MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Introduction

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 UK Modern Slavery Act 2015 requires companies to explain on an annual basis the steps taken to prevent acts of modern slavery and human trafficking occurring in their businesses and supply chains. This statement sets out the steps we have taken during the financial year ending 31 January 2018, and builds upon the positive steps we took last year.

The following statement covers 01 February 2018 to 31 January 2019.

Modern Slavery Statement - July 2019

Introduction

At Destinology Limited (“Destinology”), we are committed to carrying on 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.

About Destinology

Destinology is a luxury outbound tour operator, offering tailor made travel arrangements for our customers based mainly in the UK. We cover destinations to six continents across the world from Europe to Australasia, featuring some of the best resorts, tours and cruises, all arranged by our dedicated sales team with a personalised service.

Destinology employs over 100 people who are largely based in Bolton, Lancashire, UK.

As a business we buy a wide range of things, from hotel bookings and airline seats, to cruises and fly drive tours, as well as day to day operational items from key suppliers. 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, Destinology complies with, and is subject to, all policies and processes that Saga plc has in place. Destinology’s employees have to complete the same mandatory training as Saga employees. In addition, Destinology is included within Saga’s wider audit and compliance 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 Destinology 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 01 February 2018 to 31 January 2019.

Debbie Windle

Managing Director

July 2019


1. Introduction

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 occurring in their businesses and supply chains. This statement includes the steps we have taken during the financial year ending 31 January 2019 and builds upon the positive steps we have taken in previous years.

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 members and other 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 4,800 employees, all of whom strive to see the world through our customers’ eyes, so that we can exceed their expectations. 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

As noted in last year’s statement, our holidays and cruises operations carry a potentially higher modern slavery risk due to the vast number of locations in which we procure goods and services.

Having previously implemented a risk assessment process in respect of all our current suppliers across the Saga Group to identify potentially high-risk suppliers, in 2018 we took the decision to re-examine the risk assessment process to ensure it was as robust as possible. Focusing on our higher risk areas, this included putting our Travel suppliers through the risk assessment process a second time for assurance and we intend to repeat this process for all other existing suppliers over the next financial year.

The risk assessment process also applies to new suppliers and it is our policy to require new suppliers to be risk assessed before operating with them.

4. Due Diligence Questionnaires

Our due diligence questionnaire is distributed to our Travel suppliers that are identified as high-risk and completed via a web portal operated by our Travel Customer Health and Safety department. Given a vast majority of our non-Travel related operations (principally in the financial services sector) have previously been assessed as low risk, a manual procedure is in place to provide non-Travel related suppliers with a due diligence questionnaire should one be required.

Following feedback from suppliers, in 2018 further amends were made to our due diligence questionnaire, principally to ensure the questions can be easily interpreted in the multiple jurisdictions in which we operate.

Following this, the revised questionnaire was distributed to all Travel suppliers identified as high-risk in the risk assessment process as noted above. This was achieved prior to our deadline of 31 January 2019. Further, procedures are now in place to ensure our Customer Health and Safety team is notified of any new supplier that has been identified as needing to complete a due diligence questionnaire following completion of the risk assessment process.

The system used by our Customer Health and Safety team sets realistic timeframes for suppliers to respond with a limited number of automated reminders if a response has not been forthcoming.

We remain committed to working with our suppliers to ensure business is conducted ethically and honestly. Therefore, our Customer Health and Safety team together with Product Managers have been working with those suppliers who have failed our due diligence questionnaire which has involved first checking that suppliers have understood the questions and answered them correctly. If suppliers have understood correctly and still failed the questionnaire, our Customer Health and Safety team and Product Managers have been working with them to implement a corrective action plan to rectify areas of non-compliance. This is 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. Travelife

As mentioned in our statement last year, in respect of our Travel operations, we have continued to strongly encourage hotel suppliers to apply for membership with the independent sustainability audit programme, ‘Travelife’, and to work towards obtaining Gold certification which demonstrates compliance with international standards on human rights. We aim to continue to increase our portfolio of GOLD membership hotels and will proudly state in our brochures which hotels have this certification.

6. 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 members, 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 Whistleblowing Policy, therefore, includes reference to modern slavery and to ensure all employees can continue to confidentially and anonymously raise concerns and report suspected violations via our whistleblowing telephone facility.

The Whistleblowing Policy is communicated to employees as part of the corporate induction process and, in addition, they are regularly reminded of the whistleblowing telephone number via internal communications.

Our Anti-Slavery & Anti-Human Trafficking Policy is also communicated regularly throughout our organisation. It is reviewed annually and also requires approval from the Saga plc Board on an annual basis.

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.

In line with our Anti-Slavery & 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 Modern Slavery 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 Modern Slavery Act. We have therefore developed and implemented into our template agreements, specific contractual clauses covering these points.

We have continued to distribute training material to employees through our e-learning platform to ensure a consistent, high level 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. By 31st January 2019, 98.2% of Saga employees had completed the e-learning training. We will endeavor to increase this percent year on year.

7. Auditing & Ongoing Compliance

Our Internal Audit procedures incorporate an assessment of our modern slavery processes within all relevant audits.

We remain keen to further develop key performance indicators in order to measure our effectiveness in seeking 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 further appropriate performance indicators.

8. Summary

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
  • Protect whistle-blowers

We will continually review and refine these processes to strive to operate to the highest standards at all times.

This statement covers 01 February 2018 to 31 January 2019 and has been approved by the Board of Saga plc.

Lance Batchelor

Chief Executive Officer

July 2019


Download 2019 statement as PDF here

Appendix 1 - Subsidiaries*

1. Saga plc
10. CHMC Limited
19. PEC Services Limited
2. Saga Mid-Co Limited
11. Saga Group Limited
20. Saga Membership Limited
3. Saga Holdings Limited
12. Saga Publishing Limited
21. Driveline Group Limited
4. Saga 200 Limited
13. Metromail Limited
22. Saga Cruises Limited
5. Saga 400 Limited
14. Saga Personal Finance Limited
23. Enbrook Cruises Limited
6. Acromas Insurance Company Limited
15. Saga Investment Services Limited
24. Saga Cruises IV Limited
7. Saga Properties Limited
16. Saga Services Limited
25. Saga Cruises V Limited
8. Saga Leisure Limited
17. Saga Healthcare Limited
26. Saga Cruises VI Limited
9. CHMC Holdings Limited
18. Saga Retirement Villages Limited
27. Saga Cruises GmbH

Travel Companies

28. ST&H Group Limited
30. ST&H Transport Limited
32. Titan Travel Holdings Limited
29. ST&H Limited
31. Titan Transport Limited
33. Destinology Limited

* Please note the above list does not include dormant companies.

The following statement covers 01 February 2017 to 31 January 2018.

Modern Slavery Statement - July 2018

About Destinology

Destinology is a luxury outbound tour operator, offering tailor made travel arrangements for our customers based mainly in the UK. We cover destinations to six continents across the world from Europe to Australasia, featuring some of the best resorts, tours and cruises, all arranged by our dedicated sales team with a personalised service.

Destinology employs over 100 people who are largely based in Bolton, Lancashire, UK.

As a business we buy a wide range of things, from hotel bookings and airline seats, to cruises and fly drive tours, as well as day to day operational items from key suppliers. 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, Destinology complies with, and is subject to, all policies and processes that Saga plc has in place. Destinology’s employees have to complete the same mandatory training as Saga employees. In addition, Destinology is included within Saga’s wider audit and compliance 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 Destinology 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.

Debbie Windle

Managing Director

July 2018


1. Introduction

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 (together, “we”, “us”, “our”) pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”). The UK Modern Slavery Act 2015 requires companies to explain on an annual basis the steps taken to prevent acts of modern slavery and human trafficking occurring in their businesses and supply chains. This statement sets out the steps we have taken during the financial year ending 31 January 2018, and builds upon the positive steps we took last year.

2. Risk Assessment - Update

Last year we identified our holidays and cruises operations as carrying a potentially higher modern slavery risk due to the vast number of locations in which we procure goods and services. As such, this year we have successfully implemented a risk assessment process in respect of our current suppliers, resulting in the identification of potential high-risk suppliers. We have adopted a similar risk assessment process for the onboarding of new suppliers too, and it is this process that informs whether or not a supplier is subject to further assessment via our due diligence questionnaire.

3. Due Diligence - Update

Our due diligence questionnaire, which was developed last year, has now been successfully incorporated into the processes and procedures of our holidays and cruises operations via our Customer Health and Safety department. The due diligence questionnaire was distributed to a random sample of potential high-risk suppliers in order to assess the smoothness and efficiency of the automated process, and the level of engagement of our suppliers – all of which was deemed a success. This was achieved prior to our deadline of 31 January 2018.

Following feedback from a pilot study, we are currently making minor amendments to the due diligence questionnaire process, with the intention of rolling this out to all potential high-risk suppliers over the course of 2018.

We remain committed to working with our suppliers to ensure business is conducted ethically and honestly. Therefore, should a supplier fail our due diligence questionnaire, we will work with them to implement a corrective action plan to rectify areas of non-compliance. Should a supplier continually disregard our proposed plan, or demonstrate little progress despite realistic time frames being agreed and set, we will consider our future relationship with that supplier.

We continue to strongly encourage hotel suppliers to apply for membership with the independent sustainability audit programme, ‘Travelife’, and also to continue to work towards obtaining Gold certification which demonstrates compliance with international standards on human rights.

4. Policies & Training

Both our Anti-Slavery & Anti-Human Trafficking Policy and our Whistleblowing Policy are communicated throughout our organisation regularly, and are used as the basis for our employees to be able to detect and prevent acts of modern slavery. These policies are also now part of our corporate induction process for new employees.

In addition, we have created and distributed training material for delivery to all employees through our e-learning platform to ensure a consistent, high level of awareness and understanding is achieved. By 31 January 2019, we aim for all employees to have completed this training.

5. Summary

We now have the following 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
  • Protect whistle-blowers

We will continually review and refine these processes to strive to operate to the highest standards at all times.

This statement covers 01 February 2017 to 31 January 2018 and has been approved by the Board of Saga plc.

Lance Batchelor

Chief Executive Officer

July 2018


Download 2018 statement as PDF here

Appendix 1 - Subsidiaries*

1. Saga plc
12. Saga Publishing Limited
23. Driveline Group Limited
2. Saga Mid- Co Limited
13. Metromail Limited
24. ST&H Transport Limited
3. Saga Holdings Limited
14. Saga Personal Finance Limited
25. Titan Transport Limited
4. Saga 200 Limited
15. Saga Investment Services Limited
26. Titan Travel Holdings Limited
5. Saga 400 Limited
16. Saga Services Limited
27. Destinology Limited
6. Acromas Insurance Company Limited
17. Saga Healthcare Limited
28. Saga Cruises Limited
7. Saga Properties Limited
18. Saga Retirement Villages Limited
29. Enbrook Cruises Limited
8. Saga Leisure Limited
19. PEC Services Limited
30. Saga Cruises IV Limited
9. CHMC Holdings Limited
20. Saga Membership Limited
31. Saga Cruises V Limited
10. CHMC Limited
21. ST&H Group Limited
32. Saga Cruises VI Limited
11. Saga Group Limited
22. ST&H Limited
33. Saga Cruises GmbH

* Please note the above list does not include dormant companies.

The following statement covers 01 February 2016 to 31 January 2017.

Modern Slavery Statement 2017

About Destinology

Destinology is a luxury outbound tour operator, offering tailor made travel arrangements for our customers based mainly in the UK. We cover destinations to six continents across the world from Europe to Australasia, featuring some of the best resorts, tours and cruises, all arranged by our dedicated sales team with a personalised service.

Destinology employs over 100 people who are largely based in Bolton, Lancashire, UK.

As a business we buy a wide range of things, from hotel bookings and airline seats, to cruises and fly drive tours, as well as day to day operational items from key suppliers. 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, Destinology complies with, and is subject to, all policies and processes that Saga plc has in place. Destinology’s employees have to complete the same mandatory training as Saga employees. In addition, Destinology is included within Saga’s wider audit and compliance 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 Destinology 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.

Mal Barritt

Managing Director

July 2017


Modern Slavery Act 2015

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 (together, “we”, “us”, “our”) pursuant to section 54(1) of the Modern Slavery Act2015 (the “Act”). This statement sets out the steps we have taken to prevent acts of modern slavery and human trafficking occurring in our business and supply chains during the financial year ending 31 January 2017.

1. Introduction

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 are 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 any of our supply chains.

We are also committed to ensuring transparency in our business and in our approach to tackling slavery and human trafficking throughout oursupply chains, consistent with our disclosure obligations under the Act. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we have developed and started to implement specific contractual clauses to prohibit the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect our suppliers to hold their own suppliers to the same high standards.

2. About the Saga Group

We provide products and services predominately tailored to members and other 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 4,800 employees, all of whom strive to see the world through our customers’ eyes, so that we can exceed their expectations. Our ‘Saga’ brand has been developed over the past 67 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 largeand complex, with each supplier often having its own supply chain.

3. Risk Assessment

We have devised a risk assessment process that contains various human rights indices. This has been implemented for existing suppliers in order to analyse and evaluate their risk profiles and we shall do likewise for future suppliers. For example, suppliers may present a higher risk of slavery and human trafficking due to the location in which they provide goods or services or because of the type of goods or services they provide.

Conducting this risk assessment has helped us better understand the areas of our operations most at risk of abuses relating to modern slavery, and accordingly has enabled us to focus our efforts to ensure effective due diligence is conducted to mitigate such risks.We have found the highest potential risks are within our holidays and cruises operations, largely due to the vast number of locations in which we procure services.

4. Due Diligence

We have developed a modern slavery due diligence questionnaire that is to be issued to higher risk existing suppliers as identified by the risk assessment. Once completed, the questionnaire will provide us with greater detail about our suppliers’ workforce profiles, workplace management and supplier management, along with answers to probing questions concerning the potential risk of forced and child labour within the suppliers’ operations.

We are committed to working with our suppliers to ensure business is conducted ethically and with integrity. This is an iterative process whereby any shortcomings are addressed by a corrective action plan and a timeline for completion.

The implementation process for this questionnaire is in its final stages. The questionnaire will be fully integrated within our procurement process by the next financial year end, 31 January 2018.

Our holiday companies are members of Travelife, an independent sustainability audit programme for tourism businesses. The human rights questions within our modern slavery due diligence questionnaire are based on those set by Travelife to prospective customers. We strongly encourage and support our hotels to achieve the Travelife Gold standard, which demonstrates compliance with leading international standards in areas including labour practices and human rights.

5. Our Policies

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 members, 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. We have, therefore, updated our Whistleblowing Policy to include reference to modern slavery and to ensure all employees can continue to confidentially and anonymously raise concerns and report suspected violations via our whistleblowing telephone facility.

The Whistleblowing Policy is communicated to employees twice annually and, in addition, they are regularly reminded of the whistleblowing telephone number via internal communications.

We have also formulated an Anti-Slavery & Anti-Human Trafficking Policyand this was approved by the Saga plc Board in May 2017.

This policy will be reviewed and communicated annually to ensure it remains current and reflects best practice.

6. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and our supply chains, we will be providing training to our employees via our e-Learning centre. This will be completed by the end of the next financial year, 31 January 2018.

7. Auditing & Ongoing Compliance

Following the introduction of the new anti-slavery and anti-human trafficking processes, our Internal Audit procedures have been amended to incorporate an assessment of these new processes within all relevant audits. Furthermore, our Group Compliance has also been engaged to assess our ongoing compliance with these processes.

We remain keen to develop key performance indicators in order to measure our effectiveness in seeking to ensure slavery and human trafficking do not take place anywhere in our own business or in any of our supply chains. As our new processesevolve, appropriate performance indicators will be identified and monitored.

8. Summary

We now have the following 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
  • Protect whistle-blowers

We will continually review and refine these processes to strive to operate to the highest standards at all times.

This statement covers 01 February 2016 to 31 January 2017 and has been approved by the Board of Saga plc.

Lance Batchelor

Chief Executive Officer

July 2017


Download 2017 statement as PDF here