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Modern Slavery & Human Trafficking Statement

Virgin Cruises Intermediate Limited (Virgin Voyages)

1. Introduction

Virgin Cruises Intermediate Limited ("Virgin Voyages") is a cruise line founded by Sir Richard Branson and the Virgin Group, committed to preventing, identifying and eliminating modern slavery across our operations and supply chain.

This statement is published pursuant to UK Modern Slavery Act 2015, outlines the steps we've taken to prevent modern slavery within our operations and supply chain. It also highlights our ongoing commitment to continuous improvement. Our Board of Directors, with oversight from the Environmental, Social and Governance (ESG) Committee, has reviewed and approved this statement.

2. Our Organization & Supply Chain

Structure

Virgin Voyages is headquartered in Plantation, FL and operates four cruise ships globally, employing a diverse workforce both shipboard and shoreside. A significant portion of our procurement spend is managed by third-party entities. This statement covers our shoreside and shipboard operations and direct supplier contracts.

Supply Chain

We work with over 1,400 suppliers across the following industries:
  • Crew recruitment agencies
  • Food, beverage & retail
  • Hotel supplies & textiles
  • Tour operations & excursions
  • Shipbuilding & marine engineering
  • IT, technology & electronics
  • Professional & corporate services
To address risks with Modern Slavery, we focus particularly on higher-risk categories including food & agriculture, retail, crew recruitment, and tour operations.

3. Our Policies

We uphold responsible business practices through our codes of conduct. Our codes are embedded in our contracting process, reviewed annually and updated as needed:
  • Code of Business Conduct — sets ethical standards for all employees and leaders.
  • Supplier Code of Conduct — requires suppliers to: abolish hazardous child labor; protect workers from inhumane treatment; follow ILO core conventions; and provide modern slavery training. A copy of this policy is available at virginvoyages.com/sustainability.
  • Tour Operator Code of Conduct — specific requirements to prevent exploitation and promote fair labor practices.

4. Supply Chain Verification

While we consider the risk of modern slavery within our direct operations to be generally low, we recognize that complexity increases further down our supply chain. The majority of our procurement spend with higher-risk industries is managed by third-party entities. As such we generally do not maintain direct relationships with the end suppliers, nor do we currently conduct regular independent verification of our broader supply chain for human trafficking and slavery risks.

Verification activities we do undertake:
  • We periodically visit supplier operations — such as tour operators — to assess working conditions and alignment with our tour operator code of conduct and operating standards.
  • We interview prospective seafarers to verify no recruitment fees or coercive practices are involved in their recruitment with third parties.
These activities are not currently conducted by an independent third party in the context of human trafficking and slavery risk specifically.

5. Supplier Certification

In our Master Services Agreement direct suppliers must accept our Supplier Code of Conduct as a condition of contracting with Virgin Voyages, unless they provide a copy of an equivalent code.

In 2025, we strengthened this process by introducing a supplier attestation at onboarding, under which suppliers self-certify that they:
  • Acknowledge our Supplier Code of Conduct Requirements, and
  • Do not operate in a country considered high risk by The Global Slavery Index or in a high-risk sector.
High-risk sectors may include, but are not limited to the following:
  • Talent Recruitment Agencies
  • Manufacturing
  • Food & Beverage
  • Textiles & Hotel Supplies
  • Tour Operators
  • Retail
  • IT & Electronics
If they do operate in a high risk country or sector, then they attest to providing relevant training on ethical labor practices for relevant staff, or sharing our online training with their teams.

Additionally, our shipboard operations are subject to port state control audits to ensure compliance with Maritime Labor Convention (MLC 2006) regulations. All global crew recruitment agencies must hold MLC 2006 certification, confirmed through third-party audits.

6. Internal Accountability

Virgin Voyages maintains clear accountability standards for both suppliers and employees:
  • Suppliers: where human rights violations are identified, Virgin Voyages reserves the right to discontinue contracts with suppliers, contractors or employees who fail to meet our standards.
  • Employees: any employee who fails to uphold our Code of Business Conduct — including obligations relating to modern slavery — is subject to our standard disciplinary procedures, up to and including termination.
We maintain a confidential, third-party ethics hotline operated by EthicsPoint, available to all crew and vendors:

7. Training & Awareness

In 2025, we completed a Modern Slavery awareness and preventive action, online training program for our Crew and Suppliers, covering how to identify, eliminate and report instances of modern slavery. This training has been integrated into our new supplier onboarding process. From 2026, completion is mandatory for all employees in contracting and procurement functions.

Tour Operator Training

We continue to offer Modern Slavery Awareness Training for Tour Operators — a complimentary program aligned with Global Sustainable Tourism Council (GSTC) criteria. In 2025, a total of 30% of our active tour operators had completed the training, or had received a third party certification that requires adherence to fair labor practices, since we launched the program in 2024.

8. Measuring Our Progress

In 2025, Virgin Voyages continued to expand supplier coverage under its Business Partner Code of Conduct. As of year-end, 75% of suppliers by count had agreed to the Code of Conduct or demonstrated that they maintain an equivalent code, representing 53% of annual supplier spend.

We update this statement annually and track the following proposed KPIs looking ahead:
 

KPI

2025 Results

Suppliers who signed the Code of Conduct (% of count)

75%

Annual spend covered by Code of Conduct (%)

53%

Modern slavery EthicsPoint reports received

0

Procurement/contracting staff trained (%)

TBD in 2026

9. Website Disclosure

This statement is publicly available at virginvoyages.com in the footer navigation.

10. Contact & Further Information

For further information or a signed copy: impact@virginvoyages.com

Full Impact Report: virginvoyages.com/sustainability

Approved by:
Name: Jordan Smith
Title: Chair, Nominating, Environmental, Social & Governance Committee of the Board of Directors

Date: June 18, 2026