Virgin Voyages

Modern Slavery Statement

   I. ABOUT US

Virgin Cruises Intermediate Limited (“Virgin Voyages”) is a growing cruise line founded by Sir Richard Branson and the Virgin Group. We officially launched our first revenue sailings in August 2021 with our first ship, Scarlet Lady. In 2022, we added our second ship, Valiant Lady, to the operating fleet and announced the expected delivery of two more ships, Resilient Lady and Brilliant Lady, entering into service in 2023 and 2024 respectively. Each ship has been manufactured by the Italian shipbuilder, Fincantieri.

Departing from Miami and Barcelona – and soon to include Athens, San Juan and Melbourne in 2023 – Virgin Voyages offers itineraries to more than 100 destinations across four continents. We strive to provide a fun, safe, and inclusive experience for our passengers and crew.

We actively promote our sailings to the United Kingdom market and therefore carry out sales and marketing activities, including seasonal operations at ports in the United Kingdom. For this reason, we are issuing this Modern Slavery Statement pursuant to the United Kingdom Modern Slavery Act of 2015. In accordance with the regulation, this statement addresses how we are managing the risks of modern slavery in our operations and supply chain for the financial year ending December 31, 2022. This statement has been reviewed by our Board of Directors and signed by the Chair of the Nominating, Environmental, Social & Governance Committee of the Board of Directors. A copy of the signed document can be requested at impact@virginvoyages.com.

This statement is an initial step to addressing Modern Slavery and we will continue to build upon our plans as our organization grows. In addition to the actions we have taken to date, in this statement we outline areas for improvement. Our efforts reflect our strong commitment to ethical business practices, collaborative partnerships and sustainable tourism.

   II. OUR POLICIES

Virgin Voyages is committed to conducting business responsibly across our value chain. We have outlined expectations for ethical business conduct for Board Members, Crew, Partners, and Suppliers which are described in relevant Codes for each audience such as the Code of Business Conduct, the Supplier Code of Conduct, and the Tour Operator Code of Conduct. Virgin Voyages also continues to evaluate areas where we can improve its internal and external codes of conduct.

As a Virgin brand, we have a zero tolerance position towards slavery and human trafficking in all forms. Modern slavery is wholly incompatible with our ethics to uphold international labor standards and human rights and the principles by which we conduct our business. Virgin Voyages is committed to working to prevent, identify and eliminate modern slavery in our business operations and supply chain.
   
   III. OUR SUPPLY CHAIN

Our business partners and suppliers span across industry sectors and geographies related to the cruise ship and hospitality industries, including but not limited to the following: ship manufacturing; global crew recruitment partners; tour operators; travel agencies; hospitality services; food and beverage providers; retailers; and information technology companies. We are committed to continuously evaluating our sourcing practices to provide the best quality products. While we have determined that most of our direct (tier one) suppliers are with low-risk industries or businesses located in low-risk countries for modern slavery according to GlobalSlaveryIndex.org, we understand that each industry sector has potential for modern slavery to occur, especially further down the supply chain.

     a. Risk Assessment

To prevent instances of modern slavery, Virgin Voyages is currently developing a Supplier Responsibility Program that we expect to implement in 2023. This program will include an assessment of our direct and indirect (tier two) suppliers to determine risk levels for modern slavery and human rights violations based on our level of spend, geographic location, industry-type, and whether the supplier conducts procurement services on Virgin Voyages’ behalf. The outcome of the assessments will inform our management approach. In the interim, Virgin Voyages has conducted internal assessments of business relationships to determine whether the individual vendors are adhering to the same standards as Virgin Voyages.

     b. Vendor Engagement

Regardless of geography, industry type, or Virgin Voyages’ amount of spend, during the engagement process with a potential supplier, a copy of our Supplier Code of Conduct is provided to the vendor along with our onboarding documentation. Vendors are not compensated unless these documents are acknowledged and agreed-to. Through the Supplier Code of Conduct, Virgin Voyages 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.” Upon entering into a contract or signing a purchase order, the vendor becomes a supplier to Virgin Voyages, and their signature binds the supplier to our terms and conditions provided at https://www.virginvoyages.com/suppliers. For example, Virgin Voyages expects third-party contractors to treat their workers and employees “with dignity and respect, and in accordance with fundamental fair labor principles as recognized by the International Labor Organization core conventions on Labor Rights.” Additionally, their signature self-certifies their compliance with the Supplier Code of Conduct, unless a comparable code is provided and agreed to by Virgin Voyages.

For suppliers who are key partners to Virgin Voyages and carry out procurement services on our behalf, we conduct periodic management reviews to ensure our procurement standards are embedded in their contracting processes. We are continuing to refine our management approach with these partners to ensure our requirements are understood and there are systems in place to educate our partners, assess risk, track concerns and monitor compliance.

     c. Site Visits and Audits

Through its contractual relationships, Virgin Voyages reserves the right to conduct site visits and supplier audits where it is deemed necessary.

For instance, we require that all of our contracted global recruitment agencies are International Labour Organization, Maritime Labour Convention (2006) (“MLC”) compliant. This is verified by an independent compliance certificate provided by an authorized third party. Virgin Voyages also conducts periodic interviews with recruitment candidates to ensure agency practices adhere to our requirements and uphold the MLC, which outlines the rights of seafarers and global standards for decent work. If violations are detected, such as requiring candidates to pay recruitment fees, the agency is immediately addressed and corrective actions are implemented.

We also contract with tour operators across various geographies and conduct site visits to ensure the operation is adhering to our operational standards and Virgin Voyages’ Tour Operator Code of Conduct, which includes upholding fair labor practices, such as the International Labour Organization (ILO) C138 Minimum Age Convention.

Per the Virgin Voyages Code of Conduct, should instances of human rights violations be identified through site visits or assessments, Virgin Voyages reserves the right to discontinue contracts with its suppliers.

Looking ahead, as we develop our Supplier Responsibility Program, we may require suppliers with a high-risk potential for human rights violations to complete self-assessments, third party assessments or conduct audits.

     d. Reporting Hotline

Virgin Voyages requests employees or suppliers who have experienced violations of our Codes, or suspect non-compliance, to contact Virgin Voyages anonymously and confidentially through a third‐party platform called EthicsPoint. Reports may be made by calling (833) 620‐6812, or by visiting virginvoyages.ethicspoint.com.

   IV . TRAINING

As a growing company, Virgin Voyages continues to identify areas it can provide trainings and adapt to the ever-changing landscape of the cruise industry. In 2023, Virgin Voyages will roll out a Modern Slavery Compliance Training for leaders in the business who are responsible for procurement and managing partner relationships. These trainings may also include procurement partners.

   V. PERFORMANCE MEASURES

As Virgin Voyages continues to grow, we will further develop and refine our modern slavery compliance strategy and performance indicators. Additionally, this statement and the results of our efforts will be updated each year. Additional information on our ethical business practices, partnerships and environmental, social, and governance commitments can be found in our annual Impact Report. A copy of this report can be found at www.virginvoyages.com/sustainability.

Approved by:
Adam Nebesar - Chair
Nominating, Environmental, Social & Governance Committee of the Board of Directors


Version: May 19, 2023
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