This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (UK) and constitutes the Modern Slavery Statement 2017.
This Statement is Intrepid Group’s second Modern Slavery Statement and should be read in conjunction with our previous Statement and our Global Human Rights Policy. Intrepid Group continues to be a strong supporter of ethical business conduct in our operations and supply chains and the international effort to abolish all forms of modern slavery. Below we describe the specific actions we have taken in the past calendar year and note our next steps on this topic planned for the calendar year ending 31 December 2019.
1. Summary of actions taken during fiscal year ending 31 December 2018
- Facilitated child protection training for key staff working in our operations, product, responsible business and not-for profit teams.
- ReThink Orphanages Australia, in partnership with Intrepid Group, won a silver award in the Best in Communicating Responsible Tourism category at the World Responsible Tourism Awards, in recognition of its commitment to child protection.
- Submission to the Parliamentary Inquiry into Establishing a Modern Slavery Act, in support of orphanage tourism and trafficking being considered a form of modern slavery in Australia’s Modern Slavery Act
2. Our business
Intrepid Group is the world’s largest provider of sustainable, experience-rich travel. Carrying over 430,000 passengers a year, our brands offer over 2,700 itineraries on every continent, catering for all ages, budgets and appetites for adventure.
As a responsible travel business, Intrepid Group is committed to:
- respecting the destinations, we operate in;
- supporting local people;
- preserving the environment;
- protecting the rights of the most vulnerable; and
- giving back to local communities.
With more than 2,100 employees, contractors and freelancers in 42 offices globally, we offer more than 2,700 diverse itineraries in 120-plus countries across every continent. As a vertically integrated business, we have operational offices called PEAK Destination Management Companies (PEAK DMC), which operate most of our itineraries. This enables us to manage our own operations and have greater oversight of our supply chain, as well as identify and mitigate risk areas of modern slavery and trafficking within our business.
3. Our supply chain
Our supply chains include various forms of capital (human, financial and physical), and goods and services. As an adventure travel company, our people (human capital) are our greatest assets. Financial capital enables us to grow our business, while physical capital includes our 42 offices. We require goods and services for our global offices (DMC, sales offices and virtual offices) and to support our customers on trips, including travel management, technical and personal protection equipment, office and IT equipment, facilities and maintenance providers as well as specialist support from subcontractors.
We acknowledge the challenges of respecting human rights throughout our supply chain and are committed to working with our suppliers and business partners to adopt and follow principles and standards like our own.
4. Risk management and due diligence processes
This Statement on Modern Slavery outlines the ways in which we work to prevent, identify and mitigate incidences of modern slavery, which encompasses forced labour and wage exploitation, involuntary servitude, debt bondage, human trafficking, forced marriage and other forms of exploitation.
Intrepid Group has implemented the COSO Enterprise Risk Management – Integrated Framework to manage its global risk. We use a multi-layered approach to the identification, management and mitigation of external and operational risks. Risk governance is led by Intrepid Group’s Board, who actively participate in the ‘top-down’ identification, assessment and acceptance of strategic risk.
Global Supplier Benchmarking
Our Destination Management Companies (DMC) track the quality, service and performance of existing suppliers. This allows us to evaluate suppliers regularly and identify and mitigate any issues related to compliance with our Supplier Code of Conduct.
We ask our customers to evaluate and provide feedback on their experience in travelling with us. This feedback is invaluable to our business. It is monitored regularly and allows us to action any identified issues.
Leader Trip Report
All our tour leaders must prepare a trip report within 48 hours of completing each tour, which is then sent to their manager. Included in this report is a section where a leader can document the practices of our suppliers (accommodation, transport providers, restaurants and other businesses), and is used as a mechanism for us to identify and mitigate any potential risks from within our supply chain.
5. Our Policies
The following policies and guidelines assist our staff and suppliers in ensuring we are operating responsibly and protecting human rights throughout our operations.
Intrepid Group Code of Conduct
We are committed to obeying the relevant laws governing operations in all countries and regions in which we do business. Intrepid Group Code of Conduct is intended to help staff in identifying and overcoming ethical and legal challenges in day-to-day working life, and to provide a basis for dealing with conflict.
Supplier Code of Conduct
PEAK DMC, as part of Intrepid Group, is committed to sustainable, ethical business practices that obey applicable laws, conventions and regulations. The Supplier Code of Conduct is designed to convey our expectations to our suppliers so they will support ethical practices and must be signed by all suppliers. All suppliers are expected to demonstrate that they:
- respect human rights and labour laws;
- support local communities;
- identify and monitor bribery and corruption risks;
- identify and monitor negative environmental impacts;
- introduce and maintain quality assurance policies and procedures; and
- introduce and maintain health and safety policies and procedures.
Leader and Crew Conduct Policy
This policy provides clear guidance to all leaders and crew operating Intrepid Group trips on conduct that is deemed inappropriate and would result in termination of their employment. This includes behavior that compromises the leader or crew’s duty of care to passengers, a failure to follow Intrepid Group’s core values, behaviour that breaches s local laws and other acts of misconduct.
Prevention of Bribery and Corruption Policy
Our company culture reflects the value we place in acting with integrity and being socially responsible. Accordingly, we are committed to conducting business fairly, openly and honestly. We inherently oppose bribery and corruption. We recognise that these inappropriate ways of doing business are evident in and are a cause of hardship and crime in several countries in which we operate.
Laws in several countries (UK Bribery Act 2010, US Foreign Corrupt Practices Act 1977, AU Criminal Code [Bribery of Foreign Officials] 1999) hold Intrepid Group’s companies, staff and suppliers accountable for preventing bribery and corruption anywhere in the world in which we do business. The Prevention of Bribery and Corruption Policy confirms our commitment to comply with these laws and outlines actions to be taken by all companies within Intrepid Group to achieve this aim.
Prevention of Discrimination, Bullying and Harassment Policy
The Prevention of Discrimination, Bullying and Harassment Policy confirms that Intrepid Group does not condone any form of discrimination, bullying or harassment in the workplace, and will act to stamp out any such behaviors reported to management or human resources. The policy outlines the rights, responsibilities and our expectations of all staff regarding preventing discrimination, bullying and harassment in order to create the workplace we all want. This policy applies to all employees, contractors, temporary staff, volunteers and visitors of all Intrepid Group companies.
Confidential Hotline Policy
The Confidential Hotline Policy provides individuals with a means to report any concerns regarding malpractice, wrongdoing or illegality to the company’s attention. The confidential nature of the hotline allows individuals to lodge a report without fear of reprisal or intimidation. Any concerns raised through the confidential hotline process is fully investigated and rectified where necessary. The Confidential Hotline Policy establishes the framework and procedures for this system.
This policy is applicable to all permanent and temporary employees of Intrepid Group companies. It also applies to freelance leaders and crew, external consultants, contractors and agency personnel while providing services to Intrepid Group companies.
Each year Intrepid Group spends a substantial sum of money purchasing goods and services in the countries we operate in. With this purchasing power comes responsibility. The purchasing decisions we make have a real impact, not only on our business but on the environments and communities in which we operate. The aim of the Purchasing Policy is to ensure that the impacts are positive, while still serving the operational needs of the business.
Responsible Travel Policy
Our Responsible Travel Policy outlines our key principles for travelling responsibly: to ensure that our operations respect local destinations, preserve the local environment, and protect wildlife and the rights of the most vulnerable, while also giving back to the places we travel. Our Responsible Travel policy and supporting guidelines are used as training tools for all our staff, including those in our offices as well as operational staff and leaders.
Global Porter Policy
Intrepid Group is committed to ensuring respectful and fair working conditions for all trekking porters. This policy was updated in 2018 to include specific local porter regulations at our PEAK DMC offices in Nepal, Peru and Kenya. We also introduced our Intrepid Group Kokoda Local Porter Regulation focusing on ensuring the fair treatment and welfare of our porters.
6. Our Next Steps for the fiscal year ending 31 December 2019
Develop and implement global slavery awareness training for all staff.
Maintain active involvement in industry forums and working groups to promote the elimination of slavery around the world.
Signed on behalf of the Board of Directors,
Chief Executive Officer, Intrepid Group
Signed: May 2019 for the financial year 2018 (1 January 2018 to 31 December 2018) for Intrepid Group.