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Modern Slavery Act

This outlines the steps that ITC Travel Group has taken, and is continuing to take, to ensure that modern slavery and human trafficking is not taking place within our Group or supply chain.

Introduction
Modern slavery encompasses slavery, servitude, human trafficking and forced labour and is recognised as a global issue. Modern Slavery is a criminal activity and a gross violation of fundamental human rights. We recognise that every area of our business has the potential to be impacted by this serious issue, and the Group has therefore implemented a policy for the prevention, detection and reporting of modern slavery within its businesses and their supply chains.

Our Business
ITC Travel Group is a UK based travel business, established in 1974.

The luxury tour operator within the Group is the Inspiring Travel Company, which pioneered the concept of luxury travel in the UK and was one of the first tour operators to charter Concorde.

Some 40 years on our unrivalled experience and close relationships with the world’s finest travel partners means the Inspiring Travel Company can tailor trips to suit our clients’ unique needs.

We have 208 staff across the Group, and operate in the United Kingdom with an office in Barbados. We work with several suppliers, mainly hotel partners, Destination Management Companies and airlines.

Our Outlook
ITC Travel Group 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 our businesses or their supply chains. We recognise that we cannot unilaterally solve this problem, but we are committed to doing our part.

Mal Barritt
CEO, ITC Travel Group

Our full statement is available below;

*Last updated October 2017*

Modern slavery statement
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets
out the steps that ITC Travel Group has taken and is continuing to take to ensure
that modern slavery or human trafficking is not taking place within our
businesses or their supply chains.

Modern slavery encompasses slavery, servitude, human trafficking and forced
labour. ITC Travel Group 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
ITC Travel Group is a UK-based business, established in 1974, ITC pioneered the
concept of luxury travel in the UK. Some 40 years on, we remain privately owned
and our unrivalled experience and close relationships with the world’s finest
hotels mean the ITC Travel Group can tailor trips to suit our clients’ unique
needs. We have 215 staff and operate in the United Kingdom with an office in
Barbados. We work with a number of suppliers, mainly our hotel partners, DMC’s
and airlines.

Our High Risk Areas
There are a number of countries we outsource business to that we consider high
risk and we have taken steps to ensure our third party suppliers have been issued
with our code of conduct.

Ethical Policies
We operate a number of internal policies to ensure that we are conducting
business in an ethical and transparent manner. These include:
1. Anti-slavery and Human Trafficking Policy. This policy sets out the
organisation’s stance on modern slavery and explains how employees can
identify any instances of this and where they can go to for help.
2. 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.
3. Whistleblowing Policy. We operate a whistleblowing policy so that all
employees know that they can safely raise concerns about how colleagues
are being treated, or practices within our business or supply chain, without
fear of reprisals.
4. Code of Conduct. This code explains the manner in which we behave as
an organisation and how we expect our employees and suppliers to act.
Our Suppliers

ITC Travel Group operates a supplier code of conduct policy and maintains a
preferred supplier list. We conduct due diligence on all suppliers before allowing
them to become a preferred partner. 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:

1. They have taken steps to eradicate modern slavery within their business.
2. They hold their own suppliers to account over modern slavery.
3. (For UK based suppliers) They pay their employees at least the national
minimum wage / national living wage (as appropriate).
4. (For international suppliers) They pay their employees any prevailing
minimum wage applicable within their country of operations.
5. We may terminate the contract at any time should any instances of
modern slavery come to light.

Training
We conduct training for our teams across the ITC Travel Group so that they
understand the signs of modern slavery and what to do if they suspect that it is
taking place within our supply chain.
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.
Approval for this Statement

This statement was approved by the Board of Directors, October, 2017

Jennifer Atkinson
CEO, ITC Travel Group

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