About Aarsal Travels Ltd

Modern Slavery and Human Trafficking Statement 2025

This statement is made by Aarsal Travels Ltd pursuant to section 54 of the UK Modern Slavery Act 2015 and sets out the steps we take to prevent modern slavery and human trafficking in our business and supply chain.

Introduction

Aarsal Travels Ltd arranges flights, hotels and package holidays for customers travelling across Europe, Asia, the Middle East and North America. To deliver those journeys we work with airlines, hoteliers, transfer companies, ground handling agents and local partners in many countries. That global footprint brings both challenges and opportunities in addressing human rights.

We are committed to addressing modern slavery and human trafficking across our operation, network and supply chain. This commitment is underpinned by our Modern Slavery and Human Trafficking Policy and our Human Rights Policy, through which we assess and manage risk in line with the UN Guiding Principles on Business and Human Rights.

During 2025 we improved our internal processes to prevent, identify and address issues and to track progress. There is still work to do, and we continue to drive improvement with dedicated focus from our leadership team.

6 priority categories

We increased the number of targeted supply chain categories we assess in detail.

100% of core suppliers

Our largest suppliers are asked to confirm compliance with our Third Party Code of Conduct.

All colleagues trained

Every member of our team completes modern slavery awareness training on joining and annually.

01. Our business

Aarsal Travels Ltd is a UK travel company registered in England and Wales, with its office at 1st Floor, Interchange House, 81-85 Station Road, Croydon, CR0 2RD. We sell flights, hotels, transfers and tailor-made holidays to customers in the UK and overseas, both directly and through trade partners.

Our business is run by a small management team supported by reservations, operations and customer care colleagues. In this statement, references to 'Aarsal', 'we' or 'the company' mean Aarsal Travels Ltd and its relevant group entities.

02. Our sourcing

The majority of our spend relates to airline seats, hotel accommodation and ground transport, followed by technology services, marketing and office operations. Our supply chain mapping is based on the information we hold about our direct suppliers, most of whom are based in the UK and in the destinations we serve.

Many of those suppliers have their own suppliers in other countries, where the risk of modern slavery may be more prevalent. We continue to extend our mapping beyond direct suppliers and we ask our key partners to do the same.

03. Policies and procedures

PolicyDescription
Aarsal Code of ConductOur Code of Conduct sets out the principles for everyone working within Aarsal Travels Ltd, the behaviour expected of them and how to raise concerns. It requires that our activities respect the human rights of others, including a commitment to tackle any form of forced or involuntary labour, human trafficking and modern slavery anywhere in our business.
Third Party Code of ConductOur Third Party Code of Conduct deals expressly with modern slavery and sets out clear expectations for suppliers and partners. From the outset we require suppliers to observe ethical hiring practices, including verification of a worker's age and legal right to work. Suppliers must report any non-compliance to us. In serious cases we will engage regulators and law enforcement, terminate the relationship, or both.
Human Rights PolicyOur Human Rights Policy confirms our commitment to respect, protect and promote internationally recognised human rights as set out in the UN Guiding Principles on Business and Human Rights, supported by a risk-based framework for managing those risks across the business.
Modern Slavery and Human Trafficking PolicyThis policy reaffirms our firm commitment to preventing and combating modern slavery and human trafficking, whether issues arise within our own business or in our supply chain. It applies to everyone working for or on behalf of Aarsal Travels Ltd, including employees, temporary workers, interns, agents, contractors, consultants and business partners.
Industry standardsWe follow recognised travel and aviation industry guidance on combatting trafficking in persons, and we support the commitment of the wider industry to help governments and law enforcement prevent human trafficking through awareness raising, staff training and effective reporting.
Contractual provisionsOur supplier contracts include an explicit prohibition of modern slavery and child labour, together with requirements covering equal opportunities, freedom of association, forced labour, wages, benefits, working hours, and harassment and dignity at work.

04. Bringing our policies to life

Dignity and respect

We work with airlines, airports and authorities so that any suspected trafficking connected with travel we have arranged is identified, reported and dealt with appropriately.

Fair employment practices

Our suppliers must provide wages, benefits and overtime pay that comply with all applicable wage and hour laws, and must respect rules on working hours, rest periods and overtime.

Looking beyond tier one

We communicate our expectations to suppliers and partners at the very start of the relationship, and we are committed to taking swift action if any evidence of slavery or trafficking is identified.

Speaking up

Every colleague is expected to speak up if they see or suspect any form of human rights abuse. Concerns can be raised confidentially and without fear of retaliation.

05. Governance and oversight

Responsibility for this statement and for our modern slavery programme sits with the directors of Aarsal Travels Ltd. Day-to-day oversight is delegated to our operations lead, who reviews supplier due diligence, training completion and any concerns raised, and reports to the directors at least annually.

Any credible allegation of modern slavery is escalated to the directors immediately and, where appropriate, reported to the relevant authorities.

06. Mapping risk in our supply chain

We use a risk-based methodology that considers three factors together: the country or region in which a supplier operates, the nature of the product or service, and the type of labour typically used to deliver it. Suppliers scoring highest against these factors are prioritised for enhanced due diligence.

1. Identify

Map suppliers by category, country and labour profile.

2. Assess

Score inherent risk, then request evidence such as policies, audits and worker feedback.

3. Act and monitor

Agree improvement actions, re-check at renewal, and exit suppliers who will not engage.

07. Priority supply chain categories

Hotels and accommodation

Products and services

Rooms, resorts, apartments and villa stays booked for our customers.

Risk factors

Housekeeping, laundry and maintenance roles are often outsourced or filled through agencies, with a higher incidence of migrant labour and recruitment fees.

Ground transport and transfers

Products and services

Airport transfers, coaches, private drivers and excursion transport.

Risk factors

Long hours, informal subcontracting and cash-based employment can obscure working conditions and pay.

Agency workforce

Products and services

Temporary and seasonal staff engaged through recruitment agencies.

Risk factors

Recruitment fees, withheld documents and unclear terms of employment are known risk indicators in agency supply.

Call centres and outsourced services

Products and services

Customer contact, back-office and IT support services.

Risk factors

Offshore delivery centres can involve extended shift patterns and subcontracted staffing arrangements.

Uniforms and merchandise

Products and services

Staff uniforms, branded clothing and printed materials.

Risk factors

Garment manufacturing beyond tier one carries recognised risks of forced labour and unsafe conditions.

Excursions and local experiences

Products and services

Guides, activity operators and local tour partners in destination.

Risk factors

Small, informal operators may fall outside local labour inspection and use family or unpaid labour.

08. Training and awareness

All colleagues complete modern slavery and human trafficking awareness training when they join and refresh it annually. Training covers the indicators of exploitation, what to do if a customer or member of the public raises a concern, and how to report suspicions safely and quickly.

Colleagues in reservations and operations receive additional guidance on the specific indicators that can be visible during travel, including unusual booking patterns and third parties controlling a traveller's documents.

09. Our workforce

We carry out right-to-work checks on every colleague, pay at or above the applicable statutory minimum, and provide written terms of employment in a language each colleague understands. We never charge recruitment fees, retain identity documents or require colleagues to work excessive hours.

10. Looking forward

  • Extend supply chain mapping beyond our direct suppliers in priority categories.
  • Introduce a standard modern slavery questionnaire for all new accommodation and transfer partners.
  • Refresh our Third Party Code of Conduct and re-issue it to every active supplier.
  • Continue to work with industry bodies and destination partners to share best practice.

Reporting concerns

If you have any concerns about modern slavery or human trafficking in our operations or supply chain, please contact us in confidence at info@aarsaltravelsltd.com or call 020 4524 0462.

Approval

I confirm that the information in this statement is true, accurate and complete in all material respects for the purposes of the relevant legislation, and that I have the authority to give this commitment on behalf of Aarsal Travels Ltd.

This statement was approved by the board of directors of Aarsal Travels Ltd and covers the financial year 2025. It is reviewed and updated annually.

Director, Aarsal Travels Ltd