Anti-slavery and humantrafficking statement 2017 2018
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out thesteps taken by Collinson Group (“Collinson”) during the year ending 31 April 2018 to combat modern
slavery and human trafficking in its business and supply chains.

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, if any, during its financial
year to ensure that slavery or human trafficking is not taking place in its supply chain.
Collinson fully supports the objectives of the UK Modern Slavery Act and will not tolerate any form ofslavery. This statement sets out our approach to managing modern slavery risks in our operations andsupply chains. It relates to the actions and activities undertaken across our organisation irrespective ofturnover, to ensure slavery and human trafficking does not take place internally or anywhere within its
supply chain.
As an ethically driven company, Collinson respects the human rights of all those who work for us
directly and on our behalf. We will not accept any violation of these rights particularly in relation tohuman trafficking and slavery in any form and actively work to ensure suppliers and partners work inaccordance to the same belief.

Our business
Collinson is a global loyalty and benefits company operating in over 20 countries throughout theAmericas, Asia Pacific, Europe, the Middle East, India and Africa. We use our expertise and products tocraft customer experiences which enable some of the world’s best known brands to acquire, engage
and retain customers. We aim to be a business that our clients want to work with and our people areproud to work for and be a place of innovation and creativity, driving job satisfaction and a sense of
belonging for our people. We also aim to be a commercially successful and trusted organisation with asocial conscience, providing a share of our profits, assets and people to enhance the communities andenvironment in which we operate.
But we don’t work alone - we rely on a global network of suppliers and partners to help us deliver ourinnovative and customer focussed solutions; and we don’t just work with anyone - we are a value driven
organisation and our values drive our decision making and reflect the way we work, challenging us topush boundaries and make a positive impact globally.

1Collinson expects that its employees, partners and suppliers work with integrity and maintain robust
standards of governance, seeking to avoid any decisions that may have a negative societal impact. Asa minimum we expect our partners and suppliers 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 in
confidence to Collinson’s Head of Internal Audit or the Global People & Culture Director. The
Collinson Whistle Blowing Policy is in place to safeguard here and offer an alternative route toraising concerns.
We are guided by established standards such as the International Labour Organisation Core
Conventions, 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:• provide a safe and hygienic working environment (and, where relevant, living quarters) for all
workers 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.

2

Risk exposure and management
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.
Our commitment to preventing the crystallisation of these risks can be evidenced in our recruitment andappraisal processes as well as our company policies which are reviewed on an ongoing basis. We aim
to employ staff with high ethical and professional standards and expect the same high standards of
ethical conduct from those parties with whom we engage with.

Actions taken and looking ahead
We have hired a new Procurement Director and a new head of Corporate Social Responsibility (“CSR”).
Our Procurement Director has conducted a review of our third party sourcing processes and worked
with our new head of CSR to introduce our “Expectations for Ethical Supply” (“Expectations”) which
detail the standards we set for both ourselves and for all of our partners and suppliers across a broad
range of criteria.
In the next financial year, we will be requesting our existing suppliers to sign up to this policy through aphased roll out. When considering the award of future contracts (with both new and existing suppliers),
we will be building our Expectations into our sourcing processes and meeting our Expectations will
become one of the key elements of our decision making criteria.
We expect full transparency from our partners and a commitment to gaining full compliance with ourExpectations (or as close to them as legally possible) if any areas of noncompliance are identified.
Our Expectations are owned by our Procurement Director, with support from Collinson’s Board ofDirectors. The Expectations shall be updated from time to time to reflect changes in legislation,regulations, and good practice.
In the next financial year we will also be reviewing our management approaches to monitoring
compliance with our Expectations and continuing to enhance our procedures to help us ensure that, so
far as possible, our own operations are free from Modern Slavery.

ApprovalThis statement is made with respect to the financial year ended 31 April 2018 in accordance with s54(1)of the Modern Slavery Act 2015. This statement applies to Collinson International Limited, Priority PassLimited, Lounge Key Limited and Astrenska Insurance Limited (each a “Collinson Company”) and has
been approved by the Board of Directors of Collinson Group Limited and each other Collinson
Company. The statement will be reviewed and updated (if necessary) annually to reflect Collinson’s
ongoing commitment to ensure its business and supply chain are free from slavery and humantrafficking. This statement is signed by a director of Collinson Group Limited, the holding company ofthe group.
Mark Hampton
Collinson Group Limited
December 20183