ensuring that all compliance-related policies, along with any associated training resources are readily accessible. As well as housing our dedicated Global Anti-Slavery and Human Trafficking Policy, it also contains a modern slavery policy template for supplier use, which we hope will help to inspire and guide the creation of their own.

In 2024 we are trialling a new in-house supplier auditing process with a sample of our key ground handling agents. As part of this audit, we will ask our partners whether they have steps in place to ensure that human trafficking and modern slavery is not occurring in their own businesses and their supply chains. Audley can provide them with support in this area if required.

Our training and policies on slavery and human trafficking

We have reviewed and updated our Global Anti-Slavery and Human Trafficking Policy, which applies to all global employees, with certain sections sign-posted for suppliers. The amendments were approved by the Board in April 2023. This policy reflects our commitment to acting ethically and with integrity and to support this further, we created an online training module in 2021 on the Modern Slavery Act which all of our employees are required to complete. Having this online training module makes training more accessible to our employees and allows us to better monitor compliance. As with the policy, the content of this continues to be reviewed, and updated if necessary, on an annual basis.

We also have an internal whistleblowing procedure in place, for any employees who wish to confidentially raise or discuss any concerns they have regarding the issues covered by the Modern Slavery Policy. The confidential helpline is provided by an independent third party.

Our effectiveness in combatting slavery and human trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chain:

• The number of our employees trained on human rights, modern slavery and human trafficking;
• The number of modern slavery cases reported under our whistleblowing procedure or otherwise;
• The percentage of our GHA relationships which have existed for over five years.

As part of our commitment to delivering best practice in this area we have also published our Modern Slavery Act statement on the . This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps that the Ïã¸ÛÁùºÏ²Ê¿ª½±¼Ç¼ Group has taken during the financial year ending 31 December 2023 to prevent modern slavery and human trafficking in its business operations and supply chains.

The Directors of the Ïã¸ÛÁùºÏ²Ê¿ª½±¼Ç¼ Group companies approved this statement on 29 May 2024.

Nick Longman
CEO, Ïã¸ÛÁùºÏ²Ê¿ª½±¼Ç¼ Group
Date: 29 May 2024

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