1. Introduction from The Board of Directors:
Reader Offers Limited ("ROL") is, and remains, fully committed to operating with integrity, honesty and in compliance with all relevant laws and regulations in the course of our business operations and or dealings. Accordingly, it continues to be a priority for ROL to ensure that we trade ethically and with social responsibility and persistently work to ensure we prevent modern slavery and human trafficking throughout our organisation and in our supply chain(s).
The UK Modern Slavery Act 2015 (the "Act") requires certain businesses to publicise the specific actions they have taken during the financial year to ensure modern slavery and or human trafficking is not taking place in their operations. The financial year ending 30 April 2025 is the first occasion upon which ROL acknowledges that it fully satisfies the legislative criterion of the Act, which now requires it to publicise this statement. Accordingly, this statement summarises the key activities, and positive steps, we have undertaken and are continuing to take to ensure that modern slavery and human trafficking does not take place within our supply chain(s) and or otherwise in any part of our business undertakings. It is provided pursuant to section 54, Part 6, of the Act. Our Board of Directors has reviewed and approved this statement.
Our commitment to our stakeholders is clear - we will always treat people in our business and supply chain(s) fairly and with respect. We have a zero-tolerance approach to modern slavery and human trafficking.
We recognise our responsibility to eradicate or otherwise minimise the risks of human trafficking, forced, bonded and child labour and to respect everyone's human rights in our respective operations and our supply chain(s). Thus, we seek to continuously review, audit and improve our practices to ensure that we have proper and effective measures implemented to identify and prevent any negative impacts that could potentially arise despite such risks being deemed to currently be very low.
2. Organisation's Structure & Business:
ROL (company number: '03036965') is a private limited company that was founded, and formally incorporated, on 23 March 1995 and commercially operates under the trading name of 'ROL Cruise'. The present trading company is a wholly owned subsidiary of ROL Cruise Holdings Limited, which has operated as an Employee-Owned Trust ("EOT") following its establishment by virtue of a deed dated 29 October 2024. Pursuant to this EOT structure, ROL is majority owned by a trust that holds shares for the benefit of its employees, providing them with a sense of ownership and financial stake. It precipitates improved employee engagement, retention and continuity, and in turn business performance.
ROL's principal activity has, and remains, to be as a leading global cruise specialist - both as agents and tour operators to the consumer market within the travel industry. ROL directly employs 142 members of staff and utilises 2 contractors. It is ATOL and ABTA protected, which affords our customers with financial protection and higher service standards
The Board of Directors are experienced in their respective industry, who collectively have a significant degree of perspective to the overall decision-making processes. The Board meet on a regular basis whereby they consider a range of short/long term risks and impacts for ROL, its employees, shareholders and other stakeholders that includes their supply chain network(s), the community and environment, and how these are effectively managed.
As part of that process, the Board of Directors considers its employees to be a primary stakeholder and has a strong focus on employee engagement, which promotes and further enhances business operations to the highest standards of conduct and governance to ensure any risks are identified, and promptly eradicated or otherwise minimised.
We also work closely and collaboratively with its service providers, which includes cruise lines, airline consolidators, transport services, and overall supply chain network.
3. Our Supply Chains & Adherence to Our Values:
We recognise that it is crucial for us as an organisation to have oversight of our supply chains so that we can understand the risks of modern slavery along the chain and take action to mitigate against those risks.
Due to the global nature of cruising, we contract with suppliers worldwide. Our suppliers predominantly include cruise ships, transport companies, accommodation providers as well as excursion providers.
However, we use our direct Tier 1 suppliers, who are carefully considered, assessed and selected, in order to manage any potential risks of modern slavery throughout the supply chain. In doing so, we clearly communicate the minimum requirements we have. To confirm, they are fundamentally well recognised and major PLC companies, who evidently identify and adopt the same ethos, and high expectations (combined with their very own reporting requirements), of honest and ethical business operations to eradicate or otherwise minimise the risk of modern slavery and or human trafficking.
Through our contracting process, we also ensure our expectations are inherently clear. By signing a contract with us, ROL openly 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 publishes a similar policy and or statement, then we carefully review the contents to ensure it aligns with our approach.
In such circumstances, we consider any such risks in our mainstream Tier 1 supply chains to be very low.
Nevertheless, we acknowledge that it involves multiple levels with differing complexities and within multiple jurisdictions. Thus, we continually engage with our procurement partners to ensure their continuous alignment with our ongoing ethical policies and zero tolerance approach. In addition, for the preceding 10 years we have ROL cruise ambassadors on board many voyages that assist with the identification and management of any risks of modern slavery.
4. Our people:
We have also conducted a periodical review of our overall employment practices (in respect of both directly employed individuals and appointed contractors), and we have not identified any working practices that raises any such concerns that our personnel are:
- Forced to work through mental or physical threat.
- Owned or controlled through mental or physical abuse or threat of abuse.
- De-humanised, treated as a commodity or bought and sold as property; and or
- Physically constrained or whose freedom of movement is restricted.
5. Our policies:
In addition to this statement, we also now have specific policies in place that underscore and underpin our ongoing commitment to ensure that there is no modern slavery or human trafficking in our supply chains or otherwise in any part of our business operations. We will periodically review and update all of our policies as appropriate.
In doing so, our Anti-slavery, Anti-Bribery & Corruption, Whistleblowing, and Anti-Tax Evasion, policies reflect (individually and collectively) our approach and ongoing commitment to acting ethically and with integrity in all our business relationships. Furthermore, it conveys our implementation and enforcement of effective systems and controls to ensure slavery and human trafficking is not taking place anywhere (directly or indirectly) in our supply chains or indeed any part of our business.
In particular, it sets out the following core principles:
- Child labour is not used.
- Employment rights are preserved and maintained.
- Discrimination will not be tolerated, under any circumstances, in any aspect of our business.
- Corruption or degrading treatment shall not be tolerated.
- Whistleblowers will be protected.
6. Training & Awareness:
We recognise that to be effective at preventing, and eradicating, modern slavery we need to raise and maintain awareness of this issue and the associated risks.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, we will now implement periodical training, as necessary, to our staff.
We confirm that at the time of publication all colleagues have received communications which provided them with a high-level overview of what is meant by modern slavery and human trafficking, the methods by which ROL looks to combat it and to re-iterate that our stance is of zero tolerance in regard to this matter.
7. Governance:
We have a clear governance process for dealing with modern slavery and human trafficking challenges that could arise in our operations and supply chains.
Assessing compliance with our Anti-Slavery policy (along with monitoring of the effectiveness of the controls within the business to mitigate the risks associated with compliance with laws, regulations and company policies) is undertaken by our Compliance Team (supported by the HR function) every 12 months.
8. Further Steps:
Following a review of the effectiveness of the steps we have taken to ensure there is no modern slavery or human trafficking in our supply chains we intend to take the following further steps to mitigate against any such risk:
• Continuing to ensure the effectiveness of the existing due diligence we undertake with our suppliers and (in turn) the effectiveness of our supplier's own due diligence procedures to ensure that no modern slavery is taking place further down the supply chain. This will involve us undertaking a supply chain mapping process to enhance our understanding of the differing levels and complexities in our supply chains across different jurisdictions.
• Continue a programme of communication, awareness and e-learning on legal and regulatory compliance matters relating to supply chains. This will include modern slavery and human trafficking, bribery and corruption and failure to prevent tax evasion.
• Communicate updated compliance policies to all UK employees.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending 30th April 2025.
This statement is approved by:
Name: Mel Childs
Position: Finance Director On behalf of ROL's Board of Directors
Dated: 29 October 2025
