Modern Slavery Statement

January 2026

This statement is made by the Club Travel and constitutes Club Travel’s statement against modern slavery and human trafficking as approved by its executive leadership team for the financial year 2023.

Club Travel is Ireland’s leading business partner for managed travel. We help companies and their employees prosper by making sure travellers are present where
and when it matters.

We are committed to ensuring that there is no slavery and human trafficking in any part of our operations – this is embodied in our Code of Conduct, which applies to all our employees. Club Travel will not tolerate the use of child or forced labour in any of our operations or facilities. In accordance with our Supplier Sustainability Shared Values, we expect the suppliers with whom we do business to uphold the same values.

To further strengthen our processes in this regard, we have taken or begun to take the following steps over the last year to ensure that our vendors, partners and employees take the requisite actions in the context of our business operations, against modern slavery:

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. Our Anti-Slavery Policy, which is referenced in our Code of Conduct and separately communicated to our employees and to our suppliers through our Supplier Sustainability Shared Values, 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 are not taking place anywhere in our supply chains. For example, Club Travel has Travel Partners located around the world and Club Travel has provided such partners with a Model Policy governing Anti-Slavery to ensure such risks are mitigated throughout our supply chain.


OUR DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING AND RISK ASSESSMENT PROCESSES

Reflecting the United Nations Guiding Principles on Business and Human Rights, as part of our initiative to identify and mitigate risk, we have taken a risk-based approach and our due diligence activities correspond with the level of risk identified. As such we have undertaken and/or begun the following risk assessment processes during the last financial year to inform our due diligence approach:

  • Identify and assess potential risk areas in our supply chain and ensure supplier adherence to our values and ethics. We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our Supplier Sustainability Shared Values we have in place a robust third -party oversight program that mitigates regulatory compliance risk. Our due diligence measures and screening procedures are designed to prevent and detect modern slavery and human trafficking in our supply chain.
  • Training. To ensure understanding of the risks of modern slavery and human trafficking in our supply chain and our business, we provide training to our staff through our Code of Conduct which each employee must attest to.
  • Our Code of Conduct sets out the ethical standards to which our employees are held.

 

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

To monitor the effectiveness of the steps we have taken in our business operations and supply chains, we have in place the following performance indicators:

  • Rollout of employee Code of Conduct training, which requires employee acknowledgement annually. This training is mandatory.
  • Monitoring, investigating and addressing any employee and supplier reports which can be made through our confidential ethics reporting line.
  • Distribution of our Supplier Sustainability Shared Values to our suppliers, licensees and partners.