Introduction
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “MSA”) and constitutes the slavery and human trafficking statement of Alternative Airlines Limited (“the Company”, “we”, “our”) in respect of our financial year ending 31 October 2025. This statement has been approved by the company Directors.
Alternative Airlines is committed to acting ethically and with integrity in all our business dealings and relationships. Our approach to preventing modern slavery and human trafficking is grounded in our company values: Less but better, Race to the future, Everything matters, and Never stop caring.
These values guide how we make decisions, treat people and partners, and continuously improve our practices to identify, prevent and mitigate the risk of modern slavery within our operations and supply chains, in line with the expectations of the Modern Slavery Act 2015 and Home Office guidance.
We are equally committed to creating and maintaining an inclusive, respectful and safe working environment for all employees. We want all staff and stakeholders to feel confident that concerns can be raised without fear of retaliation, victimisation or disadvantage.
Our Values in Action
Our response to modern slavery is guided by our company values, which shape how we translate policy into practice:
Less but better – We focus on proportionate, meaningful actions that reduce risk in practice, rather than relying on excessive or purely administrative processes.
Race to the future – We recognise that addressing modern slavery is an evolving challenge and commit to strengthening our approach year on year, particularly as our business and supply chain develop.
Everything matters – We pay close attention to detail in recruitment, supplier onboarding and governance, recognising that small oversights can create risk.
Never stop caring – We prioritise respect, fairness and wellbeing for our people and those we work with, and foster a culture where concerns can be raised safely and taken seriously.
Organisation Structure
Alternative Airlines Limited is a global flight search and booking platform providing customers with a quick, easy and personalised way to book flights online, supported by an expert Customer Service team. We offer access to 600+ global airlines, including major international carriers and smaller regional airlines, supported by proprietary technology designed to increase choice and flexibility for customers.
As at January 2026, the Company employs over 110 people across more than 10 nationalities, with its principal office located in the United Kingdom. We operate a flexible working model that allows employees to work when and where they feel most productive, supporting wellbeing, inclusion and retention across the organisation.
Supply Chains
Our assessment and management of supply chain risk reflects Home Office guidance, which encourages organisations to focus on proportionality, transparency and continuous improvement, particularly where overall risk is assessed as low but not negligible. Due to the nature of our business, we assess the overall risk of modern slavery within our operations and supply chains to be low. However, we recognise that modern slavery can occur in any sector and geography. We therefore remain vigilant and committed to continuous improvement, particularly where we can use our influence to drive positive standards.
Our key supply chain partners include:
- Global airlines
- Global ancillary service providers
- Global Distribution System (GDS) providers
- Payment technology platforms
- Software and technology providers (including HR, finance and marketing platforms)
- Office services (including stationery and cleaning services)
- IT equipment suppliers and maintenance providers
- Professional services
Policies
We maintain a suite of policies and procedures designed to support our commitment to preventing modern slavery and human trafficking, including:
- Modern Slavery Policy
- Employee Handbook
- Bullying and Harassment Policy
- Public Interest Disclosure (Whistleblowing) Policy
These policies apply to all employees, directors, officers, interns, contractors, agents, consultants and relevant third-party representatives.
Due Diligence Processes
Our due diligence approach is designed to be proportionate to our size, sector and risk profile, in line with Home Office guidance. We prioritise meaningful actions over excessive process, focusing on areas where we can have the greatest impact. Our recruitment processes are transparent and fair. We communicate directly with candidates regarding job opportunities and employment terms. Where recruitment agencies are used, they are expected to comply with our Modern Slavery Policy, and all recruitment-related fees are paid by Alternative Airlines.
We carry out appropriate identity and right-to-work checks for all employees and ensure that employment terms are clearly documented. All employees are protected by the policies and procedures set out in the Employee Handbook to ensure fair treatment and equal opportunity.During the 2025 financial year, we strengthened our approach to supply chain due diligence by implementing a supplier onboarding process that incorporates consideration of modern slavery risk. Relevant suppliers are required to acknowledge and align with our Modern Slavery Policy, providing a clearer baseline of expectations and accountability.
We maintain clear reporting and escalation processes for any employee or third party who suspects or becomes aware of a potential breach of our policies. All reports are taken seriously and investigated promptly and proportionately.
Breaches of our Modern Slavery Policy may result in disciplinary action for employees or termination of business relationships with suppliers or partners.
Awareness and Proportionate Capability Building
We take a proportionate and risk-based approach to building awareness of modern slavery and human trafficking, aligned with our values and the nature of our business. Rather than delivering mandatory, standalone training, we focus on ensuring that relevant policies, expectations and reporting routes are clearly communicated and understood by management and those involved in recruitment, supplier relationships and operational decision-making. This approach reflects our commitment to Less but better, prioritising meaningful understanding and accountability over tick-box activity.
We keep our approach under review and will assess the need for more formal or structured training should our risk profile, operating model or supply chain change in the future. This future-focused assessment supports our commitment to Race to the future, ensuring our controls evolve in line with the business. Awareness of modern slavery risks is also reinforced through internal communications and policy updates.
Key Performance Indicators and Ongoing Improvement
In line with Home Office guidance, we focus on transparency, accountability and continuous improvement rather than a purely compliance-driven approach. Our values underpin how we set, review and evolve our actions year on year. Our key performance indicators and commitments, which are reviewed by senior management and support effective oversight, include:
- Ongoing review and enhancement of supplier due diligence processes
- Delivery of regular modern slavery awareness training for management
- Quarterly review by the management team of any reported concerns relating to modern slavery
- within the business or supply chain
- Annual review of this statement to ensure it remains accurate and effective
Approval
This statement was approved by the Board of Directors of Alternative Airlines Limited and signed on its behalf.
Signed:
Samuel Argyle
Director
January 2026