Modern Slavery Statement

Section 1 Governance

Ison Management Group is committed to upholding human rights and preventing modern slavery and human trafficking across its operations and global supply chain.

Oversight of modern slavery risk management is delegated by the Board of Directors to the Audit Committee. The Board retains ultimate accountability for ensuring compliance with the UK Modern Slavery Act 2015 and broader human rights obligations.

Operational responsibility is managed by a cross-functional working group comprising representatives from Legal, Human Resources, Procurement, and Senior Management. This group is responsible for policy implementation, supplier oversight, training delivery, and risk monitoring.

This statement has been approved by the Board of Directors and will be reviewed annually.

Section 2 Policy Framework

Our approach is underpinned by the following internal governance documents:

• Modern Slavery & Human Trafficking Policy
• Supplier Code of Conduct
• Whistleblowing Policy
• Ethical Business Conduct Standards
• Procurement & Supplier Due Diligence Procedures

These policies reflect:

• UK Modern Slavery Act 2015
• UN Guiding Principles on Business and Human Rights
• OECD Due Diligence Guidance for Responsible Business Conduct

Section 3 Risk Assessment & Supply Chain Management

Supply Chain Overview

Ison Management Group operates within the global travel sector. Our supply chain includes:

• Airlines
• Hotel and accommodation providers
• Tour operators
• Ground handlers
• Travel service providers and agents

We recognise that the travel and hospitality sector may present inherent risks relating to labour standards in certain geographic regions.

Risk Assessment Process

We apply a risk-based approach to identify, assess, and manage potential modern slavery risks. This includes:

• Evaluating suppliers during onboarding
• Reviewing supplier compliance with ethical standards
• Monitoring supplier risk profiles based on geography, sector, and services provided
• Incorporating human rights and anti-slavery provisions into supplier agreements

Accommodation providers are expected to maintain recognised certification standards and compliance with international hospitality and labour regulations.

Section 4 Due Diligence & Controls

Our due diligence framework includes:

Supplier Onboarding

• Assessment of supplier ethical standards
• Inclusion of anti-slavery clauses within contractual terms
• Acceptance of our Supplier Code of Conduct

Ongoing Monitoring

• Periodic review of supplier relationships
• Engagement with accommodation providers holding recognised international certifications
• Monitoring of publicly available risk indicators and alerts

Contractual Protections

We are incorporating specific anti-slavery representations, warranties and compliance obligations within supplier agreements and expect equivalent standards to cascade through supply chains.

Section 5 Reporting & Whistleblowing

We maintain confidential reporting mechanisms that enable employees and stakeholders to raise concerns regarding unethical conduct, including suspected modern slavery.

We are committed to protecting whistleblowers from retaliation and investigating all credible reports appropriately.

Section 6 Training & Awareness

We are committed to promoting a culture of ethical conduct and human rights awareness. We provide relevant training to employees, particularly those in procurement, operations, HR and senior management roles, to ensure they:

• Understand modern slavery risk indicators
• Recognise high-risk geographies and sectors
• Know how to escalate concerns
• Understand their responsibilities under company policy

Modern slavery awareness is integrated into broader compliance and governance training where appropriate. These measures support our commitment to fostering an ethical and compliant organisational culture aligned with ISO compliance standards.

Section 7 Performance & Continuous Improvement

During the reporting period, we:

• Continued updating supplier terms to strengthen anti-slavery protections
• Maintained oversight through Board-level governance
• Reviewed supplier engagement processes
• Reinforced internal awareness of modern slavery risks

We are committed to continuous improvement of our due diligence processes and supplier engagement practices.

Section 8 Compliance with Legal & ESG Reporting Requirements

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and supports broader ESG and corporate governance reporting obligations, including:

• Human rights due diligence expectations
• Ethical supply chain management
• Corporate governance and compliance transparency

This statement applies to Ison Management Group and its subsidiaries and will be published on our website and submitted to the UK Government Modern Slavery Statement Registry.

Section 9 Key Commitments for 2025–2026