Modern Slavery Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Travel eSIMple's Modern Slavery and Human Trafficking Statement for the financial year ending 31 December 2024.

Travel eSIMple is unequivocally opposed to all forms of modern slavery, forced labour, servitude, and human trafficking. We recognise that modern slavery is a serious crime and a fundamental violation of human rights. We are committed to acting ethically and with integrity in all our business dealings and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chains.

Modern slavery encompasses slavery, servitude, human trafficking, and forced labour. The Modern Slavery Act 2015 requires certain organisations to publish an annual statement setting out the steps they have taken during the financial year to ensure that slavery and human trafficking are not taking place in any of their supply chains or in any part of their own business.

Travel eSIMple is a UK-registered eSIM comparison and affiliate website operating at travelesimple.com. We provide consumers with independent comparisons of eSIM data plans for international travel, enabling users to identify and purchase the most suitable eSIM product for their destination and needs.

Our business model is primarily digital. We operate through our website platform, and our revenue is generated through affiliate commissions earned when users purchase eSIM plans from our partner providers, including Saily (operated by Nord Security) and 1Global. We do not manufacture any physical products, and our operations are predominantly conducted through digital channels.

As a digital services business, our direct workforce is small. We engage a limited number of contractors and freelance professionals in areas including web development, content creation, and digital marketing, all of whom are engaged through legitimate contracts and paid at fair market rates in compliance with applicable UK employment legislation.

Our supply chains are limited in scope given the digital nature of our business. Our principal supply chain relationships are:

• eSIM affiliate partners: Companies such as Saily and 1Global whose eSIM products are featured on our comparison platform. These are established technology companies operating in regulated telecommunications markets.
• Technology and SaaS providers: Hosting, analytics, and software-as-a-service providers, primarily based in the UK, EU, and United States, operating in regulated markets with established compliance frameworks.
• Professional services: Legal, accountancy, and other professional services engaged on an ad hoc basis, all UK-registered firms subject to professional regulation.
• Freelance contractors: Individual contractors engaged for website development, content writing, and design work, sourced from reputable platforms and engaged under written contracts.

We consider the risk of modern slavery within our direct supply chains to be low, given their predominantly digital nature and the regulated jurisdictions in which our principal partners operate. However, we recognise that vigilance is required even in lower-risk supply chains.

We maintain the following policies and commitments relevant to modern slavery and human trafficking:

• This Modern Slavery Statement: Published annually and reviewed for accuracy and completeness.
• Code of Ethics: Our Code of Ethics sets out our commitment to operating with integrity, which encompasses fair treatment of all individuals engaged in or affected by our business.
• Supplier Engagement: We communicate our expectations regarding ethical conduct, including in relation to modern slavery, to our principal suppliers and partners.
• Contractor Engagement: All contractors and freelancers are engaged under written agreements that confirm the legal basis for engagement and compliance with applicable employment law.
• Whistleblowing: We encourage anyone who becomes aware of modern slavery concerns within our business or supply chains to raise the matter without fear of retaliation, by contacting us at contact@travelesimple.com.

As part of our efforts to identify and address the risk of modern slavery, we undertake the following due diligence activities:

• Review of publicly available information on principal affiliate partners, including their own modern slavery statements and published ethical policies where applicable;
• Review of Companies House and equivalent corporate registrations for UK-based suppliers to confirm legitimate business status;
• Verification of right to work documentation for any individuals directly engaged in the UK;
• Preference for suppliers who themselves publish modern slavery statements and demonstrate a commitment to ethical practices.

We acknowledge that our due diligence processes are proportionate to the size and nature of our business. As we grow, we commit to enhancing these processes accordingly.

We have assessed the risk of modern slavery in our business and supply chains as low, for the following reasons:

• Our business operations are entirely digital and do not involve manufacturing, physical goods, or labour-intensive processes commonly associated with higher modern slavery risk;
• Our principal supplier relationships are with established technology companies operating in regulated telecommunications and digital markets;
• Our directly engaged workforce is small and engaged through transparent, legitimate arrangements in the UK and comparable jurisdictions;
• We do not source goods or services from high-risk geographical regions or sectors identified in the Global Slavery Index or Home Office guidance.

Notwithstanding this assessment, we remain alert to the possibility that modern slavery risk may arise, particularly in respect of contractors sourced through online platforms where visibility into working conditions may be limited.

We use the following indicators to monitor the effectiveness of our approach to modern slavery:

• Annual publication and review of this Modern Slavery Statement;
• Zero incidents of modern slavery identified in our business or direct supply chains during the reporting period;
• 100% of directly engaged workers are engaged under written contracts at or above the National Living Wage;
• All new principal supplier relationships reviewed for ethical standards prior to engagement.

During the financial year ending 31 December 2024, we are not aware of any instances of modern slavery or human trafficking in our business or supply chains.

We are committed to ensuring that those involved in our business understand the risks of modern slavery and know how to identify and respond to concerns. Our training approach includes:

• Providing key personnel with access to information and guidance on modern slavery indicators and reporting mechanisms;
• Incorporating modern slavery awareness into onboarding materials for new contractors and employees;
• Ensuring that individuals responsible for supplier engagement are aware of modern slavery risks in supply chains.

As our business grows, we are committed to expanding our training programme in line with the scale of our operations and supply chain complexity.

This statement has been approved by the board of directors (or equivalent governing body) of Travel eSIMple and will be reviewed and updated annually. It is signed on behalf of Travel eSIMple.

This statement covers the financial year ending 31 December 2024 and is published in accordance with section 54 of the Modern Slavery Act 2015.