Modern Slavery Statement
Modern Slavery Statement – September 2025
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced or 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. Top Travels has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its business or in any of its supply chains.
Top Travels is committed to ensuring there is transparency in its business and approach to tackling modern slavery throughout its supply chains, consistent with its disclosure obligations under the Act.
Our Business and Supply Chain
Top Travels is a fast-growing online retailer of holidays and we act as agent to facilitate bookings for our customers. The business is operated from the United Kingdom and serves hundreds of customers every year. When arranging holidays Top Travels act as an agent only and customers contract directly with their chosen suppliers of flights, hotels and/or transfers. For flights, the business tends to act as agent for the consumer, except where a specific agency agreement is in place with an airline. For hotels and transfers, Top Travels has agreements in place with suppliers which enable it to sell the relevant services to the customer as agent for the supplier. For package holidays, the business acts as “package organiser” and has obligations to ensure the package holiday is properly performed by the customer’s suppliers even though it is acting as an agent.
Our supply chain includes direct and indirect contracts with certain Service Providers and contracts regarding services which support the operation of our business (including marketing, IT, software, human resources, agency, credit card processing and professional advisory services). The Service Providers and providers of ancillary services that are involved in such supply chain are located in the UK and globally.
Our Policies
Top Travels has in place a number of policies and procedures to ensure that business is conducted in an ethical and transparent manner. These include:
Anti-Bribery and Corruption Policy – guidance on recognising and countering bribery and corruption.
Modern Slavery Policy – outlines our stance on modern slavery, how to recognise it and report it.
Recruitment – our recruitment procedures include checks of eligibility to work legally in the UK.
Whistleblowing Policy – employees are encouraged to raise concerns about any wrongful treatment or practice within our business or supply chain, including potential acts of modern slavery.
We encourage openness and will support anyone who raises genuine concerns in good faith under these policies even if they turn out to be mistaken. We are committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our business or in any of its supply chains.
