Virgin Cruises Intermediate Limited (“Virgin Voyages”) is a growing cruise line founded by Sir Richard Branson and the Virgin Group. At Virgin Voyages, our compass is set towards a future where people, planet, and purpose steer everything we do. As a growing cruise line with big dreams and strong ethical foundations, Virgin Voyages is committed to working to prevent, identify and eliminate modern slavery in our business operations and supply chain.

This statement, made in accordance with the UK Modern Slavery Act 2015, outlines the steps we've taken to prevent modern slavery within our operations and supply chain. It also highlights our ongoing commitment to continuous improvement. Our Board of Directors, with oversight from the Sustainability & Social Impact Committee, has reviewed and approved this statement.


OUR POLICIES

Proudly part of the Virgin family, we have a zero-tolerance position towards slavery and human trafficking in all forms. We have outlined expectations for ethical business conduct and upholding fair labor practices for Board Members, Virgin Voyages Crew Members, Partners, and Suppliers in relevant Codes for each audience, such as:
 

• Our Code of Business Conduct: This code clearly defines the expected ethical behavior for all Virgin Voyages employees and leaders, emphasizing compliance with all relevant laws.
• Our Supplier Code of Conduct: This code sets out our clear expectations for all our suppliers, requiring them to (among other things):
  • Abolish Hazardous Child Labor
  • Adopt policies and procedures that protect employees from inhumane treatment, harassment and abuse.
  • Follow fair labor practices and international labor standards (including ILO core conventions).
  • Provide their workers with training on modern slavery issues.
• Our Tour Operator Code of Conduct: This code outlines specific requirements for tour operators partnering with us, focusing on preventing exploitation and promoting fair labor practices.

These Codes clearly communicate our expectations and are regularly reviewed and updated.


UNDERSTANDING OUR SUPPLY CHAIN: RISKS AND OUR APPROACH

We're proud to collaborate with over 1,000 suppliers, from shipbuilders and crew recruitment agencies to food providers and local tour guides. While we consider the risk of modern slavery within our direct operations to be generally low, we recognize that complexity increases further down our supply chain. Therefore, we are particularly focused on areas such as manufacturing, food and retail sourcing, and tour operations, where the risk can be higher. We also actively engage with our procurement partners to ensure their alignment with our ethical labor policies and that they receive up-to-date Modern Slavery awareness training.


HOLDING OUR PARTNERS ACCOUNTABLE

Through our contracting process, we ensure our expectations are clear through Virgin Voyages’ Supplier Code of Conduct. By signing a contract with us, Virgin Voyages expects all industry partners to provide “training for appropriate workers on modern slavery issues and how to identify and respond in a timely and safe manner.” If a supplier already has a similar policy, we carefully review it to ensure it aligns with our policy.

In 2024, we enhanced our understanding of our supply chain:

• 75% of our suppliers, representing 53% of our annual spending, have signed our Supplier Code of Conduct or have an equivalent policy in place.
• We've identified 25 key suppliers who account for over 70% of our annual spending, and we're working closely with them to ensure full compliance.
• Only 3% of our spending is with UK-based suppliers, underscoring the importance of our global efforts.

We are also improving our systems to better track adherence to these commitments. Additionally, we are focusing special attention on suppliers operating in higher-risk countries as identified by the Global Slavery Index.


SITE VISITS & AUDITS: TRUST AND VERIFICATION

We believe in building trust, and we also believe in verifying that trust.

• All global recruitment agencies must hold MLC 2006 certification, confirmed through third-party audits.
• We conduct interviews with potential seafarers to ensure no recruitment fees or coercive practices are involved.
• We conduct site visits with partners to gain exposure to operations with key partners, which allow us to verify our standards are met.

In accordance with the Supplier Code of Conduct, should instances of human rights violations be identified through site visits or assessments, Virgin Voyages reserves the right to discontinue its contracts with its suppliers.


REPORTING

Virgin Voyages maintains a confidential, third-party ethics hotline for our crew and vendors to report violations of our Codes, or suspect non-compliance. Crew and vendors are encouraged to contact Virgin Voyages anonymously and confidentially through the third‐party platform, EthicsPoint. Reports may be made through the following methods:

📞 Call: (833) 620-6812 🌐 Visit: virginvoyages.ethicspoint.com


TRAINING & AWARENESS: EDUCATION AS PREVENTION

Education is crucial in preventing modern slavery.

In 2024, we continued the Modern Slavery Awareness Training for Tour Operators that we launched in 2023. This complimentary training, aligned with the Global Sustainable Tourism Council (GSTC) criteria, included content on fair labor practices.

• 30% of our Tour Operators completed the training.
• 212 tours in our global portfolio have been certified for meeting GSTC criteria.
  • In 2025, new operators will be required to complete this training to become a Supplier.

Additionally, in 2024, we began developing a Modern Slavery awareness and preventive action training for suppliers we deem to be at risk to experience instances of modern slavery, based on reports by human rights non-profit organizations and jurisdictions with Modern Slavery regulations. This training includes specific examples of how modern slavery could occur within key business areas and where risks are highest, including but not limited to:

• Talent Recruitment Agencies
• Manufacturing
• Food & Beverage
• Textiles & Hotel Supplies
• Tour Operators
• Retail
• IT & Electronics

TRACKING OUR PROGRESS: MEASURING OUR IMPACT

We've developed key performance indicators to measure the effectiveness of our risk management, partner training, and overall impact. We update our Modern Slavery Statement annually to reflect our learnings and achievements.

In 2024, we strengthened our collection of direct (tier one) supplier data and identified key areas for supplier engagement based on spending, geographical location, and relevant UK governance.

Moving forward we will continue to track this data to address any compliance gaps and increase the number of suppliers who confirm they have received training on this critical issue.

To learn more about our broader positive impact, please read our latest Impact Report available at virginvoyages.com/sustainability.


CONTACT US

For further information, or to obtain a signed copy of this document, please reach out to us at impact@virginvoyages.com.


Approved by:
Jordan Smith - Chair
Nominating, Environmental, Social & Governance Committee of the Board of Directors


Version: 2025