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Modern Slavery Statement

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This statement is made on behalf of Newmarket Holidays Ltd, where we are committed to understanding all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our business and supply chains.

This statement relates to actions and activities during the financial year ending 31 March 2021


About Newmarket Holidays and our supply chains


Established in 1983, Newmarket Holidays Ltd is one of the UK's largest independently owned specialist tour operators, with our head office in Wallington, Surrey where it employs over 100 staff. With a commitment to offering great value for money wish-list holidays and exceptional customer service, we are a multi-award-winning tour operator. From Argentina to Zambia, and covering Italy, America, Spain, India, Uzbekistan and a host of other destinations in between, our holidays and tours offer our customers the chance to discover the world, staying in accommodation selected for its comfort and convenience, enjoying included and optional excursions, all accompanied by a tour manager.

As a business we contract and purchase wide variety of goods and services from suppliers within the UK and internationally – stationary, flight seats, cleaning services, accommodation, coach services, guide services and more. Some of these we use in our own business and others we use as part of the services we provide to our customers. The result being our supply chain is complex, with each supplier often having a supply chain of its own.

We operate holidays in the following countries:

UK plus Jersey, Isle of Man, Republic of Ireland, Italy, France, Iceland, Norway, Finland, Estonia, Latvia, Portugal, Spain, Netherlands, Switzerland, Austria, Slovakia, Russia, Georgia, Poland, Czech Republic, Hungary, Croatia, Slovenia, Serbia, Romania, Greece, Albania, North Macedonia, Malta, Republic of Cyprus, Turkey (incl. N. Cyprus), Israel, Jordan, USA, Canada, Cuba, Jamaica, Cayman Islands, Mexico, Japan, China, Thailand, Cambodia, Vietnam, Laos, Singapore, Malaysia, Uzbekistan, India, Nepal, Bhutan, Sri Lanka, South Africa, Namibia, Botswana, Zimbabwe, Zambia, Kenya, Mozambique, Egypt, Morocco, Costa Rica, Brazil, Argentina, Chile, Peru, Ecuador

Risk Assessment

Due to the varied nature of our holidays, we procure an equally wide variety of goods and services. We have already conducted a risk assessment process with existing suppliers and continue this practice with new suppliers to determine the likelihood of risk in each country and given the goods or service being procured. Countries are determined as high, medium, or low risk depending on data supplied by respected sources. Certain activities are at higher risk of slavery or human trafficking than others.

Due diligence

We undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers. Our due diligence and reviews include mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking; evaluating the modern slavery and human trafficking risks of each new supplier; reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping; any supplier identified as high risk is subject to further due diligence procedures, to further assess the level of risk and the steps required to monitor and manage that risk.

Policies, training and raising awareness

We are committed to working with integrity and transparency, as set out in our Core Values. We require our people to observe high standards of personal and professional honesty and integrity in all business dealings and circumstances.

Our policies and training describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations. Responsibility for our anti-slavery initiatives rest with all our employees, so our Whistleblowing and Modern Slavery policies are communicated to employees as part of our company induction process and with regular awareness reminders.

Our modern slavery training covers our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline; how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available; how to identify the signs of slavery and human trafficking; what initial steps should be taken if slavery or human trafficking is suspected; how to escalate potential slavery or human trafficking issues to the relevant parties within our organisation; what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative and additional training opportunities with ABTA, for example.

As well as training staff, we have raised awareness of modern slavery issues by putting up posters across our premises and circulating a series of emails to staff. The posters/emails explain to staff the basic principles of the Modern Slavery Act 2015 and how employers can identify and prevent slavery and human trafficking, what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation and what external help is available, for example through the Modern Slavery Helpline.

Performance indicators

We have reviewed our key performance indicators (KPIs). As a result, we require all staff to complete training on modern slavery – workshops/inductions. We have developed a system for supply chain verification which has been in place since 2016, whereby we evaluate potential suppliers before they enter the supply chain. We review our existing supply chain by re-evaluating all existing suppliers on an annual basis. We continually look to develop further KPIs to measure our effectiveness in seeking to ensure that slavery and human trafficking do not take place in our own business or in that of our suppliers.


As part of the travel industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking. We are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains or any other part of our business are free from slavery and human trafficking.

Board approval

This statement was approved on 6th April 2021 by our board of directors, who review and update it annually.
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