2.1 Company Overview

AboveTheWings Ltd (Company Registration Number: 15119005) is a travel technology company registered in England and Wales. We operate an online travel booking platform that connects travelers with accommodation providers worldwide, similar to other major travel booking platforms.

2.2 Business Structure

• Headquarters: England & Wales
• Business Model: Online travel booking platform
• Key Services: Accommodation booking, travel information, customer support
• Geographic Presence: Global online platform with local partnerships

2.3 Supply Chain Overview

Our supply chain includes:

• Accommodation providers (hotels, hostels, vacation rentals)
• Technology service providers (cloud hosting, payment processing)
• Marketing and advertising partners
• Customer support and communication services
• Professional services (legal, accounting, consulting)

4.1 Risk Assessment Process

We conduct regular risk assessments to identify potential modern slavery risks in our business operations and supply chains. Our assessment considers:

• Geographic risk factors (countries with high modern slavery prevalence)
• Industry-specific risks (hospitality and tourism sectors)
• Business relationship risks (new suppliers, subcontractors)
• Operational risks (remote work, temporary employment)

4.2 Due Diligence Procedures

Our due diligence processes include:

• Supplier Screening: Background checks and compliance verification
• Contract Terms: Anti-slavery clauses in all supplier agreements
• Regular Audits: Periodic reviews of supplier practices
• Certification Requirements: Preference for certified suppliers

5.1 Employee Training

We provide comprehensive training to all employees on:

• Recognition of modern slavery indicators
• Reporting procedures and whistleblowing policies
• Supplier relationship management
• Legal obligations under the Modern Slavery Act 2015

5.2 Management Training

Senior management and procurement staff receive specialized training on:

• Supply chain risk assessment
• Due diligence best practices
• Incident response procedures
• Continuous improvement strategies

6.1 Key Performance Indicators

We monitor the following KPIs to assess our anti-slavery efforts:

• Number of suppliers assessed for modern slavery risks
• Percentage of suppliers with anti-slavery clauses in contracts
• Number of employees trained on modern slavery awareness
• Number of reported incidents and resolution time
• Supplier audit completion rates

6.2 2024-2025 Performance

• Supplier Assessments: 100% of new suppliers assessed
• Contract Compliance: 95% of contracts include anti-slavery clauses
• Training Completion: 100% of employees trained
• Incident Reports: 0 confirmed cases of modern slavery
• Audit Coverage: 80% of high-risk suppliers audited

7.1 Reporting Procedures

If modern slavery is suspected or identified:

• Immediate reporting to designated compliance officer
• Preservation of evidence and documentation
• Cooperation with law enforcement authorities
• Support for victims and affected parties
• Review and improvement of prevention measures

7.2 Remediation Actions

Our remediation approach includes:

• Immediate cessation of problematic practices
• Support for victims through appropriate channels
• Corrective action plans for suppliers
• Enhanced monitoring and oversight
• Legal action where appropriate

8.1 Regular Reviews

We conduct regular reviews of our anti-slavery measures to:

• Assess the effectiveness of current policies and procedures
• Identify emerging risks and trends
• Update training materials and awareness programs
• Enhance due diligence processes
• Strengthen supplier relationships and requirements

8.2 Stakeholder Engagement

We engage with various stakeholders to improve our approach:

• Industry associations and working groups
• Non-governmental organizations (NGOs)
• Government agencies and regulators
• Academic institutions and researchers
• Peer companies and best practice sharing

9.1 Acknowledged Challenges

We recognize the following challenges in combating modern slavery:

• Complexity of global supply chains
• Limited visibility into subcontractor practices
• Cultural and legal differences across jurisdictions
• Resource constraints for comprehensive monitoring
• Evolving nature of modern slavery practices

9.2 Mitigation Strategies

To address these challenges, we:

• Prioritize high-risk suppliers and regions
• Leverage technology for better supply chain visibility
• Collaborate with industry partners and NGOs
• Invest in training and capacity building
• Maintain flexible and adaptive policies

10.1 2025-2026 Objectives

Our commitments for the next financial year include:

• Expand supplier assessment coverage to 100%
• Implement enhanced technology solutions for risk monitoring
• Develop industry-specific training programs
• Strengthen partnerships with anti-slavery organizations
• Publish regular progress updates and case studies

10.2 Long-term Vision

Our long-term vision is to:

• Eliminate modern slavery from our entire supply chain
• Become a leader in ethical business practices
• Inspire positive change across the travel industry
• Contribute to global efforts to end modern slavery