Modern Slavery, Human Trafficking and Forced Labour Statement

At Brightsun India, we are committed to conducting our business responsibly, ethically and with respect for human rights.

We recognise that modern slavery, human trafficking, forced labour, bonded labour and other forms of exploitation are serious global issues that can affect individuals, businesses and supply chains across industries.

We have zero tolerance for modern slavery, human trafficking, forced labour, bonded labour and other forms of exploitation and are committed to maintaining responsible business practices throughout our operations and relationships with our employees, suppliers and business partners.

Our Commitment

We are committed to protecting human rights and treating everyone with dignity, fairness and respect.

No individual should be subjected to slavery, servitude, human trafficking, forced labour, bonded labour or any other form of exploitation.

Our commitment is guided by applicable Indian laws and regulations, together with our internal policies and standards relating to ethical business conduct and respect for human rights.

Our Legal & Regulatory Framework

Our approach to preventing modern slavery, human trafficking and forced labour is supported by the legal framework applicable in India.

Bharatiya Nyaya Sanhita, 2023

The Bharatiya Nyaya Sanhita, 2023 (BNS) contains specific provisions addressing trafficking, exploitation, slavery and compulsory labour. The BNS came into force on 1 July 2024. Relevant provisions include:

• Section 143 – Trafficking of persons: addresses trafficking for the purpose of exploitation, including exploitation involving slavery, practices similar to slavery and servitude.
• Section 144 – Exploitation of a trafficked person: addresses certain forms of exploitation of trafficked persons.
• Section 145 – Habitual dealing in slaves: addresses habitual importing, exporting, removing, buying, selling, trafficking or dealing in slaves.
• Section 146 – Unlawful compulsory labour: addresses unlawfully compelling a person to labour against their will.

Bonded Labour System (Abolition) Act, 1976

We also recognise the Bonded Labour System (Abolition) Act, 1976, which was enacted to abolish the bonded labour system and prevent the economic and physical exploitation associated with bonded labour.

The Act abolishes the bonded labour system and provides that no person may compel another person to render bonded labour or other forms of forced labour.

Brightsun India is committed to conducting its activities in accordance with applicable laws and regulations and to maintaining standards that support the prevention of exploitation, forced labour and human trafficking.

Our Approach

We take a responsible approach to identifying and addressing potential risks relating to modern slavery, human trafficking and forced labour. Our approach includes:

• Promoting respect for human rights across our business
• Maintaining appropriate policies and standards
• Working with responsible suppliers and business partners
• Considering relevant ethical and human-rights risks
• Encouraging employees and relevant stakeholders to raise concerns
• Providing appropriate awareness and training
• Reviewing our practices and identifying opportunities for improvement

Our Policies & Standards

Our commitment to preventing modern slavery and human trafficking is supported by our internal policies, procedures and standards.

These provide a framework for responsible business conduct and establish expectations for our employees, suppliers and business partners.

Our policies are reviewed periodically to ensure that they remain relevant to our business practices and aligned with applicable legal and regulatory requirements.

Our People

Our employees are central to our commitment to responsible and ethical business practices.

We aim to maintain a workplace where everyone is treated fairly and with dignity and respect. We do not tolerate forced labour, human trafficking, bonded labour, discrimination, harassment, intimidation or any other form of exploitation.

Everyone working on behalf of Brightsun India is expected to act responsibly, respect human rights and comply with applicable laws and company policies.

Our Supply Chain

We recognise that human-rights risks can extend beyond our direct operations and may arise within wider supply chains.

We seek to work with suppliers and business partners who share our commitment to responsible and ethical business practices.

Where appropriate, we communicate our expectations regarding ethical conduct, human rights and compliance with applicable laws.

We encourage our suppliers and business partners to maintain appropriate measures to identify and address risks relating to modern slavery, human trafficking, forced labour, bonded labour and other forms of exploitation within their own operations and supply chains.

Risk Assessment & Due Diligence

We recognise the importance of identifying and managing potential human-rights risks.

Where appropriate, we consider relevant factors when engaging with suppliers and business partners, including the nature of the services provided, the operating environment and other relevant risk indicators.

Our due-diligence activities may include reviewing supplier information, assessing relevant policies and standards, seeking appropriate assurances and addressing concerns where they arise.

Where a potential issue is identified, we aim to take appropriate and proportionate action.

Training & Awareness

Awareness plays an important role in preventing modern slavery, human trafficking and forced labour.

We aim to ensure that relevant employees understand our commitment to ethical business practices and know how to recognise and raise concerns about potential exploitation.

Where appropriate, training and awareness initiatives may be provided based on employees' roles, responsibilities and the level of risk associated with their activities.

We encourage an open culture in which employees feel comfortable asking questions and raising concerns in good faith.

Reporting Concerns

We encourage employees, suppliers, business partners and other relevant stakeholders to raise concerns if they become aware of, or suspect, any activity involving modern slavery, human trafficking, forced labour, bonded labour or other forms of exploitation connected with our business.

Concerns can be raised through the appropriate internal reporting or grievance channels.

We are committed to treating concerns seriously and taking appropriate steps to review, investigate and address issues where necessary.

We encourage concerns to be raised at the earliest opportunity so that appropriate action can be considered.

Governance & Responsibility

Our commitment to preventing modern slavery and human trafficking is supported by appropriate management oversight and responsibility.

Relevant teams and management are responsible for implementing our policies, promoting awareness, considering relevant risks and addressing concerns within their respective areas of responsibility.

We recognise that preventing exploitation requires ongoing commitment across the organisation and collaboration between employees, management, suppliers and business partners.

Continuous Improvement

We recognise that responsible business practices require continuous improvement.

We periodically review our policies, processes and practices, where appropriate, to identify opportunities to strengthen our approach to human rights and ethical business conduct.

As our business and operating environment evolve, we will continue to consider emerging risks, regulatory developments and relevant best practices.

Our aim is to continually strengthen our processes and promote a culture of responsibility, transparency and respect.

Our Commitment to Ethical Business

At Brightsun India, integrity, respect and accountability are fundamental to the way we conduct our business.

We are committed to maintaining a business environment that respects human rights and does not tolerate modern slavery, human trafficking, forced labour or bonded labour.

Through responsible business practices, employee awareness, appropriate due diligence, collaboration with our business partners and continuous improvement, we aim to contribute to a more ethical and responsible business environment.

Brightsun India remains committed to conducting business with integrity, respect and accountability. This statement has been approved by the Board of Directors of Brightsun Travel Limited.