Human Rights Policy

1: Purpose

We are committed to respecting and supporting human rights across our operations and business relationships. This policy sets out our approach to identifying, preventing, and addressing potential human rights impacts in line with recognised international standards.

2: Our Commitment

We commit to operating in accordance with:

• The UN Guiding Principles on Business and Human Rights

• The International Bill of Human Rights, including the rights under the Universal Declaration of Human Rights

• The International Labour Organization (ILO) Core Conventions • Applicable UK employment law and local laws in the countries where we operate We will:

• Treat all individuals with dignity, fairness, and respect

• Prevent discrimination, harassment, and unfair treatment

• Provide safe and healthy working conditions

• Oppose all forms of forced labour, modern slavery, and child labour • Promote ethical business practices across our supply chain

3: Scope

This policy applies to:

• All employees

• Contractors and temporary workers

• Suppliers, partners, and third-party providers More broadly, this policy’s scope covers all individuals and communities affected by the company’s own operations and its value chain. We expect those we work with to uphold similar standards. Our Human Rights Risk Assessment sets out the salient issues identified, our prioritisation approach, and our preventative and remedial action plan.

4: Key Human Rights Risks in Our Business

We recognise that our industry presents specific human rights risks, particularly in: Supply Chain & Partners

• Limited visibility over working conditions in international travel & tourism partners

• Risk of modern slavery or unfair labour practices in accommodation, transport, and local providers Workers

• Ensuring fair treatment, equal opportunity and wellbeing of employees and contractors

• Maintaining safe working conditions Communities • Ensuring our operations and partnerships respect local communities and do not cause harm We take a proportionate, risk-based approach to managing these areas

5: Our Approach

5.1 Employment Practices

We are committed to:

• Fair and lawful pay and working conditions • Equal opportunities and non-discrimination

• Zero tolerance for harassment or bullying

• Supporting employee wellbeing and safety These commitments are supported by our internal HR policies and procedures.

5.2 Supply Chain Standards

We expect our suppliers and partners to:

• Comply with applicable labour laws

• Prohibit forced, bonded, or child labour

• Provide safe and fair working conditions

• Treat workers with dignity and respect We are working to strengthen our approach through:

• Supplier expectations (e.g. Code of Conduct)

• Incorporating relevant clauses into agreements

• Risk-based review of partners where appropriate

5.3 Risk Identification & Management

We take a proportionate approach to identifying and managing risks by:

• Reviewing areas of higher exposure within our supply chain

• Maintaining awareness of relevant industry risks (e.g. modern slavery)

• Integrating human rights considerations into operational decision-making

5.4 Grievance & Reporting

We encourage open communication and provide channels for concerns to be raised.

• Employees can raise concerns through internal processes, including management or HR

• Concerns can be escalated confidentially where needed

• We are committed to non-retaliation for anyone raising concerns in good faith We aim to extend appropriate reporting channels to third parties over time.

5.5 Driver Guide & Operator Safety

As a travel business operating with both in-house Driver Guides and third-party coach operators, we recognise that driver and operator welfare is a specific human rights risk area. We are committed to:

• Ensuring Driver Guides are not scheduled in ways that compromise safe driving hours or rest periods

• Maintaining health and safety procedures covering vehicle safety, incident reporting, and emergency preparedness

• Expecting third-party coach operators to demonstrate compliance with applicable driver hours regulations and vehicle maintenance standards

• Ensuring customer safety is considered in the planning and operation of all tours and excursions

5.6 Privacy & Data Protection

We recognise that the protection of personal data is a human rights matter. We are committed to handling customer and employee data responsibly and in compliance with applicable data protection law, including the UK GDPR. This includes the secure handling of sensitive information such as health or accessibility requirements and ensuring that any third-party booking or payment providers meet appropriate privacy standards.

5.7 Training & Awareness

We provide relevant training to ensure staff are equipped to uphold our human rights commitments. This includes training on health and safety, equality and inclusion, and how to raise or escalate concerns. Driver Guides receive specific training relevant to their role, including customer wellbeing and safe driving practices.

5.8 Remedy

In line with the third pillar of the UN Guiding Principles on Business and Human Rights, we are committed to remedy where human rights impacts are identified. Where issues arise - whether affecting employees, contractors, communities or those in our wider supply chain - we will investigate promptly, take appropriate action, and seek to address any harm caused.

5.9 Community & Destination Impact

We recognise that our operations have an impact on the communities and destinations we work in, and we are committed to giving back where we operate. Our approach includes:

• A self-managed carbon contribution applied to our operations, directing funds toward environmental and community benefit in the destinations where we operate

• Two paid volunteering days per year for all staff, supporting community initiatives in the areas where we operate We will continue to develop our approach to community engagement as our business grows.

6: Responsibilities

• CEO: Ultimate accountability for human rights performance; signs off this policy and any material updates; receives escalation of high-severity issues; leads annual review

• Head of People / HR: Responsibility for employment practices and internal policies

• Operations / Procurement: Managing relationships with suppliers and partners in line with this policy

• All Employees: Expected to act in accordance with this policy

7: Monitoring & Review

We will:

• Review this policy periodically

• Improve our processes as our business grows and our understanding of risk evolves

• Take appropriate action where issues are identified

8: Human Rights Due Diligence Process

We maintain an ongoing process to identify, assess, and respond to actual and potential negative human rights impacts across our operations and value chain. This process operates as follows.

8.1 How concerns are collected

All staff have a responsibility to report human rights concerns as they arise. Concerns may be identified through day-to-day operations, supplier interactions, customer feedback, or staff observations - for example, a Driver Guide noticing unsafe working conditions at a third-party operator, or a staff member raising a concern about a supplier’s practices. Concerns should be reported to a line manager or HR in the first instance. All concerns are logged so they can be tracked and reviewed.

8.2 Roles and responsibilities

HR and line managers are the first point of escalation for human rights concerns. They are responsible for receiving and logging concerns, conducting initial assessment, and determining appropriate action. High-severity issues - those scoring 3 on severity in our risk assessment matrix, or involving potential legal breach, serious harm, or modern slavery - are escalated immediately to executive leadership. Executive leadership retains overall accountability for human rights performance and reviews the risk assessment and mitigation plan at least annually.

8.3 How impacts are prioritised

Concerns are assessed using the likelihood and severity matrix set out in our Human Rights Risk Assessment. Severity is weighted as the primary factor: a low-likelihood but high-severity concern will be treated as a priority. Where a concern relates to a specific individual or community, we will seek to understand the impact from their perspective and involve them in the response where appropriate.

8.4 When we seek further information and what triggers a proactive review

Where a concern relates to a supplier or third-party partner, HR or the responsible line manager will follow up directly with that partner - requesting evidence of their practices or raising the concern in conversation - before the next booking or contract renewal. In addition, we will proactively review our human rights risks when any of the following occur: we begin operating in a new destination; we onboard a significant new supplier or partner; there is a material change in our operations or workforce; or a concern is raised through our grievance channel that suggests a systemic issue.