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d-flo Limited

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that d-flo Limited has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain. We recognise that modern slavery is a crime and a violation of fundamental human rights. We are aware that modern slavery takes various forms, including slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain We fully support the UK government’s objectives to eradicate modern slavery and human trafficking. d-flo Limited has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Business

d-flo is a specialist travel technology company transforming how tour operators and cruise lines engage, inform and support travellers. Our intelligent communications solutions help travel businesses deliver more personalised experiences, strengthen customer relationships and proactively identify and manage disruption — protecting both travellers and brand reputation across the entire journey.

Our Policy

We recognise that modern slavery can occur in any industry and that particular risks can arise where workers are vulnerable to exploitation, including migrant workers, temporary workers and workers employed through labour providers or subcontractors. We will strongly uphold worker’s rights and will require all employment within our operations to be voluntary, with good working conditions, fair treatment and reasonable rates of pay.

This policy fully supports the following principles to ensure:

  • Freedom of employees to terminate employment.
  • We prohibit any threat of violence, harassment and intimidation.
  • We prohibit debt bondage and bonded labour.
  • We prohibit any disciplinary measure which includes an obligation to work.
  • We do not condone any compulsory overtime
  • We will not support the use of worker-paid recruitment fees.
  • Where modern slavery or exploitation is identified or suspected, our priority will be to protect and support affected individuals and, where appropriate, work with relevant authorities, specialist organisations and suppliers to provide or facilitate appropriate remedy. We will not knowingly take action that could increase the risk to an individual and will consider appropriate corrective action against suppliers where required.

Responsibility for implementing and reviewing this policy rests with the CEO, supported by the Operations Manager. They are responsible for ensuring that systems to prevent modern slavery are effective and this policy is annually reviewed.

Training and Awareness

We provide training and guidance to employees involved in procurement and supplier management, to help them identify signs of modern slavery and understand how to report concerns.

Reporting

We encourage all employees, contractors, and suppliers to report any concerns related to modern slavery. Reports can be made confidentially to privacy@dflo.co.uk. We will investigate all reports and ensure there is no retaliation against anyone who raises a concern in good faith.

Our Suppliers

Our suppliers are critical in our business success and are expected to comply with all local laws and regulations. Our supplier terms and conditions require suppliers to comply with applicable laws relating to modern slavery and human trafficking and to maintain appropriate labour standards.

We take a risk-based approach to ensure that there is no modern slavery or human trafficking in any of our operations or in our supply chain. We assess potential risks of modern slavery by reviewing factors such as the location of suppliers, the type of goods or services provided, and the degree of subcontracting involved.

Due diligence is conducted on all sub-contractors/suppliers before allowing them to become a preferred supplier. Our due diligence process includes reviewing suppliers’ own anti-slavery policies, requesting evidence of compliance (such as Modern Slavery statements), and verifying that appropriate labour standards are in place.

This modern slavery policy forms part of our contract with all suppliers and we monitor the effectiveness of our measures through periodic reviews of supplier risk assessments, audit results, and any incidents or reports received. Where a supplier is found to have inadequate controls or to be involved in practices associated with modern slavery, we will assess the circumstances and may require corrective action, enhanced monitoring or, where appropriate, suspend or terminate the supplier relationship.

Last updated: 12th October 2026.