Modern Slavery and Human Trafficking Statement
At Saga Travel Group (UK) Limited (trading as “Titan Travel”), we are committed to carrying out our business operations responsibly and to acting ethically and with integrity in all business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure slavery and human trafficking do not take place in our own business or in any of our supply chains.
Established in 1978, Titan Travel is the UK’s number one provider of escorted holidays worldwide, providing a superb choice of more than 200 tours and cruises to almost 100 countries and every continent. With an unswerving commitment to quality and value for money, Titan Travel continues to receive accolades from both consumers and the industry. Titan Travel was the pioneer of home transfers, and the acclaimed VIP door-to-door travel service ensures our customers enjoy a stress-free journey to and from the airport or port.
Titan Travel employs over 100 people who are largely based in our offices in Crawley, West Sussex.
As a business, we buy a wide range of things from flight seats, hotel rooms, cruises (cabins and full charters), coach services, guide services and more. Some of these things we use in our own business and others we use as part of the services we provide to our customers.
As a member of the Saga Group, Titan Travel complies with, and is subject to, all policies and processes that Saga plc has in place. Titan Travel’s employees have to complete the same mandatory training as Saga employees. In addition, Titan Travel is included within Saga’s wider audit activity to ensure we comply with both the law and Saga’s internal governance.
Modern Slavery Act 2015
As a result of the above, our statement includes the statement by Saga plc, which is set out in the appendix below. This describes the steps that Titan Travel and Saga plc have taken to prevent acts of modern slavery and human trafficking occurring in our own businesses and in any of our supply chains.
Our statement covers 1 February 2022 to 31 January 2023.
Chief Executive Officer
Modern Slavery and Human Trafficking Statement – July 2023
This statement is made on behalf of Saga plc (a public limited company listed on the London Stock Exchange, registered in England and Wales, with registered number 8804263) and its subsidiaries, as listed in Appendix 1, (together, “we”, “us”, “our”) pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”).
The Act requires companies to explain on an annual basis the steps taken to prevent acts of modern slavery and human trafficking from occurring in their businesses and supply chains. This statement includes the steps we have taken during the financial year ending 31 January 2023.
We are committed to carrying on our business operations responsibly with a zero-tolerance approach to any slavery and human trafficking incidents which are proven to have taken place. We remain committed to acting ethically and with integrity in all business dealings and relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking do not take place in our own business or in our supply chains.
2. About the Saga Group
We provide products and services predominately tailored to customers over the age of 50 in the UK. Such products and services include insurance, cruises and package holidays, personal finance and the Saga Magazine. Central to the success of each of these operations are our 3,137 employees, all of whom strive to deliver exceptional experiences to our customers every day. Our ‘Saga’ brand has been developed over the years to become a recognised and trusted brand among UK consumers aged over 50.
The varied nature of our products and services means we purchase a wide variety of goods and services from suppliers within the UK and internationally. Therefore, our supply chain is large and complex, with each supplier often having its own supply chain..
3. Risk Assessments
The Saga Group continues to operate a risk assessment process for new suppliers to assess any modern slavery risk which has been embedded in to our Procurement & Supplier Management onboarding process.
In respect of existing suppliers, we previously implemented a risk assessment process in respect of all existing suppliers across the Saga Group in 2016. As part of our ongoing monitoring of our modern slavery risk, in 2019 we re-examined our existing suppliers across the Saga Group to assess the potential for any residual modern slavery risk. Again, our holidays and cruise operations were identified as carrying a higher modern slavery risk due to the vast number of locations in which we procure goods and services. All other areas were identified as low risk from a modern slavery perspective and therefore no further action was required in respect of those existing suppliers.
In 2022, we began the process of re-examining our existing suppliers as part of our ongoing monitoring of modern slavery risk in our supply chains. We had expected to complete this in 2022 but, due to organizational changes within the business, this is now expected to be completed in 2023. The process of re-examining our existing suppliers will then be undertaken again in 2025 in line with our policy of carrying out follow-up risk assessments on existing suppliers every three years.
4. Due Diligence Questionnaires
Any suppliers identified as high risk (following the risk assessment process outlined above) are subject to further due diligence procedures, including the completion of a due diligence questionnaire designed to further assess the level of risk and the steps required to monitor and manage that risk.
In respect of our holidays and cruise suppliers identified as high-risk, our due diligence questionnaire is distributed by the relevant business Health and Safety team for completion by the relevant suppliers. The Health and Safety teams set realistic timeframes for suppliers to respond with a limited number of reminders if a response has not been forthcoming. As noted above, our non-holidays and cruise related operations (principally in the financial services sector) have been identified as low risk; however, should further due diligence be required, procedures are also in place to put these suppliers through our due diligence processes including providing them with a similar due diligence questionnaire.
We remain committed to working with our suppliers to ensure business is conducted ethically and honestly. In particular, in respect of those holidays and cruise suppliers identified as high-risk from a modern slavery perspective, our Health and Safety teams together with Product Managers work with those suppliers who have failed our due diligence questionnaire. This has involved first checking that suppliers have understood the questions and answered them correctly followed by, if required, working with them to implement corrective action plans to rectify areas of non-compliance. This remains an ongoing process. Should a supplier fail to co-operate with our due diligence procedures and/or any corrective action plan or otherwise demonstrate little progress despite realistic time frames being agreed and set, we have and will consider our future relationship with that supplier.
5. Policies & Training
We are committed to working responsibly and with integrity, as set out in our Personal Standards & Ethics Policy. We require the highest standards of personal and professional honesty and integrity from our employees in all business dealings and relationships, including with our customers, other employees and suppliers.
The prevention, detection and reporting of slavery and human trafficking in any part of our business or supply chains is the responsibility of all those working for us. Our Speak Up Policy ensures all employees are able to confidentially and anonymously raise concerns and report suspected violations via our Confidential Speak Up Service which can be accessed online and by phone.
The Speak Up Policy is communicated to employees as part of the corporate induction process and, in addition, it is available for our colleagues to access at any time on our intranet ‘Workplace’.
Our Anti-Slavery and Anti-Human Trafficking Policy is also communicated regularly throughout our organisation. It is reviewed annually and requires approval from the Saga plc Board on an annual basis although our policy approval processes are currently being reviewed.
Our policies are used as the basis for our employees to be able to detect and prevent acts of modern slavery. These policies also form part of our corporate induction process for new employees and are available on our intranet ‘Workplace’.
In line with our Anti-Slavery and Anti-Human Trafficking Policy, it is a requirement that all new agreements with suppliers must be in writing and contractually oblige the supplier to comply with the Act. Where possible, it is a requirement that each agreement shall give the relevant Saga Group company concerned a right of termination in the event that the contractor or supplier is proven to have committed slavery or human trafficking offences or to have acted in a manner inconsistent with the Act. We have, therefore, developed and implemented into our template agreements, specific contractual clauses covering these points. These are reviewed and enhanced where it is felt necessary.
We have continued to distribute training material to employees through our e-learning platform to ensure a consistent, high level of awareness and understanding of modern slavery is achieved. This is reviewed and will continue to be rolled out to employees on an annual basis. It has and will also continue to form part of the induction process for new employees.
6. Auditing & Ongoing Compliance
Our Internal Audit procedures incorporate an assessment of our modern slavery processes within all relevant audits and in 2022 we uploaded our statement to the Government Modern Slavery Statement Registry to share the steps we are taking to prevent modern slavery in our supply chains.
We remain committed to preventing slavery and human trafficking. As a result of structural changes within our businesses following the Covid-19 pandemic, we are currently reviewing our processes, beginning with our Travel businesses, to ensure they remain effective and will also seek opportunities for further improvements in assessing and developing our approach to modern slavery. As part of this, we remain keen to further develop our processes to ensure slavery and human trafficking do not take place anywhere in our own business or in any of our supply chains. As our processes evolve, we aim to identify and monitor appropriate performance indicators.
We have systems in place to:
Identify and assess potential risk areas within our businesses and supply chains;
Mitigate the risk of slavery and human trafficking occurring in our supply chains;
Monitor potential risk areas in our supply chains;
Train employees to raise awareness of modern slavery and how to report it; and
We will continually review and refine these processes to strive to operate to the highest standards at all times.
This statement covers 01 February 2022 to 31 January 2023 and has been approved by the Board of Saga plc.
Group Chief Executive Officer
APPENDIX 1 – SUBSIDIARIES*
Acromas Insurance Company Limited
PEC Services Limited
Saga Group Limited
Saga Membership Limited
Saga Mid Co Limited
Saga Personal Finance Limited
Saga Publishing Limited
Saga Services Limited
The Big Window Consulting Limited
Travel and Shipping Companies:
Saffron Maritime Limited (Guernsey)
Saga Crewing Services Limited
Saga Cruises Limited
Saga Cruises IV Limited
Saga Cruises V Limited
Saga Cruises VI Limited
Saga Travel Group (UK) Limited
Titan Transport Limited
* Please note the above list does not include dormant and non-trading companies.
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Why choose a Titan Travel tour or cruise?
Our award-winning collection of holidays covers all seven continents, with carefully planned itineraries ranging from rail journeys and river cruises, to small-group adventures and trips exclusively for solo travellers.
VIP travel service
Smooth transfers to and from home with unlimited mileage
From excursions to hotels, entry tickets and dining packages, we include more than any other tour.
Be guided by some of the most passionate and knowledgeable tour managers in the world, on hand to help every step of the way.
Feel free to amend or extend your travel plans, up until final payment, and enjoy free time on your tour with us too.