2023 MODERN SLAVERYACT STATEMENT
This statement has been published in accordance with the Modern Slavery Act 2015. It outlines how BCD
Travel UK & Ireland worked to help prevent modern slavery and human trafficking in our business andsupply chain during the year ending 31 December 2023.

Introduction
BCD Travel helps companies travel smart and achieve more. We drive program adoption, cost savings andtalent retention through digital experiences that simplify business travel. Our 15,000+ dedicated teammembers service clients in 170+ countries as we shape a sustainable future for business travel.
We recognise that we have obligations to uphold the highest ethics in our employees’ and in our business’
activities. We have a zero-tolerance approach to slavery, servitude, forced labour and human trafficking
within our operations and our supply chain. We accept that all members of our operations and supply
chain must be alert to the risks of modern slavery, however small, and be able to act upon them.

Our business and supply chain
Due to the nature of our business, we are at low risk of employing victims of child labour, forced labour,
modern slavery or human trafficking in our own operations. We adhere to local labour laws and pay ouremployees at least the legal minimum wage in all countries where we operate. We perform all due
diligence within the hiring process and we ensure any contractors we are planning to engage are also
compliant. We train our people to be alert to any behaviour that could resemble forced labour, childlabour or human trafficking activity and to highlight and safely report any such instances; this training iscompulsory.
We expect BCD employees to report any concerns using the appropriate channels. Management isrequired to immediately and effectively act upon them. This is supported by our Code of Conduct andNon-Compliance Reporting policy.
Our business depends on a reliable, global network of service providers. The majority of our direct
suppliers are U.K. and U.S.-based companies providing technology and professional services that we haveidentified as low-risk sectors. Indirect suppliers in the travel industry, such as airlines and hotels, are in ahigher risk category.
We seek business relationships that are built on trust, respect and shared values. We select suppliers whomeet our business and commercial requirements. It’s also important that our suppliers demonstrate
responsible business practices based on ethical, environmental and social criteria.
Our commitment to human rights is based on principles of leading international standards andconventions and covers our global operational scope. All suppliers are expected to share a commoncommitment to:••Conduct business in an ethical manner and abide by all legal and regulatory requirements andother requirements included in BCD Travel’s Supplier Code of Conduct.
Comply with the international labour practice standards with specific focus on the International
Labour Organisation (ILO) Conventions, the 10 principles of the UN Global Compact (UNGC) andthe UN Sustainable Development Goals (SDGs).

A policy and process-driven approach ensures compliance with these standards and demonstrates
continual improvement.

Policies and contractual controls
As new sustainability legislation is implemented, and stakeholder requirements evolve across the supply
chain, the importance of integrating ethical and social best practices across global procurement processes
continues to increase. We recognise that all positive action around preventing, identifying and minimising
instances of modern slavery must start with explicit policies, guidelines and controls. This is why we clearly
outline our expectations of the standards we require from our suppliers and partners in our Supplier Codeof Conduct.
Ethically conducting business and abiding by all legal and regulatory requirements are importantcomponents of this shared commitment. We continue to increase the number of global suppliers who’ve
signed our Supplier Code of Conduct. It also forms part of our agreement with each partner in the BCDglobal network. We encourage them to promote our shared values of sustainable procurement within theirown supply chain.
We ensure our Supplier Code of Conduct is aligned with the latest ethical business legislation. In 2023 acore cross-functional team reviewed and updated our Supplier Code of Conduct to ensure it continues tobe fit for purpose. Key changes included more robust language and expectations around labor standards,
human rights, ethical business practices and environmental protection. The key requirements outlined inour Supplier Code of Conduct include:••••Ethical business practices – including corruption and bribery, business integrity, conflict ofinterest, money laundering, fair compensation and anti-trust and trade sanctions
Privacy and security – including personal data processing
Human rights – including child labour, freely chosen employment, wages and benefits, working
hours, health and safety, diversity and inclusion and freedom of association
Environmental protection – including legal compliance, reduction of waste and measurement ofcarbon emissions

Our independently operated BCD Travel SpeakUp system offers our employees and suppliers theopportunity to anonymously report any incidents. A compliance email account is also monitored by theglobal group internal audit and legal functions. All reported incidents are investigated, and the results arereviewed by a designated member of the BCD Travel Board responsible for compliance.

Supply chain due diligence
Our sustainable procurement initiatives incorporate several processes to assess supplier compliance andsustainable practices within our supply chain of direct suppliers. As outlined earlier in this statement, weconsider our risk of modern slavery, human trafficking and child or forced labour within our operations anddirect supply chain to be low.
While this is the case, we recognise that certain services and processes within the wider travel industry areused by human trafficking organisations to facilitate their crimes. We are uniquely positioned to enhance
education and awareness across our industry as part of the solution to modern slavery. This is a primary

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focus for BCD Travel in our partnership work to prevent modern slavery. We provide further details on ourinitiatives in this area later in this statement.
As part of our supplier due diligence process, we carry out desktop assessments of our supply chain toassess risk in the areas of environment, business ethics, labour standards, human rights and modernslavery, as well as their participation in the UNGC.
As a minimum, our suppliers are strongly encouraged to:••••Comply with BCD Travel’s zero-tolerance stance regarding human slavery, human trafficking andthe sexual exploitation of children.
Apply the highest standards of integrity in all business interactions with us.
Respect workers’ human rights and comply fully with all applicable laws.
Promote our Supplier Code of Conduct within their own supply chain.

Training and awareness
Human trafficking continues to be a huge issue that negatively impacts the lives of millions of people
globally. For this reason, our commitment to taking action on this issue in 2023 didn’t falter.
We believe that as a travel management company, we’re uniquely positioned to raise awareness with ouremployees, travellers and partners about human trafficking and child exploitation, and the role they canplay in addressing it. We use our reach to raise awareness and educate on the issue, driven by our active
human trafficking awareness committee.
We know that traffickers often use air and rail travel to transport victims between cities and countries anduse hotels as venues to traffic or abuse victims. If every traveller can identify the signs of human trafficking
and understands what to do and how to report it if they encounter a potential incident, we in turn can help
end the commercial and sexual exploitation of human beings.
This year, we expanded and raised the profile of our human trafficking awareness committee. Members
come from a broad range of functions and locations across BCD. This passionate team, motivated to drive
awareness of human trafficking in and beyond our industry, has focused initiatives around three goals overthe past year: educate, engage, and partner.

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Officially launched back in 2017, our mission remains clear: to raise awareness and educate on the issue.
All efforts are aimed at ending human trafficking and the sexual exploitation of children.
Since 2017, huge strides have been made, from signing the agreement with ECPAT and The Code in 2017to launching an end-to-end education and awareness strategy. Highlights of our achievements over thepast year include:•••••••••

Continued to practice due diligence to guard against human rights violations, as demonstrated in
the human rights section of our Supplier Code of Conduct.
Expanded and raised the profile of our human trafficking awareness committee.
Continued to partner globally with ECPAT (including reporting to The Code) and A21.
Continued with Don’t Look Away, our human trafficking awareness training, made available to allemployees to increase understanding of ECPAT, The Code and our role in raising awareness. Todate we have achieved a 94% completion rate.
Continued our National Human Trafficking Prevention Month campaign.
Supported key events such as the A21 Walk For Freedom march with campaigns and BCDvolunteers.
Supported the A21 Cambodia human trafficking education project through our Making a
Difference program.
Implemented flagship A21 fundraising initiative and additional fundraising.
Received the Travel Partner of the Year – Large TMC award in 2023 from Business Travel Awards
Europe, who specifically referenced our awareness approach to human trafficking as key to ourpartnership success.

Partnerships are central to BCD’s education
and awareness strategy
Partnerships are central to our work to help combat modernslavery. We formed a global partnership with ECPAT in 2017 andwith A21 in 2020. Our commitment to both ECPAT and A21 is toraise awareness through education and training with ouremployees, suppliers, partners and clients.

ECPAT
ECPAT are the leading international organization seeking to end
children's commercial sexual exploitation through awareness,advocacy, policy, and legislation. They have a membership of 125
civil society organizations in 104 countries.
They work to better understand the problem through research
while pushing for the critical systemic and social changes
necessary to end the sexual exploitation of children withgovernments, intergovernmental institutions, the private sector,
civil society, and the general public, including with the children
themselves.

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How we partner with them
The sexual exploitation of children in the context of travel and tourism (SECTT) has continued to thrive
globally, with child sex offenders using the infrastructure of the industry, increasingly combined with online
technologies, to commit their crimes. This can change only if we actively take steps to fight this crime.
BCD is a signatory to ECPAT’s Code of Conduct for the Protection of Children from Sexual Exploitation inTravel and Tourism (The Code). The Code encourages members to provide educational tools and support
initiatives to end sexual exploitation of children.
We undertake annual reporting to The Code which provides a framework for tracking progress, as well as
supporting ECPAT through awareness and fundraising initiatives throughout the year. We also promote
PACT (by ECPAT-USA), a human trafficking awareness free online training developed specifically for travel
professionals.

A21
A21 combats modern-day slavery by working to Reach, Rescue and Restore lives — they are working to
reduce vulnerability, assist victims, and empower survivors. The organisation works in 19 different locationsin 14 countries across the globe.
A21 have many different education programmes and initiatives, as well as 24/7 confidential hotlines, childadvocacy centres, professional training, victim identification operations, legal aid representation andsupport.
They provide aftercare services from trauma-informed holistic support for survivors, emergency shelters,
accommodation and relocation services and much more.
How we partner with them
We work closely with A21 on key initiatives including their Annual Walk For Freedom, fundraising projects,
and in 2023 supported a children-centered human trafficking education project in Cambodia through ourMaking a Difference programme.
Key partnership initiatives included:
Walk For Freedom – BCD employees once again showed unwavering support for the A21 Walk For
Freedom in 2023. The A21 Walk For Freedom is a day of global awareness and local action in the fightagainst human trafficking. Their aim is to reduce vulnerability locally by empowering neighbours, friends,and communities to identify and report trafficking suspicions. The event took place on October 14th andtens of thousands of people participated in more than 425 communities across over 56 countries reachingnearly 800 million people through media with awareness of human trafficking. In support of ourpartnership with A21, BCD people took to the pavements across regions.
Open water swimming fundraising - Last year the Vice President Global Client Team and chair of thecommittee challenged her fear of open water swimming with an open water sea swim from Lyme Regis toCharmouth to raise funds and awareness for A21’s Cambodia human trafficking education project.

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Business Travel Awards Europe
Travel Partner of the Year award – As a testament to the impact of our awareness initiatives, BCD Travelalso received the Travel Partner of the Year Award for large TMCs from the Business Travel Awards Europein 2023. The judges applauded our work to create awareness and training around human trafficking, andour willingness to go above and beyond with our partnerships. They noted that while many industry ESG
efforts highlight traditional sustainability efforts, this commitment to the broader social and ethical impact
illustrates ways that organisations can go above and beyond with their partnerships.

In summary - effectiveness in preventing modernslavery
We have identified that enhancing education and awareness around modern slavery is where ourorganisation is able to make the most impact. We also recognise that there will continue to be modernslavery risks. To mitigate these risks in our business, as well as support our objectives for education andawareness, we will continue to identify, adopt and implement best practices in the following areas in theyear ahead:••••Continue to raise staff awareness levels through mandated training and opportunities toparticipate in wider global events.
Continue to focus on education and awareness driven by our human trafficking awarenesscommittee.
Continue to work with our key partners, A21and ECPAT including sharing news, campaigns andclient awareness collateral on our human trafficking awareness committee intranet hub.
Continue with investigations into any reports of modern slavery and remedial actions taken inresponse.

BCD TRAVEL (UK) DIRECTORSMICHÈLE LAWLEY President, Europe

CLAUDIA JACKSON Managing Director, UK & Ireland

We approve this statement against modern slavery and human trafficking pursuant to section 54(1) of theModern Slavery Act 2015. Financial Year Ending December 2023.

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