Anti Slavery and Human Trafficking Policy

Modern slavery statement


This statement applies to Travel Innovation Group (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2020/2021.

Organisational structure

Travel Innovation Group includes the following companies:

  • Lime Management Limited
  • Aviate Management Limited
  • Calrom Limited
  • Calrom Management Limited
  • Lime Management (Australia) Limited
  • Calrom Pakistan (Private) Limited
  • Calrom USA Inc.

Our Head Office is in the United Kingdom.

The organisation is controlled by a Board of Directors.

We are a ticketing and servicing agent in the travel sector. We have over 200 employees operating in the following countries:

  • United Kingdom
  • Pakistan
  • Australia
  • Spain
  • USA


The Organisation considers that modern slavery encompasses:

  • · human trafficking
  • · forced work, through mental or physical threat
  • · being owned or controlled by an employer through mental or physical abuse of the threat of abuse
  • · being dehumanised, treated as a commodity or being bought or sold as property
  • · being physically constrained or to have restriction placed on freedom of movement.


The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in UK, Pakistan, Australia, USA & Spain, and in many cases exceeds those minimums in relation to its employees.

Supply chains

In order to fulfil its activities, the main supply chains of the Organisation include Tours Operators, Travel Agents, Airlines and office suppliers/ contractors.

Potential exposure

The Organisation considers its main exposure to the risk of slavery and human trafficking to exist in Pakistan because the provision of labour is in a country where protection against breaches of human rights may be limited.

In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited because we directly employee all the staff in our Pakistan office.

Impact of COVID-19

During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges for the Organisation, as it did for others across the nation.

The Organisation welcomes the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty.

Despite the permitted, delay, the Organisation remains in a position to publish its statement for the financial year 2020/2021 in line with the original publishing requirements.

The Organisation concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under ‘POTENTIAL EXPOSURE’ above.

During the pandemic, the Organisation’s employees still had access to the grievance procedure to raise any concerns that they may have had.

The Organisation’s modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.


The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

  • Reviewed our supplier contracts which would be terminated in the event that the supplier is, or is suspected, of being involved in modern slavery
  • Put measures in place to identify and assess the potential risks in our supply chain
  • Ensure all suppliers meet our ‘supply chain compliance standards’. The compliance team consists of HR, Finance, Sales & Procurement
  • Monitoring potential risk areas in our supply chain
  • Ensuring staff have access to the whistleblowing policy which sets out the process by which employees can report any concerns of wrong doingKey performance indicators

The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

  • Completion of audits by external provider
  • Use of labour monitoring and payroll systems; and
  • Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations


The Organisation has the following policy which further define its stance on modern slavery


Slavery Compliance Officer

The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.


Michael Edwards

Managing Director

July 2021