Modern Slavery Statement

Published: 17 July 2026 · In respect of the financial year ending 31 December 2026

1. Introduction and scope

This statement is made by Travelbase LLC (QFC No. 04202), a travel and payments infrastructure company registered in the Qatar Financial Centre and headquartered in Doha, Qatar (“Travelbase”, “we”, “us”). It sets out our position on modern slavery — including forced labour, bonded labour, child labour, and human trafficking — and the steps we take, and have committed to take, to address the risk of it occurring in our business and supply chain.

Travelbase is not currently subject to a statutory reporting obligation under section 54 of the UK Modern Slavery Act 2015 or equivalent legislation. We publish this statement voluntarily, with regard to the principles of that Act, because we believe companies operating in travel and payments should be transparent about these risks from the outset, and because our customers and partners are entitled to know where we stand before they work with us.

2. Our business

Travelbase operates a travel and expense management platform for businesses, and a travel and payments API that allows other companies to embed travel booking and payment capabilities into their own products. We serve corporate customers and API partners across the Middle East and North Africa. We are an early-stage company with a small, office-based team in Doha. We do not manufacture goods, operate physical travel assets, or directly employ workers in high-risk labour categories.

3. Our supply chain

Our supply chain reflects what we are: a technology intermediary. It consists principally of travel content suppliers — airlines, hotels, and ground transport providers, accessed largely through established global aggregation and distribution channels — together with a licensed payment services provider, cloud infrastructure and software vendors, and professional services firms.

We recognize that the most significant modern slavery risk we are connected to sits in the hospitality layer of this chain. The hotel sector is widely acknowledged as higher-risk because of its reliance on outsourced, seasonal, and migrant labour in functions such as housekeeping, laundry, and construction, where subcontracting can obscure how workers are recruited and paid. As a booking intermediary we do not employ or control this workforce, but we accept that the bookings our platform processes connect our customers to it, and that this connection carries a responsibility to choose and monitor our sourcing channels with care.

4. Our position and policies

Zero tolerance. We do not tolerate forced labour, bonded labour, child labour, or human trafficking in any part of our business or supply chain, and we will exit any supplier relationship where such practices are found and not remedied.

Our own people. We comply with the employment standards applicable to us in Qatar and the Qatar Financial Centre. Everyone who works for Travelbase does so freely, under written terms, with pay that meets or exceeds legal requirements. We do not retain identity documents, charge recruitment fees to workers, or restrict anyone’s freedom to resign and leave.

Sourcing preferences. Where we select travel content channels, we give preference to suppliers and aggregators that publish their own modern slavery statements and supplier standards, so that the inventory reaching our customers passes through parties that have made their own public commitments.

Reporting. Anyone — employee, supplier, partner, or member of the public — who has a concern about modern slavery in connection with our business can contact us at [email protected]. Reports are reviewed by senior management, and no one will suffer retaliation for raising a concern in good faith.

5. Due diligence

At our current stage, due diligence is carried out at the point of supplier and partner selection. Before entering a material supplier or partner relationship, we consider the counterparty’s regulatory status, labour practices where visible, and published commitments on human rights. Our commercial agreements are being drafted to include the right to terminate for conduct that breaches applicable anti-slavery and human trafficking laws.

6. Steps for the year ahead

We are candid that this is our first statement and that our programme is at the beginning. Over the coming financial year we have committed to: adopt a written Supplier Code of Conduct covering labour rights, working conditions, and recruitment practices, and make acceptance a condition of onboarding for material suppliers; embed anti-slavery clauses in our standard partner and supplier agreement templates; brief every member of our team on recognizing and reporting modern slavery risks as the team grows; and review and reissue this statement annually, reporting honestly on what was done rather than what was intended.

7. Approval