Modern Slavery Statement
Anti-slavery & Human Trafficking Statement 2025
This statement (the “Statement”) is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) to set out the steps taken by Cover Genius Holdings Pty Ltd and its United Kingdom based subsidiaries, Cover Genius Ltd, Booking Protect Ltd, Cover Genius EMEA Employee Services Ltd, Cover Genius EMEA Trading Ltd and CG Ticketing Services Ltd (collectively, the “Company”) during the financial year ending 30 June 2025 to combat modern slavery and human trafficking in its business and its supply chain.
This Statement is produced to detail the Company’s activity to prevent modern slavery and human trafficking. This is the third statement we have issued under the Act.
Structure and Supply Chains
The Company is a technology services company engaged in the distribution of insurance and other protection products primarily through Cover Genius Ltd and Booking Protect Ltd. Distribution is made via the platforms of e-commerce companies and directly to consumers.
Policies
The Company is guided by established standards on human rights and modern slavery and has corporate governance procedures in place to ensure compliance with applicable law. The Company’s anti-slavery efforts are supported by internal policies that create a framework for preventing slavery and human trafficking. The Company’s policies undergo an annual review cycle to ensure their effectiveness, align with the latest regulatory developments.
Diligence Process
The Company performs due diligence to apply appropriate internal controls concerning its distribution partners, vendors, and other partners. The risk assessment is based on the nature of the Company’s relationship with the partner. Due diligence is performed on an ongoing basis and includes a requirement for our partners to comply with all slavery and human trafficking legislation.
Training
The Company provides training to relevant staff to identify and mitigate the risks of slavery and human trafficking in our supply chains. Our training will undergo continuous review and updates to ensure its effectiveness and practical implementation.
Leading our Modern Slavery Approach
The Company’s Legal and Compliance team reports on compliance with the policies and processes underlying this Statement to the Company’s Audit and Risk Committee. The Audit and Risk Committee oversees compliance with this Statement as delegated by the Company’s Board of Directors. In 2024, no suspected cases of Modern Slavery were reported across all disclosure routes.
Effectiveness and Key Performance Indicators (KPIs)
A crucial part of our approach is measuring the effectiveness of our actions. The Company monitors its performance through a combination of indicators, including:
- The number of staff who have received training on modern slavery.
- The number of high-risk suppliers identified and subject to enhanced due diligence.
- A statement confirming that no instances of modern slavery were discovered during the reporting period, or details of any incidents and our remediation actions.
Looking Forward
During the next reporting year the Company will:
- Continue to conduct due diligence on new and existing partners at regular intervals, with enhanced checks where higher risks are identified.
- Enhance KPIs to track our progress in addressing modern slavery risk.
- Ensure annual training occurs and expand our training manual to ensure that it is tailored to specific roles and responsibilities.
- Review and enhance our policies to ensure they address the risk of modern slavery and human rights as part of our regular annual cycle.
Approval
This Statement was approved by the Board of Directors of the Company and signed on its behalf by Angus McDonald below. This Statement will be reviewed and updated if necessary to reflect the Company’s ongoing commitment to ensure its business and supply chain are free from slavery and human trafficking.