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Modern Slavery Statement

Modern Slavery Statement 2019

TravelSmart Technologies Ltd (and subsidiaries including Fleetway Travel Ltd)


This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that TravelSmart Technologies Ltd (and subsidiaries including Fleetway Travel Ltd, “Fleetway” has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain, up to and including the financial year ending 31st October 2018.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Fleetway has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our business

Fleetway Travel is one of the UK’s leading independent Travel Agents, with over 45 years of experience selling holidays. We operate across the Fleetway Travel, Luxury Holiday Collection and Exclusive Luxury Breaks brands.

We have an extensive network of airline, hotel and ground handling relationships. These relationships with our partners are crucial to our success. Our Partners benefit from our expertise in constructing and marketing a successful deal, which has been built up and refined over many years. We market these exclusive worldwide offers through multiple channels including key online platforms such as Travelzoo and Secret Escapes, national newspapers such as The Telegraph and The Times, as well as our own loyal and ever growing database.

Countries of Operation

Fleetway predominantly sells holidays to UK consumers, and during 2016 has also commenced selling to US and Canadian customers.

We provide holidays to over 30 countries worldwide. We do not employ any staff outside of the UK, so rely on local suppliers to deliver our holidays.

Our high risk areas

The nature of our operations means we supply holidays to a wide variety of destinations and have an extensive supplier base, including both large global chains and small independent suppliers. We consider our high risk areas of operation to be suppliers who are based in developing countries and/or those in unstable political environments, or where legal protection for employees is less developed.

Our Internal Policies

We operate a number of internal policies to ensure that we are conducting our business in an ethical and transparent manner. These include:

  • Our HR Manager is responsible for putting in place and reviewing policies and the process by which they were developed.
  • Investigations/due diligence: Our CEO is responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
  • Whistleblowing policy: The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can raise them without fear of reprisals.
  • Employee code of conduct: The Company's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Supplier code of conduct: The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.
  • Recruitment policy: We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. Our organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Our approach to suppliers

Fleetway operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

  • They have taken steps to eradicate modern slavery within their business
  • They hold their own suppliers to account over modern slavery
  • (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate)
  • (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

  • No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified
  • No customer complaints are received
  • Compliance levels from our own review

Awareness-raising programme

As well as training staff, we will raise awareness of modern slavery issues by circulating a series of emails to staff.

The emails explain to staff:

  • the basic principles of the Modern Slavery Act 2015;
  • how employers can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • where external help is available, for example through ABTA.

Approval for this statement

This statement has been approved by the organisation's CEO, who will review and update it annually.

Stuart Jackson
May 2019

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