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Travelport Technology Limited

Modern slavery statement for the financial year ended December 31, 2023

Modern slavery and human trafficking are significant global issues that present a challenge for businesses worldwide. Travelport is committed to supporting and respecting the principles set out in internationally proclaimed human rights. Travelport will not tolerate child and forced or compulsory labor where used by a business partner or at any point in the business partner’s supply chain.

Supporting policies

Our executive management team has established and maintains a strong ethical culture, overseen by our Board of Directors. Our policies and practices reflect corporate governance initiatives that are compliant with all relevant laws and regulations, both within Travelport and for our business partners. In 2021, we updated our Business Partner Conduct & Ethics Policy, and we will be reviewing our Code in 2024. Travelport’s Code of Business Conduct and Ethics and our Business Partner Conduct & Ethics Policy are available for all Travelport people, our business partners and the public to view.

We actively encourage our employees to report any misconduct or unethical behavior. Travelport and its businesses provide multiple avenues of reporting concerns, including the Travelport Integrity Line, which is operated by an independent third party and is monitored 24-7 and enables our people to report anonymously where permitted by law. In 2023, Travelport did not receive any complaints raising concerns about slavery, child labor or human trafficking.

Our Workforce

AAs a global travel retail platform, our main operations consist of providing technology products, and solutions. A substantial portion of our workforce consists of skilled labor. Given the nature of our business, Travelport assesses that there is a very low risk of slavery and human trafficking in our business and supply chains. Travelport also uses placement agencies to recruit skilled labor employees and outsourced service suppliers to provide talent. We expect our placement agencies and suppliers to be aware of good recruitment processes, including avoiding child labor, modern slavery and human trafficking. All Travelport employees and certain contractors must complete training on our Code of Business Conduct and Ethics, which covers modern slavery. We recently improved our talent onboarding process and increased the number of new joiners subject to background checks and right to work checks. Our current employees are screened against the key relevant sanctions and restricted party lists.

Supplier adherence to Travelport values

Travelport maintains external business partner policies that require its business partners to ensure that the employment of workers adheres to all applicable laws and regulations, to make every endeavor to be fully aware of human rights issues, such as human trafficking and slavery, and to conduct itself in a manner that will foster respect, dignity and equality for all. The Travelport Business Partner Conduct and Ethics policy, which was recently updated in 2023, can be found here.

Risk assessment

We have adopted a risk-based approach and started a rolling program of modern slavery risk assessments of our suppliers to better focus our activities. As a result, we have identified key business areas where employees may come into contact with resources working for suppliers and may come into contact with people affected by modern slavery and human trafficking. In addition to this we have strengthened our wording in relation to supplier contracts. Overall, our marketplace platform and solutions have a low risk of slavery and human trafficking in our business.

Training and due diligence

Mandatory online training is provided to all Travelport employees to assist them in recognizing the signs of modern slavery and human trafficking.

Travelport companies

Entities carrying on a business or part of a business in the UK, and having total turnover themselves above the threshold:

  • Travelport, LP (Delaware)
  • Travelport International Limited
  • Travelport International Operations Limited

Entities which are carrying on a business in the UK or are UK holding companies which in aggregate with their subsidiaries have turnover above the threshold:

  • Toro Private Holdings I, Ltd.
  • Toro Private Holding II, Ltd.
  • Toro Private Holdings III, Ltd.
  • Toro Private OpCo, Ltd.
  • Travelport International Management Limited
  • Travelport Operations Limited
  • Travelport Global Limited
  • Travelport Group Investments Limited

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It is Travelport’s slavery and human trafficking statement for the financial year ended December 31, 2023.

This statement has been approved by the Board of Directors and is verified as accurate by:

Signed: Greg Webb

Chief Executive Officer

May 15, 2024

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