Last Update: January 2022

The Ink Group acknowledges its responsibilities in relation to tackling modern slavery and human trafficking and commits to complying with its obligations under the Modern Slavery Act 2015. The Ink Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

This statement applies to all the companies listed within Appendix 1 to this statement (collectively referred to in this statement as ‘The Ink Group’). The information included in this statement is for the financial year ending 31st December 2021.

Definition

Modern slavery encompasses slavery, servitude, forced and compulsory labour and human trafficking.

Some examples of modern slavery are:

• Human trafficking;
• Forced work through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or having a restriction placed on freedom of movement.

Organisational Structure

The Ink Group is a global leader in the creation of travel media. Headquartered in London, with offices in the United States, Singapore and Brazil, the Ink Group creates bespoke media content for a number of the world’s major airlines, US airports and travel groups across inflight magazines, mobile devices and other digital, print and video media products. In addition we sell advertising to the largest brands in the world today. The Ink Group is made up of the businesses listed in Appendix 1 to this statement. Each entity within the Ink Group is controlled by a Board of Directors or local equivalent. Whilst our staff work across the world, they are predominantly engaged in the United Kingdom, the United States of America, Singapore and Brazil.

Potential Exposure

The Ink Group considers its main exposure to the risk of modern slavery and human trafficking to exist via its suppliers and subcontractors in its supply chains because they may involve the use of labour in a country where protection against modern slavery and human trafficking is limited.

The Ink Group also recognises the risk of modern slavery and human trafficking within its workforce particularly where temporary workers and agency workers are supplied by employment agencies.

In general, the Ink Group considers its exposure to modern slavery and human trafficking to be relatively low. Nonetheless, it has taken appropriate steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Supply Chains

The Ink Group’s supply chains are both UK based and worldwide. They include travel providers (predominantlyairlines), media marketing, media advertising, paper suppliers, print and digital production, distribution channels, mailing services and freelance content suppliers. They also include professional services from third party advisers, IT service suppliers, office cleaning suppliers and other office facilities services suppliers. The Ink Group is committed to ensuring it does not enter into any business relationship with any organisation, in the United Kingdom or abroad, which does not share the Ink Group’s commitment to combatting modern slavery and human trafficking.

Labour

The Ink Group is committed to ensuring that no person working for the Ink Group is the victim of modern slavery or human trafficking. The Ink Group strictly adheres to and exceeds the minimum standards required in relation to its responsibilities under relevant employment legislation in the countries in which its staff work.

Steps Taken Against Modern Slavery

The Ink Group has taken the following steps to combat modern slavery and human trafficking risks within its business and supply chains:

• The Ink Group carries out due diligence processes in relation to ensuring slavery and/or human trafficking doesnot take place in its organisation or supply chains, including conducting a review of the controls of its suppliers;
• The Ink Group has a Whistleblowers Policy and Procedure detailed in the Ink Group’s employee handbook to make sure all our staff know they can report actual or suspected modern slavery and human trafficking issues without facing unfavourable treatment;
• The Ink Group’s HR department ensure we have the correct right to work information for all employees and that we comply with both UK and local legal requirements in territories outside of the UK;
• All our employees are treated fairly and equally, and are paid at least the national minimum wage or local equivalent;
• The majority of the Ink Group’s suppliers are low risk with whom Ink maintains a long term and good working relationship;
• The Ink Group requires specific contractual commitments in our partner, subcontractor and supplier contracts; and
• The Ink Group reviews its existing supply chains to identify any high risk suppliers and/or jurisdictions.

Key Performance Indicators

The Ink Group has set the following key performance indicators to measure its effectiveness in ensuring modern slavery and human trafficking is not taking place in the Ink Group’ business or in any of its supply chains.

• Use of the Whistleblowing policy in relation to modern slavery and human trafficking issues, As of the date of this statement there have been zero (0) instances;
• Review of our recruitment and payroll systems to ensure our recruitment practices comply with all applicable laws (100% achieved);
• Reviews with our direct suppliers to understand the level of communication and personal contact with the next link in the supply chain and their understanding of, and compliance with, the Ink Group’s expectations in relation to modern slavery and human trafficking (in progress & ongoing).
• Review of current agreements with our partners to ensure a statement confirming all entities and affiliated companies have never been convicted of offences relating to modern slavery and comply with their legal and ethical obligations in this regard (in progress & ongoing).

The Ink Group has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery or human trafficking.

Training And Awareness

The Ink Group takes the following steps to support its stance against modern slavery and human trafficking:

• Raise employee awareness via the employee handbook and induction process for new employees;
• Make a copy of the Ink Group’s Modern Slavery Policy available to all staff electronically and a copy of the Modern Slavery Act 2015 available from the HR department upon request.

Ongoing Commitment

The Ink Group is committed to ongoing review and constant improvement of our practices to combat modern slavery and human trafficking both within our business and within our supply chains. We recognise the important role we play in combatting modern slavery and human trafficking issues and the positive influence we can have across our supply chains.

This statement has been approved by a Director of Travel Content Limited on behalf of the Ink Group, is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 for the financial year ending 31st December 2021 and will be reviewed for each financial year.

Appendix 1

The Ink Group is headquartered in the UK at Blackburn House, Blackburn Road, London NW6 1RZ and is made up of the following entities:

Travel Content Limited; parent company registered in the UK (11504751);

Volanti Media (Holdings) Limited registered in the UK (10812060);

Volanti Management Limited registered in the UK (10812330);

Volanti Media Limited registered in the UK (10812511);

Volanti Holdings Limited registered in the UK (09331218);

Ink Publishing (Holdings) Limited registered in the UK (05879839);

eSubstance Limited registered in the UK (03829537);

Ink Do Brasil Consultancy & Marketing Services Limited registered in Brazil;

Ink Publishing Corporation registered in the United States;

Travel Content LLC (joint venture) registered in the United States;

Ink Publishing (HK) Limited registered in Hong Kong;

Ink Publishing (PTE) Limited registered in Singapore;

Ink Publishing Advertising (Shanghai) Co Limited registered in the Peoples

Republic of China.