Modern Slavery Act

Introduction
Traveleads is committed to acting with integrity and ethically in all of our business relationships, including compliance with the Modern Slavery Act 2015 (MSA). As defined by the UK Government, “modern slavery” includes slavery, servitude, forced and compulsory labour (including child labour amounting to modern slavery) and human trafficking.

Slavery, as well as being a crime, is a violation of fundamental human rights and we strongly condemn the exploitation of any person’s liberty by others in order to exploit them for personal or commercial gain.

Structure and supply chains
We have no “permanent” supply chains, as we act as agents in the procurement of travel services for our clients.

In acting as agents for our clients, we may have to utilise suppliers from many countries around the world which makes audit extremely difficult, however we require our suppliers, and their supply chains, to ensure that they have taken all practical steps to comply with the MSA.

Our policies on modern slavery
We expect our suppliers, and their supply chains, to observe and implement good employment practices and to comply with all relevant legislation of the countries in which they operate, and to seek continual improvement for their workers. Any supplier found to be in breach of these regulations will be delisted and reported.

Due diligence
Our own employment processes are robust and ensure that all employees are legitimately employed, have the right of employment in the UK and have verified their identity via passport checks.

Traveleads is a Living Wage Foundation employer and adheres to the standards set by this organisation in all of our employment contracts.

Risk assessment in supply chains
We endeavour to only work with reputable organisations in who we have confidence that they will embrace the intent of the legislation, given that so much of our supply chain exists outside of the UK and beyond scope of UK legislation.

Our employees are required to consider the potential for slavery or exploitation when interacting with suppliers, and to report anything they consider to be suspicious.

Measuring effectiveness
When undertaking annual reviews, all suppliers will be reminded of their obligations and the necessity of maintaining vigilance along their supply chain. Larger suppliers will be asked to disclose details of MSA audits.

Training for staff
Awareness of modern slavery forms a part of our internal staff training processes, and staff are made aware of the importance of raising concerns with the management.

Gary McLeod
Managing Director – Corporate Division
08 April 2019

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