LAST UPDATE 02/05/2025

Opening statement

This statement sets out the efforts we have undertaken to understand the specific risks to TravelPerk and the steps towards addressing modern slavery (including forced labour and human trafficking) in our operations and supply chains on a global level.

At TravelPerk, our core values guide every business decision we make. Our values are embedded in, align with, our commitment to taking action to eradicate modern slavery

• A 7-star experience: As a hyper-growth business, our conduct, integrity, and reputation are foundational to achieving our long-term ambition of becoming a 100-year company. Delivering a 7-star experience doesn’t stop at product or customer service—it extends to how we show up as ethical leaders in the industry.
• Impact over effort: Focus means making deliberate choices—even when they’re hard. That’s why we’ve embedded clear, enforceable standards in our supplier contracts, partnered only with organisations that share our values, and conducted hands-on audits where it matters most.
• Be a good person: Our Code of Conduct isn’t just a policy—it’s a reflection of who we are. Itsets the tone for how we treat one another, how we act when no one’s watching, and how we define what it means to be a TravelPerker.
• We are a team: We treat suppliers as partners, not just vendors. By building collaborativerelationships that span all our supply chain (e.g., Marriott Group, Deutsche Bahn, Jones Lang LaSalle and more), we ensure mutual responsibility for upholding human rights.
• We are all owners: Ownership means we don’t just spot problems—we solve them. Everyone atTravelPerk is empowered (and expected) to take action when something doesn’t align with our values. Combatting modern slavery is a responsibility we own across teams, functions, and leadership.

Our structure

Around half our staff are based in Barcelona, Spain. We have offices located across Europe, the UK and the US. The overwhelming majority of our customers and suppliers are located in these territories.

All entities in our group are wholly owned, directly or indirectly, by TravelPerk Inc.

TravelPerk acquired a new entity American Travel Solutions LLC (AmTrav) in 2024. AmTrav underwent a comprehensive due diligence process during the merger, with specific attention paid to its operations, supply chains, and people-related practices.

We are currently engaged in ongoing efforts to ensure full integration of AmTrav—this includes aligning all policies and practices with TravelPerk’s standards, and driving consistency across the entire organisation.

Governance and policies

TravelPerk has implemented measures to minimise risks relating to modern slavery and human rights, including verifying and recording employee compliance with its Code of Business Conduct and Ethics (the Conduct Code), promoting channels for stakeholders to report unethical or illegal issues, and promoting a positive working culture among its suppliers through its suppliers through its Supplier Code of Conduct (the Supplier Code).

TravelPerk reviews its policies and processes regularly, and deploys considerable resources to ensuring that its policy suite accords with best practice.

Conduct code

The Conduct Code applies to all contractors, consultants, employees, executives and directors of all TravelPerk's companies and offices. In summary, the Conduct Code:

• emphasises ethical and legal principles to be followed by our personnel, and the importance ofmaking good, ethical decisions at all times. The Conduct Code expressly recognises theimportance of ethical decision-making, and perceptions of ethical conduct.
• highlights the importance of creating a respectful workplace, inclusive culture, and equalopportunity regardless of race, gender, sexual orientation, or any other matters.
• prohibits any acts of violence, harassment, or bullying in the workplace, includinggender-based behaviour discrimination, unwelcome flirtation or sexual advances, sendingporn or sexual pictures, and name-calling that is insulting or humiliating.
• emphasises respecting privacy, intimacy, labour rights, and security at work.

Employees are required to read and confirm their acceptance of the Conduct Code, and TravelPerk’s Anti-Corruption and Anti-Bribery Policy, during onboarding and annually thereafter. We track completion of this exercise (and the completion of other important internal policies) using the online platform KnowBe4. TravelPerk expects personnel to immediately report any behaviour or activity that jeopardises the safety or well-being of the company and its employees.

TravelPerk's employment and personnel policies comply with relevant labour laws, and promote the company's culture of respect as an equal opportunities employer.

Supplier Code

You can find the Supplier Code here. In summary, the Supplier Code:

• incorporates specific provisions for suppliers regarding human rights and labour rights.Suppliers are required to respect diversity and ensure that everyone is treated with dignity andrespect regardless of their personal characteristics.
• incorporates minimum standards for working conditions and pay including, specifically, thepayment of living wages and the provision of humane conditions for workers. Workers must not work more than the maximum daily working hours set by local laws, and must receive legallymandated benefits and leave.
• prohibits all forms of offensive behaviour and harassment towards workers.
• prohibits use of forced, bonded, involuntary or child labour. Suppliers are obligated to reportany risks of human trafficking or exploitation, or incidents or suspicions of sexual or otherexploitation of children, to local authorities.

In case of any uncertainty or immediately on becoming aware of any matter that may contravene the Supplier Code of Conduct, Suppliers are obligated to contact legal@travelperk.com.

Supply chain

TravelPerk boasts a high-quality supply chain that supports key operational areas like customer care, and supplier relations. Several of our key suppliers - like Marriott Group and Deutsche Bahn - have made their own public commitment to combating modern slavery.

These partnerships are not just transactions; they represent collaborative ventures where suppliers are integral partners to TravelPerk, working in tandem to achieve mutual success, sharing knowledge and learnings to develop compliance in anti modern slavery efforts. Through these alliances, we deliver outstanding experiences for our customers and operational efficiency, and we uplift our standards by proxy.

To further develop our approach to modern slavery, our procurement team has begun to map our supplier base to improve visibility and oversight. This foundational work includes the gradual implementation of more robust onboarding processes for suppliers, with an emphasis on reducing and streamlining our tech suppliers to better manage risk.

In 2024, our Security, Legal, and Privacy teams rolled out a more structured onboarding process for technology tools and external consultants, incorporating checks that by proxy, identify and mitigate potential modern slavery risks as part of a broader risk management framework.

Business process outsourcing (BPO) partners

We select BPO providers according to country, cultural, and business ethics, including compliance with standards expressed in the Ethical Trading Initiative base code. In addition, our contracts with outsourcing companies contain provisions we consider appropriate to support our compliance with the Modern Slavery Act.

To maintain visibility and ensure consistent oversight, in 2024, TravelPerk’s Vendor Management team implemented a more frequent site visit approach—sending TravelPerk team members to one of our outsourced hubs (in Salvador, Mauritius, Egypt and the Philippines) at least once every quarter. These visits allow us to assess working conditions firsthand. We engage directly with staff, and reinforce the importance of ethical conduct and values alignment, with over 90% of the meetings happening in the centres to ensure that we see daily running and operations.

During these in person meetings, we interviewed and confirmed with relevant persons the continued commitment to fair treatment of workers (including catering and cleaning services used in our offices):

• Every hire is subject to the presentation of a birth certificate or other equivalent documentation, in order to verify age and ensure no one under the legal age is hired.
• All employees have the skills required for their jobs’ description, receive training, and can leave their jobs on 30 days’ notice.
• All employees are free to associate and be part of collective deals.
• The facilities are safe and hygienic as attested by the providers, checked personally by TravelPerk’s staff against a quality control checklist.
• Working hours are compliant with local laws and regulations.
• Living wages are pre-agreed and over the national legal standard and reviewed regularly.
• The providers have put in place anti-discrimination measures and policies.
• There are internal rules, policies and procedures against inhumane treatment and abuse in the working environment.

We only work exclusively with internationally recognised outsourcing partners, including Concentrix, Enshored, Yngen, and IGT—all of whom have demonstrated alignment with our ethical standards and commitment to fair labour practices, and have undergone TravelPerk’s due diligence RFP process.

In 2024, we further introduced a TravelPerk-owned Reward and Recognition programme aimed specifically at our outsourced teams. This initiative recognises and rewards high-performing individuals who embody our values, with at least 20% of team members celebrated monthly. While not directly part of our compliance framework, this investment reflects our broader commitment to uplifting worker wellbeing and fostering a respectful, motivating environment across our extended workforce.

Workspace

The UK Government has identified the engagement of service staff - such as cleaners and canteen workers - as the highest risk area for modern slavery in the UK. Factors that make the cleaning sector susceptible to exploitation including fractured supply chains, low wages (meaning that many cleaning operatives are migrants, who may face language barriers or lack access to legal protections, making them prime targets for traffickers), and the ‘invisibility’ of service work (in that cleaning, for example, often occurs outside regular business hours, reducing visibility and increasing the risk of exploitation).

Our workspace team comprises both TravelPerk employees and contractor/ sub-contractor staff. During 2025, we intend to improve our direct engagement with and audit of contractor/ sub-contractor staff, both to ensure that our suppliers’ comply with their contractual commitments to combat exploitation, and to ensure the entirety of our workplace team is treated with dignity and fairness

Progress and looking forward

As TravelPerk continues to scale, we understand that growth brings increased complexity—and with it, heightened exposure to potential modern slavery risks. Looking forward, TravelPerk will begin reviewing The Supplier Code and The Conduct Code. These documents are not just formalities—they are core tools in how we communicate our expectations, uphold our values, and mitigate risk across our expanding global footprint.

By keeping these codes up to date, we ensure that both our internal teams and external partners understand the behaviours, principles, and safeguards we expect as we grow and adapt into new markets. This includes clear guidance around ethical conduct, fair treatment, and the absolute prohibition of forced labour, human trafficking, or exploitation.

We also continue to engage with interested customers and prospects on the subject of our labour supply chain. These interactions continue to help us shape this policy, and to develop the efficacy and utility of our program. We thank the individuals and companies who have shared their views.

Applicability

The following statement is made by TravelPerk Inc. and its subsidiaries (including, without limitation, the UK-domiciled companies TravelPerk Ltd, TK Operations Ltd, Click Holdings Ltd, and TravelPerk UK IRL Ltd and newly acquired American Travel Solutions LLC), referred to collectively here as TravelPerk.

This statement is made in compliance with section 54(1) of the UK Modern Slavery Act 2015.

Please feel free to contact us at legal@travelperk.com with any comments, queries or suggestions regarding this statement.

Abraham Meir
Co-Founder and CEO

Approved by TravelPerk, Inc’s Board of Directors on 16^th April 2024 in relation to the financial year ending 31 December 2023

TravelPerk S.L.U., TravelPerk GmbH, TravelPerk America, Inc., TravelPerk US Inc., TK Operations Ltd, Click Holdings Ltd, TravelPerk Ltd and TravelPerk UK IRL Ltd are all wholly owned subsidiaries of TravelPerk, Inc., directly or indirectly.