Anti Slavery and Human Trafficking

Organisational structure

Travel Innovation Group includes the following companies:

• Lime Management Limited
• Aviate Management Limited
• Calrom Limited
• Calrom Management Limited
• Lime Management (Australia) Limited
• Calrom Pakistan (Private) Limited
• Travel Innovation Group SA (PTY) Limited
• Travel Innovation Group (Barbados) Limited

Our Head Office is in the United Kingdom.

The organisation is controlled by a Board of Directors.

We are a ticketing and servicing agent in the travel sector. We have over 450 employees operating in the following countries:

• United Kingdom
• Pakistan
• Australia
• South Africa
• Barbados

Definitions

The Organisation considers that modern slavery encompasses:

• human trafficking
• forced work, through mental or physical threat
• being owned or controlled by an employer through mental or physical abuse of the threat of abuse
• being dehumanised, treated as a commodity or being bought or sold as property
• being physically constrained or to have restriction placed on freedom of movement.

Commitment

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in UK, Pakistan, Australia, South Africa and Barbados and in many cases exceeds those minimums in relation to its employees.

Supply chains

In order to fulfil its activities, the main supply chains of the Organisation include Tours Operators, Travel Agents, Airlines and office suppliers/ contractors.

Potential exposure

The Organisation considers its main exposure to the risk of slavery and human trafficking to exist in Pakistan because the provision of labour is in a country where protection against breaches of human rights may be limited.

In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited because we directly employee all the staff in our Pakistan office.

Steps

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

• Reviewed our supplier contracts which would be terminated in the event that the supplier is, or is suspected, of being involved in modern slavery
• Put measures in place to identify and assess the potential risks in our supply chain
• Ensure all suppliers meet our ‘supply chain compliance standards’. The compliance team consists of HR, Finance, Sales & Procurement
• Monitoring potential risk areas in our supply chain
• Ensuring staff have access to the whistleblowing policy which sets out the process by which employees can report any concerns of wrong doing

Key performance indicators

The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

• Completion of audits by external provider
• Use of labour monitoring and payroll systems; and
• Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations

Policies

The Organisation has the following policy which further define its stance on modern slavery

VIEW ANTI-SLAVERY POLICY

Slavery Compliance Officer

The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Approvals

Date of approval: April 2023

Michael Edwards
Managing Director