PJAY ASSOCIATES LTD Modern Slavery Statement

Pursuant to Section 54 of the UK Modern Slavery Act of 2015, PJAY ASSOCIATES LTD and its subsidiaries provide the following statement:

We are committed to improving our practices to combat slavery and human trafficking. We recognise that slavery and human trafficking is a real yet hidden issue in our society. We will not tolerate slavery and human trafficking in our business or supply chain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that any form of slavery is not taking place in our own business or supply chains.

Furthermore, we respect human rights and workplace rights and are committed to conducting our business in a manner that protects these rights; and prohibit and oppose all forms of modern slavery, servitude, forced labour and human trafficking.

Organisation’s Structure

We are a service-led, travel platform. Our ultimate parent company is PJAY ASSOCIATES LTD ,our head office based in England.

Our Business

We provide travel products and services provided by numerous lodging properties, airlines, car rental companies, destination service providers, cruise lines, vacation rental property owners and managers, other travel product and service companies etc. We also offer travel and non-travel advertisers access to a potential source of incremental traffic and transactions through our various media and advertising offerings on our websites.

Our High Risk Areas

The following activities are considered to be at risk of modern slavery within our organisation and the list will be reviewed and updated from time to time:

· business relationships with agents, independent contractors, consultants, and other business partners where their work practices may be non-compliant


Relevant Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

a. Recruitment – we operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

b. Whistleblowing – our whistleblowing policy ensures that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business without fear of reprisal.

c. Health and Safety – this policy sets out our approach to ensure we provide a healthy working environment for our staff and contractors that work out of our premises.

d. Equal Opportunities Policy – we are fully committed to ensuring that equal opportunities policies are implemented and maintained. All terms and conditions of service apply on a fair and consistent basis to every member of staff.

e. Corporate Social Responsibility Policy – we have long practiced strong corporate governance guidelines and we continue to advocate corporate responsibility in every facet of our business on a daily basis.


To ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation and our supply chains, we provide a training programme to our staff. All staff are encouraged to attend training in this area to better understand the risks.

Measuring Performance

We have zero tolerance to slavery and human trafficking. To ensure all those we work with – our agents, independent contractors, consultants, and business partners comply with our values we operate in line with principles of


responsible sourcing, including paying employees at the prevailing minimum wage applicable within their relevant location of operations.

Whilst our business does not extend to operating planes, hotels, rental cars, guided tours, cruise ships or other direct travel operator services, we are conscious of the supply chain and travel industry context in which we operate. We have accordingly begun to seek ways to utilise our systems to assist our travel suppliers and partners in identifying potential instances of human trafficking, and enhance their own monitoring.

We have in place a supply chain compliance programme that is maintained by the relevant account manager or relevant management. This consists of client and partner reviews; audits; and self-certification declarations.

To ensure all those in our supply chain comply with our values we conduct due diligence on all business partners and agents. Our anti-slavery policy forms part of our contract with all our partners and agents and they are required to confirm that no part of their business operations contradicts this policy.

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

· No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

We are committed as an organisation to tackling modern slavery and human trafficking and want to work with suppliers who share our values.

Further steps

We intend to take the following further steps to combat slavery and human trafficking:

1. risk assess all new partners using the Global Slavery Index and ask them to certify that they have taken steps to eradicate modern slavery within their own organisation and supply chain;


2. notify all existing suppliers of our expectations and their obligations in relation to the prohibition of modern slavery;

3. incorporate anti-slavery and human trafficking obligations into procurement agreements and subcontracting arrangements on a risk assessed basis;

4. include appropriate measures in our due diligence processes for sourcing suppliers, agents, business partners, subcontractors and acquisitions on a risk assessed basis;

5. provide training to relevant employees to ensure a high level understanding of the risks of modern slavery and human trafficking; and

6. where appropriate we will include reference to the Modern Slavery Act 2015 in our policies and procedures.


Signed by D I ASAGWARA on behalf of  PJAY ASSOCIATES Ltd

11 August 2019.

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