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Slavery and Human Trafficking Statement

WHO ARE WE?
 

Barrhead Travel and its trading divisions – Barrhead Business Travel, Cruisedirect.co.uk, The-Cruise-Specialists.co.uk, CanadaTravelSpecialists.co.uk, Flightsdirect.com and Brilliant Travel are all part of Travel Leaders Group LLC.
 

Travel Leaders Group, LLC and its affiliates (“Company”) is a global travel services company that serves corporate and individual client travel needs and offers other travel related services.
 

We are proud of the steps we have taken to combat slavery and human trafficking. 
 

Travel Leaders Group  has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.   
 

The Company also expects the same high standards from all its suppliers, contractors and other business partners.
 

In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, the Company accepts that it has a responsibility through practical and reasonable due diligence processes to ensure that workers are not being exploited, that they are safe, and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

The Company’s Anti­Slavery and Human Trafficking Policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.
 

Our policies on slavery and human trafficking
 

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. 
 

Our Anti­Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in out supply chains.
 

Due diligence processes for slavery and human trafficking
 

As part of our initiative to identify and mitigate risk we have in place systems to:
 

  • Identify and assess potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains.
  • Monitor potential risk areas in our supply chains.
  • Protect whistle blowers.
     

The Managing Director has overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations. The HR Manager has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in the Company’s business or supply chains.
 

Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.

Compliance
 

The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the Company. Company or under the Company’s control. You are required to avoid any activity that might lead to a breach of this policy.

If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager immediately. 
 

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager. You can also contact the Government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.
 

The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.
 

We have a dedicated compliance team, which consists of involvement from the following departments:
 

  • Legal
  • Compliance
  • Human resources
     

Training
 

Regular training on this policy, and on the risk that the business faces from modern slavery in its supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.
 

The Company’s zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.
 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 5th April 2019. 
 

Jacqueline Dobson
President