This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It constitutes Holiday Extras Ltd slavery and human trafficking statement for the financial year ended 31 March 2018.
Holiday Extras Limited is a United Kingdom based company which is part of a group of companies involved in the supply of travel ancillaries and UK short break products. As of January 2018 the company had over 500 employees based in the United Kingdom in two offices.
Holiday Extras recognises the importance of the Modern Slavery Act 2015 as a tool in combating the widespread human rights abuses comprised in modern slavery. We have a continued commitment to trying to ensure that there is no modern slavery or human trafficking in our supply chains, or any part of our business and operate a zero-tolerance policy in this regard.
We do have a Anti-Slavery Policy which we review annually, and we also operate a number of other internal policies to ensure that we are conducting business in a transparent and ethical manner. Where we consider we have lacked coherent policies, we remain on a rolling programme of review and implementation. We are for example working towards a Corporate Social Responsibility Policy and a Whistleblowing Policy in the 2019/20 financial year to provide an established framework of our corporate responsibilities towards best business practice, community and stakeholder relationships.
Nearly all our suppliers are based in the United Kingdom and we endeavour only to use reputable suppliers. We continue to work with our business partners to enable us to get an understanding of ethical and modern slavery risks to our business, and to know our business partners and their supply chains. We have created contractual obligations for our suppliers so they work with us in accordance with our values and have a duty to provide assurance of their own business practices around modern slavery and human trafficking through warranties and undertakings. Since the introduction of the Modern Slavery Act, we have also carried out due diligence on our partners in regard to modern slavery policy and practice.
Suppliers - given the nature and location of our suppliers, and our due diligence efforts, we consider the risk of slavery or human trafficking within our supply chain to be low.
Investments - Holiday Extras as a group makes minority investments in UK. Although our investments are not part of our supply chain and we do not have control over those businesses, we seek to ensure compliance with laws, including the Modern Slavery Act.
People - our recruitment processes are transparent in a policy, and we have comprehensive vetting procedures in place which involve the use of external service providers. We are therefore able to confirm their identities, their right to work in the UK and ensure that their reward is paid directly into a personal bank account. All employees are paid above the UKs national living wage.
Training - we continue to work closely with our team members to raise awareness to help ensure that we understand, identify and assess modern slavery risks within, and to, our business, and when reporting is appropriate. This is done on an annual refresher basis.
Ongoing monitoring - if issues are identified in relation to modern slavery, these will be dealt with by the management with support of the legal and compliance teams. We continue to try to develop mature processes around anti-modern slavery and human trafficking in our business and its partnerships. We strive to raise awareness of, and to develop mature processes around, anti-slavery and human trafficking in our business and its partnerships.
This statement was approved by the Holiday Extras board of directors in December 2018
Chief Operating Officer