Virgin Voyages
Modern Slavery Statement
I. ABOUT US
Virgin Cruises Intermediate Limited (“Virgin Voyages”) is a growing cruise line founded by Sir Richard Branson and the Virgin Group. We officially launched our first revenue sailings in August 2021 with our first ship, Scarlet Lady. In 2022 and 2023, we added our lady ships, Valiant Lady and Resilient Lady respectively, to the fleet. Our fourth lady ship, Brilliant Lady, is expected to start commercial operation in 2025. Each ship has been manufactured by the Italian shipbuilder Fincantieri S.p.A..
Virgin Voyages offers itineraries to more than 100 destinations. We strive to provide a fun, safe, and inclusive experience for our passengers and crew.
We continue to actively promote our sailings to the United Kingdom market and therefore carry out sales and marketing activities, including seasonal operations at ports in the United Kingdom. For this reason, we are issuing a Modern Slavery Statement pursuant to the United Kingdom Modern Slavery Act of 2015. In accordance with the regulation, this statement addresses how we are managing the risks of modern slavery in our operations and supply chain.
This statement builds upon our initial statement from 2022 and highlights the actions we have taken in 2023 as we have continued to grow. We also outline areas for improvement as we look ahead. Our efforts reflect our strong commitment to ethical business practices, collaborative partnerships and sustainable tourism.
This statement has been reviewed by our Board of Directors and signed by the Chair of the Nominating, Environmental, Social & Governance Committee of the Board of Directors. A copy of the signed document can be requested at impact@virginvoyages.com.
II. OUR POLICIES
Virgin Voyages is committed to conducting business responsibly across our value chain. 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. These Codes include the Code of Business Conduct, the Supplier Code of Conduct, and the Tour Operator Code of Conduct. Our policies are revisited periodically and updated as necessary as we identify areas for improvement.
As a Virgin brand, we have a zero tolerance position towards slavery and human trafficking in all forms. Modern slavery is wholly incompatible with our ethics to uphold international fair labor standards, human rights, and the principles by which we conduct our business. Virgin Voyages is committed to working to prevent, identify and eliminate modern slavery in our business operations and supply chain.
III. OUR SUPPLY CHAIN
We continuously evaluate our sourcing practices to provide the best quality products. Our business partners and suppliers span across industry sectors and geographies related to the cruise travel and hospitality industries, including but not limited to the following: ship manufacturing; global crew recruitment partners; tour operators; travel agencies; hospitality services; food and beverage providers; retailers; and information technology companies. While we have determined that our direct operation is a low-risk industry for incidents of Human Trafficking due to port-state controls, and the required documentation to travel on cruise ships, we have a broad and complex supply chain that supports our business, and we understand that each industry sector has potential for modern slavery to occur, especially further down the supply chain.
a. Risk Assessment
We have conducted a risk analysis of our direct (tier one) suppliers. We have determined that most of our suppliers are low-risk for Modern Slavery incidents based either on their industry classification, or because they are located in a low-risk country (according to GlobalSlaveryIndex.org). We define “tier one” as a supplier who Virgin Voyages procures services or goods from directly.
In 2023, we issued a survey to our tier one suppliers to track which companies were taking some form of action to mitigate the risks of human trafficking in their supply chain. Actions included the adoption of the Virgin Voyages code of conduct, compliance with the UK Modern Slavery Act, or the implementation of a supplier training. Through these efforts we decided that additional follow-up was necessary for the following suppliers:
b. Vendor Engagement
Regardless of geography, industry type, or Virgin Voyages’ amount of spend, during the engagement process with a potential supplier, a copy of our Supplier Code of Conduct is provided to the vendor as part of our onboarding process. Through the Supplier Code of Conduct, 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.” Upon entering into a contract or signing a purchase order, the vendor becomes a supplier to Virgin Voyages, and their signature binds the supplier to our terms and conditions provided at https://www.virginvoyages.com/suppliers. By doing so, Virgin Voyages sets the expectation that third-party contractors treat their workers and employees “with dignity and respect, and in accordance with fundamental fair labor principles as recognized by the International Labor Organization core conventions on Labor Rights.” Additionally, their signature self-certifies their compliance with the Supplier Code of Conduct, unless a comparable code is provided and agreed to by Virgin Voyages. As previously stated, we are currently improving our tracking capabilities to identify where we do not have a signed Supplier Code of Conduct on file.
For suppliers who are key partners to Virgin Voyages and carry out procurement services on our behalf, we conduct periodic management reviews to ensure our procurement standards are embedded in their contracting processes. We are continuing to refine our management approach with these partners to ensure our requirements are understood and there are systems in place to educate our partners, assess risk, track concerns and monitor compliance.
c. Site Visits and Audits
Through contractual relationships, Virgin Voyages reserves the right to conduct site visits and supplier audits where it is deemed necessary.
For instance, we require that all of our contracted global recruitment agencies are International Labour Organization, Maritime Labour Convention (2006) (“MLC”) compliant. This is verified by an independent compliance certificate provided by an authorized third party. Virgin Voyages also conducts periodic interviews with recruitment candidates to ensure agency practices adhere to our requirements and uphold the MLC, which outlines the rights of seafarers and global standards for decent work. If violations are detected, such as requiring candidates to pay recruitment fees, the agency is immediately addressed and corrective actions are implemented.
We also contract with tour operators across various geographies and conduct site visits to ensure the operation is adhering to our operational standards and Virgin Voyages’ Tour Operator Code of Conduct, which includes upholding fair labor practices, such as the International Labour Organization (ILO) C138 Minimum Age Convention.
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.
Looking ahead, as we develop our Supplier Responsibility Program, we may require suppliers with a high-risk potential for human rights violations to complete self-assessments, third party assessments or conduct audits.
d. Reporting Hotline
Virgin Voyages requests employees or suppliers who have experienced violations of our Codes, or suspect non-compliance, to contact Virgin Voyages anonymously and confidentially through a third‐party platform called EthicsPoint. Reports may be made by calling (833) 620‐6812, or by visiting virginvoyages.ethicspoint.com.
IV. TRAINING
As a growing company that continues to adapt to the ever-changing landscape of the cruise industry, Virgin Voyages consistently seeks to also continue to identify areas where it can provide training and create awareness. By way of example, in 2023, Virgin Voyages rolled out a Sustainable Tourism Training Program to tour operators, which included a segment on human trafficking. Looking ahead, we will deliver a Modern Slavery Compliance Training for leaders in the business who are responsible for procurement and managing third- party partner relationships. This training may also include our third-party procurement partners.
V. PERFORMANCE MEASURES
As Virgin Voyages continues to grow, we will further develop and refine our modern slavery compliance strategy and develop performance indicators. Additionally, this statement and the results of our efforts will be updated each year. Additional information on our ethical business practices, partnerships and environmental, social, and governance commitments can be found in our annual Impact Report. A copy of this report can be found at www.virginvoyages.com/sustainability.
Approved by:
Jordan Smith - Chair
Nominating, Environmental, Social & Governance Committee of the Board of Directors
Version: 2024
Virgin Cruises Intermediate Limited (“Virgin Voyages”) is a growing cruise line founded by Sir Richard Branson and the Virgin Group. We officially launched our first revenue sailings in August 2021 with our first ship, Scarlet Lady. In 2022 and 2023, we added our lady ships, Valiant Lady and Resilient Lady respectively, to the fleet. Our fourth lady ship, Brilliant Lady, is expected to start commercial operation in 2025. Each ship has been manufactured by the Italian shipbuilder Fincantieri S.p.A..
Virgin Voyages offers itineraries to more than 100 destinations. We strive to provide a fun, safe, and inclusive experience for our passengers and crew.
We continue to actively promote our sailings to the United Kingdom market and therefore carry out sales and marketing activities, including seasonal operations at ports in the United Kingdom. For this reason, we are issuing a Modern Slavery Statement pursuant to the United Kingdom Modern Slavery Act of 2015. In accordance with the regulation, this statement addresses how we are managing the risks of modern slavery in our operations and supply chain.
This statement builds upon our initial statement from 2022 and highlights the actions we have taken in 2023 as we have continued to grow. We also outline areas for improvement as we look ahead. Our efforts reflect our strong commitment to ethical business practices, collaborative partnerships and sustainable tourism.
This statement has been reviewed by our Board of Directors and signed by the Chair of the Nominating, Environmental, Social & Governance Committee of the Board of Directors. A copy of the signed document can be requested at impact@virginvoyages.com.
II. OUR POLICIES
Virgin Voyages is committed to conducting business responsibly across our value chain. 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. These Codes include the Code of Business Conduct, the Supplier Code of Conduct, and the Tour Operator Code of Conduct. Our policies are revisited periodically and updated as necessary as we identify areas for improvement.
As a Virgin brand, we have a zero tolerance position towards slavery and human trafficking in all forms. Modern slavery is wholly incompatible with our ethics to uphold international fair labor standards, human rights, and the principles by which we conduct our business. Virgin Voyages is committed to working to prevent, identify and eliminate modern slavery in our business operations and supply chain.
III. OUR SUPPLY CHAIN
We continuously evaluate our sourcing practices to provide the best quality products. Our business partners and suppliers span across industry sectors and geographies related to the cruise travel and hospitality industries, including but not limited to the following: ship manufacturing; global crew recruitment partners; tour operators; travel agencies; hospitality services; food and beverage providers; retailers; and information technology companies. While we have determined that our direct operation is a low-risk industry for incidents of Human Trafficking due to port-state controls, and the required documentation to travel on cruise ships, we have a broad and complex supply chain that supports our business, and we understand that each industry sector has potential for modern slavery to occur, especially further down the supply chain.
a. Risk Assessment
We have conducted a risk analysis of our direct (tier one) suppliers. We have determined that most of our suppliers are low-risk for Modern Slavery incidents based either on their industry classification, or because they are located in a low-risk country (according to GlobalSlaveryIndex.org). We define “tier one” as a supplier who Virgin Voyages procures services or goods from directly.
In 2023, we issued a survey to our tier one suppliers to track which companies were taking some form of action to mitigate the risks of human trafficking in their supply chain. Actions included the adoption of the Virgin Voyages code of conduct, compliance with the UK Modern Slavery Act, or the implementation of a supplier training. Through these efforts we decided that additional follow-up was necessary for the following suppliers:
- Suppliers who have not signed our Supplier Code of Conduct. In 2024, we will engage with suppliers who have not signed our code of conduct to make sure they either sign our code or have a similar code in place for their business.
- Businesses who are tour operators. These companies deliver experiences on shore for our guests when we arrive at our destinations. The tours they offer are designed to highlight the local culture, food, and experiences that make each destination unique. Due to some of their operations taking place in countries with lower human-rights standards, they could have a higher risk for modern slavery instances, such as child labor, in their business operations. Based on these assessment findings, in 2023 we focused on training our tour operators on the risks of human trafficking in tourism, and how it is incompatible with Sustainable Tourism Standards.
- Strategic partners for retail and food and beverage procurement. Retail and food and beverage procurement is streamlined through two companies. However, these companies engage tier two and tier three suppliers who could be at a greater risk for human trafficking given their industry sector. As a result, in 2023, we reached out to the retail and food and beverage companies with whom we conduct business in order to better understand their current practices to prevent human trafficking in their supply chain. Our discussions with these companies regarding their practices remain ongoing in 2024.
b. Vendor Engagement
Regardless of geography, industry type, or Virgin Voyages’ amount of spend, during the engagement process with a potential supplier, a copy of our Supplier Code of Conduct is provided to the vendor as part of our onboarding process. Through the Supplier Code of Conduct, 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.” Upon entering into a contract or signing a purchase order, the vendor becomes a supplier to Virgin Voyages, and their signature binds the supplier to our terms and conditions provided at https://www.virginvoyages.com/suppliers. By doing so, Virgin Voyages sets the expectation that third-party contractors treat their workers and employees “with dignity and respect, and in accordance with fundamental fair labor principles as recognized by the International Labor Organization core conventions on Labor Rights.” Additionally, their signature self-certifies their compliance with the Supplier Code of Conduct, unless a comparable code is provided and agreed to by Virgin Voyages. As previously stated, we are currently improving our tracking capabilities to identify where we do not have a signed Supplier Code of Conduct on file.
For suppliers who are key partners to Virgin Voyages and carry out procurement services on our behalf, we conduct periodic management reviews to ensure our procurement standards are embedded in their contracting processes. We are continuing to refine our management approach with these partners to ensure our requirements are understood and there are systems in place to educate our partners, assess risk, track concerns and monitor compliance.
c. Site Visits and Audits
Through contractual relationships, Virgin Voyages reserves the right to conduct site visits and supplier audits where it is deemed necessary.
For instance, we require that all of our contracted global recruitment agencies are International Labour Organization, Maritime Labour Convention (2006) (“MLC”) compliant. This is verified by an independent compliance certificate provided by an authorized third party. Virgin Voyages also conducts periodic interviews with recruitment candidates to ensure agency practices adhere to our requirements and uphold the MLC, which outlines the rights of seafarers and global standards for decent work. If violations are detected, such as requiring candidates to pay recruitment fees, the agency is immediately addressed and corrective actions are implemented.
We also contract with tour operators across various geographies and conduct site visits to ensure the operation is adhering to our operational standards and Virgin Voyages’ Tour Operator Code of Conduct, which includes upholding fair labor practices, such as the International Labour Organization (ILO) C138 Minimum Age Convention.
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.
Looking ahead, as we develop our Supplier Responsibility Program, we may require suppliers with a high-risk potential for human rights violations to complete self-assessments, third party assessments or conduct audits.
d. Reporting Hotline
Virgin Voyages requests employees or suppliers who have experienced violations of our Codes, or suspect non-compliance, to contact Virgin Voyages anonymously and confidentially through a third‐party platform called EthicsPoint. Reports may be made by calling (833) 620‐6812, or by visiting virginvoyages.ethicspoint.com.
IV. TRAINING
As a growing company that continues to adapt to the ever-changing landscape of the cruise industry, Virgin Voyages consistently seeks to also continue to identify areas where it can provide training and create awareness. By way of example, in 2023, Virgin Voyages rolled out a Sustainable Tourism Training Program to tour operators, which included a segment on human trafficking. Looking ahead, we will deliver a Modern Slavery Compliance Training for leaders in the business who are responsible for procurement and managing third- party partner relationships. This training may also include our third-party procurement partners.
V. PERFORMANCE MEASURES
As Virgin Voyages continues to grow, we will further develop and refine our modern slavery compliance strategy and develop performance indicators. Additionally, this statement and the results of our efforts will be updated each year. Additional information on our ethical business practices, partnerships and environmental, social, and governance commitments can be found in our annual Impact Report. A copy of this report can be found at www.virginvoyages.com/sustainability.
Approved by:
Jordan Smith - Chair
Nominating, Environmental, Social & Governance Committee of the Board of Directors
Version: 2024
