Modern slavery and human trafficking statement

Financial year ended 2025

Dragonpass International Limited, is part of the Dragonpass Group (collectively “Dragonpass”), is committed to conducting its business ethically, transparently and with respect for human rights. We do not tolerate slavery, servitude, forced or compulsory labour, unlawful child labour or human trafficking in our business or supply chains. We recognise our responsibility to identify risks, take proportionate preventive action and respond appropriately when concerns arise.

This statement applies to Dragonpass International Limited, Dragonpass APAC Pte. Limited, Dragonpass Brazil LTDA, Dragonpass FZ-LLC and Dragonpass South Africa (Pty) Ltd. References to the wider Dragonpass Group provide business context only and do not extend the scope of this statement to entities not identified here. This statement is published voluntarily with reference to the transparency principles in section 54 of the UK Modern Slavery Act 2015.

Dragonpass works with a wide range of suppliers, service providers and business partners in support of its operations, including technology providers, outsourced service providers, recruitment and staffing channels, facilities and support services, and other third parties connected to the delivery of travel and lifestyle services. While we consider the direct risk of modern slavery within our own corporate operations to be relatively low, we recognise that risks may arise in broader supply chains, outsourced arrangements and labour-intensive service environments, particularly where services are delivered across multiple jurisdictions. This informs our risk-based approach to supplier oversight and due diligence.

We understand that modern slavery risk is not limited to traditional manufacturing environments and may also arise in labour-intensive services, subcontracting arrangements, temporary staffing models, recruitment channels and cross-border supplier relationships. We therefore seek to maintain appropriate oversight over our own operations and, where proportionate, over our supplier base.

We are committed to maintaining effective systems and controls to help identify and address the risk of modern slavery and human trafficking in our business and supply chains. We expect our employees, suppliers, contractors and business partners to uphold the same standards of integrity, lawful conduct and respect for human rights.

We do not knowingly work with any organisation or individual that is involved in slavery, servitude, forced or compulsory labour, child exploitation or human trafficking. Where such concerns are identified, we seek to investigate them appropriately and to take proportionate and appropriate remedial action.

Dragonpass has implemented governance measures designed to support ethical conduct and reduce the risk of modern slavery and human trafficking in our operations and supply chain. These measures form part of our broader compliance and risk management framework and are intended to promote responsible business conduct, accountability and effective escalation of concerns.

Our Anti-Slavery Policy prohibits forced, bonded or involuntary labour, unlawful child labour, exploitative recruitment, coercion, abuse and conduct that facilitates trafficking. It applies to employees, officers, contractors, consultants, temporary staff and persons acting on behalf of Dragonpass. Our Whistleblowing Policy supports confidential reporting and protection against retaliation.

These policies operate our Code of Conduct. Our approach is informed by internationally recognised human rights and labour principles, including relevant standards and principles. This policy also supports the ongoing review of our practices, internal escalation where concerns arise, and appropriate action where actual or suspected non-compliance is identified.

We expect suppliers to comply with applicable laws and regulations relating to labour standards, employment practices and anti-trafficking measures, and to at all times operate in a manner consistent with recognised ethical sourcing principles.

Our suppliers are expected to refrain from the use of forced, bonded or involuntary labour, to avoid child exploitation, to provide lawful and fair working conditions, and to maintain appropriate oversight over their own supply chains where relevant. We may also require certain suppliers to confirm compliance with our standards contractually or through due diligence processes from time to time.

Our Whistleblowing Policy provides a mechanism for employees and relevant stakeholders to raise concerns confidentially and, where appropriate, anonymously. This includes concerns relating to (but not limited to) unethical conduct, labour exploitation, suspected trafficking, forced labour and/or other human rights concerns that may arise in our business or supply chain.

We seek to ensure that concerns raised in good faith are taken seriously, reviewed appropriately and handled without retaliation. We believe that effective speak-out arrangements form an important part of preventing exploitation and identifying risks that may otherwise remain hidden.

We may suspend or terminate a relationship where serious harm cannot be adequately addressed, a supplier refuses to cooperate or continued engagement is unlawful. We consider the consequences of disengagement for affected workers.

We adopt a risk-based approach to due diligence and supply chain oversight. Depending on the nature of the supplier relationship, the services provided, and the level of identified risk, our processes may include supplier onboarding checks, contractual commitments, review of supplier conduct, escalation of red flags, and periodic reassessment of higher-risk relationships (as appropriate).

We recognise that the level of diligence required may vary from case to case according to factors such as geography, sector, the use of temporary or migrant labour, subcontracting chains, labour intensity and the availability of reliable visibility into working conditions. Where concerns are identified, we seek to engage appropriately with the relevant supplier or business partner and to consider remediation, enhanced monitoring or disengagement as necessary.