UK Modern Slavery Transparency Statement

This statement is published pursuant to Section 54 of the Modern Slavery Act 2015 (the “Modern Slavery Act”) on behalf of Direct Travel, Inc. d/b/a Direct ATPI Global Travel, a Delaware corporation, and its wholly-owned subsidiaries (“Direct ATPI Global Travel” and “Direct Travel”). References to “we” and “our” in this statement are references to Direct ATPI Global Travel.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and 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 modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Our Business

Direct ATPI Global Travel, through its subsidiary companies, is a travel management company, providing corporate travel, meetings and events, and leisure services. Direct ATPI Global Travel has a subsidiary based in the UK, Colpitts World Travel Limited UK.

Our Approach

We perform checks with respect to all candidates, employees at all levels, interns, agents, contractors, external consultants, third-party representatives, and suppliers who we introduce to clients to ensure that we clearly establish their identity. For individuals, this includes checking documentation as to their passport and right to work documentation. For corporate entities, this includes checking documentation with respect to their incorporation, insurance, and tax status.

In evaluating Direct ATPI Global Travel’s recruitment and hiring policies in the UK, the nature of the travel management business and its supply chain, the profile of the client base, and the business of Direct ATPI Global Travel, presents a very low risk of human trafficking, the use of forced, compulsory, or trafficked labour, or anyone held in slavery of servitude, whether adults or children. With respect to its office supply chain, communications/utility services/ IT service companies, and any facility management companies, where applicable, Direct ATPI Global Travel includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, in its agreements with contractors providing those services.

Direct ATPI Global Travel supports and approves of anyone who raises concerns in good faith about any issue or suspicion in any parts of our business or supply chains regarding the Anti-Slavery/Human Trafficking Policy.

Management Approval

Direct ATPI Global Travel remains committed to ensuring that we carry out our business in full compliance with applicable local law and best practice. That includes, but is not limited to, proper respect for human rights and a commitment to combating abuses of those rights, whether through human trafficking, slavery, child labour or otherwise.

The Directors approved of this Transparency Statement on August 7, 2023. It will be reviewed and updated annually.