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Anti-slavery & Human Trafficking Statement
2020 -2021
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out thesteps taken by The Collinson Group Limited (“Collinson”) during the year ending 31 April 2020 tocombat modern slavery and human trafficking in its business and its supply chain.
This statement is produced in a period in which the COVID-19 pandemic continues to affect Collinson
and the wider travel industry. In addition to our normal, continued activity to prevent modern slavery andhuman trafficking, we have also responded to the additional effects of COVID-19 and, where relevant,have included these actions in this report.
This is our 4th statement made under the Act. Our previous statements can be found alongside thisstatement.
Introduction
The Modern Slavery Act 2015 requires commercial organisations supplying goods or services with aturnover above £36 million to prepare and publish an annual 'Slavery and Human Trafficking
Statement'. The Statement must set out the steps an organisation has taken during its financial year toprevent slavery or human trafficking.
Collinson fully supports the UK Modern Slavery Act and will not tolerate any form of slavery. As an
ethically driven company, Collinson respects the human rights of all those who work for us directly andon our behalf. We will not accept any violation of these rights in any form, particularly in relation tohuman trafficking and slavery, and we actively work to ensure suppliers and partners operate inaccordance with the same belief.
This statement sets out our approach to managing modern slavery risks throughout our internal
operations and our supply chains. It relates to the actions and activities undertaken across Collinson,
irrespective of the turnover of each entity.
Our Structure, Business and Supply Chains
Collinson is a global loyalty and benefits company. We use our expertise and products to craft customer
experiences which enable some of the world’s best-known brands to acquire, engage and retain
customers. We directly operate in over 20 global locations, and we have clients, suppliers and partners
across the entire planet. We operate under a matrix structure, with our core divisions being Airport
Dimensions, Assistance, Insurance, Loyalty, Travel Experiences and Valuedynamx, all managed
across our regional teams (EMEA, APAC & the Americas). We are the owners of well-known brands
such as Priority Pass and Columbus Direct.
Collinson is a private, family-owned business. Our founder, Colin Evans remains our Chairman after 30years and his sons’ Christopher Evans and David Evans operate as the joint CEOs. Building on ourfamily ethos, we aim to be a business that our clients want to work with, and our people are proud towork for. A place of innovation and creativity, driving job satisfaction and a sense of belonging. We alsoaim to be a commercially successful and trusted organisation with a social conscience, providing a1

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share of our profits, assets and people to enhance the communities and environments in which weoperate.
At Collinson we are proud to have a range of internal networks including Women in Collinson, Collinson
Under 30s, Link (Global LGBT+ Community), Embracing Neurodiversity and Kaleidoscope (Racial &Cultural Diversity). Our networks play both an integral and active part in ensuring we focus oncelebrating, educating and enhancing diversity and inclusion across the organisation.
In April 2021 Collinson was awarded The Elgantyne Jebb Award for Extraordinary Team Contribution at
Save the Children’s Partnership Awards. We not only raised £10,000 for Save's Emergency Fund but
we also mentored 200 young migrants in China, supported local children's villages in Cape Town,raised funds and awareness for children's mental health in Hong Kong, helped to bridge the digital
divide in London and supported the Disaster Emergency Committee’s Coronavirus Appeal. We
continue to work with our charity partners to not only make a change but also to influence others to.
Collinson is part of the Stonewall Diversity Champions Programme, which not only gives support toorganisations on meeting their statutory requirements under the Equality Act 2010, but the tools andresources to improve our practices beyond the legal minimum, and to develop a culture where all ourLGBTQ+ colleagues can thrive.
We also support our staff’s endeavours beyond their roles at Collinson and our employees sit on a
range of external committees and boards. Our Director of Employee Engagement and CSR has a nonexecutive role on the board for the Youth Group; this advisory role helps to guarantee the success andviability of their initiatives and programmes. Our Director of Procurement is an Ambassador for theSustainable Procurement Pledge, which is a pro-bono community of those committed to embedding
sustainability in their procurement practices - and sharing knowledge and tools of how to do so.
We know that Collinson is much more than ourselves - we rely on a global network of over 2000
suppliers and partners, and our Priority Pass network spans over 1,300 lounges and airportexperiences. These extended networks help us deliver our innovative and customer focussed solutions.
And we don’t just work with anyone. We expect that our partners and suppliers work with integrity andmaintain robust standards of governance, seeking to avoid any decisions that may have a negative
societal impact. As a minimum we expect them to:• comply with all applicable laws and regulations;• provide recurrent anti-bribery training to employees and ensure that no employee intimates, offers,
provides or accepts any form of bribe (or any other inappropriate type of inducement) to or from anyother individual, business or foreign public official;• not associate with any group that supports acts of violence or terrorism;• develop corporate initiatives that seek to improve the communities in which they operate; and• raise any concerns about inappropriate conduct by Collinson, its employees, suppliers or partners inconfidence to a dedicated “Speak Up” line, or to Collinson’s Head of Internal Audit or Chief People
Officer. The Collinson Whistle Blowing Policy is in place to safeguard and offer an alternative routeto raising concerns.
We are guided by established standards such as the International Labour Organisation CoreConventions, the United Nations Convention on Human Rights and the UK Modern Slavery Act 2015.
We treat our employees with respect and dignity and expect the same of our partners and suppliers.
As a minimum we expect our partners and suppliers to:2

DocuSign Envelope ID: C78C98DF-DBE2-410D-913F-F4443A7F61C1• provide a safe and hygienic working environment (and, where relevant, living quarters) for allworkers and proactively work to minimise health and safety risks through process controls andtraining and ensure any incidents are logged and learnt from in a cycle of continuous improvement;• ensure that all workers undertake work voluntarily with no incidences of forced, compulsory, orbonded labour and no human trafficking;• provide all employees with a written employment contract that clearly explains their role, delivery
expectations, remuneration and rights and ensure that all reasonable steps are taken to confirm thateach employee has understood the contract prior to signature;• comply with applicable laws in respect of child employment and legal working age;• ensure workers are appropriately trained to carry out their roles and are fairly remunerated in moneyand not in kind in accordance with any minimum wage requirements at the very least;• not force workers to work excessive hours, ensure allowances are made for appropriate breaks andany overtime is in accordance with applicable laws;• not restrict the right for employees to exercise freedom of association and collective bargaining if
such is in accordance with applicable laws or prevent the development of alternative means ofemployee representation;• not require workers to lodge monies or identity papers in order to work and be free to leave
employment (after reasonable notice is given if required);• promote a diverse workplace, free from any form of discrimination or victimisation grounded in (butnot limited to) age, disability, ethnicity, gender, gender identity, nationality, marital status, parental
status, political orientation, race, religion, sexual orientation, social origin, or union affiliation;• maintain and promote formal and documented processes for employee grievances, allowing
grievances to be raised, heard, assessed and resolved fairly and with no fear of personalrepercussions;• maintain and promote formal and documented whistleblowing policies that encourage employees toraise any concerns of unlawful or inappropriate business practices with no fear of personalrepercussions;• maintain and communicate formal and documented disciplinary processes; and• not force employees to undergo any medical testing of any kind unless except where required or
allowed for under applicable laws.
Leading through the Covid-19 pandemicOperating largely in the travel and hospitality industry, Collinson has undoubtedly been heavily
impacted by the Covid-19 pandemic. Whilst this has created unprecedented challenges for ourbusiness, we have continued to operate to the core of our values, and we have taken numerous steps
to protect as many jobs as possible. We have accessed the various government support schemes
available in our countries of operation, our senior leaders have taken a temporary voluntary pay
reduction, and we have taken steps to reduce non-employee driven costs where possible.
To ensure the safety and wellbeing of our staff, we have implemented flexible policies and provided theinfrastructure for all teams to work from home as required. We have also worked within legislative
guidelines to keep our offices open for those employees for whom home working is not an effective
option. We have run monthly wellbeing pulse surveys and used the feedback to implement initiatives
that will support our employees’ physical and mental wellbeing through these challenging times.
Conscious of the impact the pandemic has had on domestic violence, we have launched our own online“Safe Space”, providing a portal of information and resources to support those in need, and we haveformed a partnership with the Employers Initiative on Domestic Abuse.

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Due Diligence Management and Risk exposure
Our risk management framework enables us to identify, assess, manage and control key risks to thebusiness including those related to slavery and human trafficking across the organisation. Ourcentralised risk team oversees a risk log and reports directly to the Risk Committee.
Through our recruitment, training and appraisal processes we aim to employ staff with high ethical andprofessional standards. All new employees undergo a vigorous verification process. We ensure thatthey have the right to work through document checks, proof of ID and investigation into duplicate bankaccounts.
Our policies clearly set out our company standards, with the Collinson Code, our company wide code ofconduct, being the overarching reference point for our behavioural expectations. We operate aconfidential Whistleblowing Policy and system to allow anyone to call out behaviour that does not alignwith the Collinson Code, and our shared values.
We expect the same high standards of ethical conduct from third parties with whom we engage. We
use our due diligence processes when onboarding new suppliers to explore areas of relevant risk andall new Suppliers are asked to sign up to and adhere to our “Expectations for Ethical Supply”.
Actions taken and Looking ahead
To summarise, during the last financial year, we have:• Supported our employees through the Covid-19 pandemic with Pulse surveys and various initiatives
to support physical and mental wellbeing.
• Rolled out the “Collinson Code”, our primary Code of Conduct, globally, which is applicable to all ofour group companies.
• Applied a modern slavery lens to our policies and helped drive change through the Employer’s
Initiative for Domestic Abuse (EIDA), Wellbeing programmes, Flexible Working and Diversity andInclusion initiatives.
• Won awards for our work and partnership with several charities, including Save The Children.
In our next financial year, we will be looking to build on our progress by:• Recruiting two new dedicated roles: a Head of Diversity, Inclusion and Wellbeing and aSustainability Manager. Whilst we are proud of the progress we have made to date we truly believethat the most meaningful change will occur when a colleague comes to work every day with the sole
focus of driving progress in these areas.
• Supporting our Procurement Director in developing a new Chapter of the Sustainable Procurement
Pledge, focusing on driving sustainable procurement practices in the Travel and Hospitality industry.
• Further developing our ‘SafeSpaces’ initiative, working with EIDA, and identifying further
opportunities to help domestic abuse victims beyond our organisation.
• Developing more formalised training relating to modern slavery for all of our employees.
• Working to improve the lives of at-risk and disadvantaged young people around the world through aseries of local and global partnerships.
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Our core policies and processes are endorsed by our Board of Directors and have clear ownershipshared by our Director of Governance, Risk and Compliance, our Director of Procurement and ourDirector of Corporate Responsibility.
ApprovalThis statement is made with respect to the financial year ended 31 April 2021 in accordance with s54(1)of the Modern Slavery Act 2015. This statement applies to The Collinson Group Limited, Collinson
International Limited, Priority Pass Limited, Lounge Key Limited and Astrenska Insurance Limited (eacha “Collinson Company”) and has been approved by the Board of Directors of The Collinson Group
Limited on behalf of each other Collinson Company. The statement will be reviewed and updated (ifnecessary) annually to reflect Collinson’s ongoing commitment to ensure its business and supply chain
are free from slavery and human trafficking. This statement is signed by a director of The Collinson
Group Limited, the holding company of the group.

Mark Hampton
Collinson Group Limited
September 2021

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