Modern Slavery Statement

A) ORGANISATION This statement applies to DIRECT WAT (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 1 January 2022 to 31 December 2022 OR This statement applies to all companies within and associated to DIRECT WAY (referred to in this statement as ‘The Group’). The information included in the statement refers to the financial year 1 January 2020 to 1 December 2020. Direct Way is committed to the highest standards of professionalism, integrity, and ethics in conducting day to day business. We do not tolerate any form of slavery, human trafficking or forced labour in any part of the business and supply chain.B) ORGANISATIONAL STRUCTURE DIRECT WAY provides ground transportation services for corporate, private and VIP sectors, across the globe. Our mission is to serve all clients, with the highest of customer care and luxury chauffeured vehicles. The organisation works with a vast supply chain, such as affiliates, cleaning companies and facilities services, as well as professional services such as accountants. The headquarters is based in Brussels , but we have many partners and affiliates based in major cities around the world. These partners follow the organisations duty of care policies, and core values. The business has a structured Operations team, who liaise with the partners on a daily basis, ensuring continuity and fluid communication is made with all parties involved. The organisations sales and marketing team keeps the public audience up to date with all services available and supporting all clients with a solution to every day travel challenges.C) DEFINITIONS The organisation considers that modern slavery encompasses: Human trafficking. Forced work, through mental or physical threat. Being owned or controlled by an employer through mental or physical abuse of the threat of abuse. Being dehumanised, treated as a commodity or being bought or sold as property. Being physically constrained or to have restriction placed on freedom of movement.D) COMMITMENT The organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains. The organisation does not enter into business with any other organisation, in Belgium or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour. No labour provided to the organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the Belgium, UK, and major cities we service to. This is ensuring the supply chain, affiliates and partners in each country has policies and procedures in place that meet the organisations ethics and core values.E) SUPPLY CHAINS In order to fulfil its activities, the organisation’s main supply chains include those related to travel and the ground transportation sector. Working with partners and affiliates, through the organisations operations department following policies and procedures to achieve the desired results.F) POTENTIAL EXPOSURE The organisation considers its main exposure to the risk of slavery and human trafficking to exist in some countries, but we ensure our staff, chauffeurs and partners are all following the same procedures and ethics to deliver a credible service in industry. In general, the organisation considers its exposure to slavery/human trafficking to be minimal, nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.G) STEPS The organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers. The organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery. In accordance with section 54(4) of the Modern Slavery Act 2015, the organisation has taken the following steps to ensure that modern slavery is not taking place: Reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery. Duty of care policy and procedures in place. Chauffeur training and onboarding process. Measures in place to identify and assess the potential risks in its supply chains. Undertaking impact assessments of its services upon potential instances of slavery. Regular checks and review of contracts with strategic partners. Open speech policy for all members of staff, 1-2-1 meetings, red flag system.H) POLICIES The organisation has the following policies which further define its stance on modern slavery Duty of care policy. Organisational resilience policy. Staff and chauffeur policies.I) TRAINING The organisation provides training to staff to effectively implement its stance on modern slavery. This ranges from external training with the International Travel Management, and the Global Business Travel Association, to regular internal training for all members of staff.J) SLAVERY COMPLIANCE OFFICER The organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the organisation obligations in this regard. This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.