Modern Slavery Statement

Modern Slavery and Human Trafficking Statement


Our Business and Structure

ETrawler Unlimited Company (“ETrawler”) (through our trading name CarTrawler) is a world leading B2B
end-to-end travel technology solution provider. We build partnerships for travel businesses such as
airlines, online travel agents and accommodation providers by connecting their customers with car rental,
private transfer and other transportation solutions all over the world.

ETrawler also introduces customers directly to car rental and ground transportation solutions through our
B2C brands (Argus Car Hire, Holiday Autos, Cabforce and Dégrifauto).

Our company values, along with our focus on people and process, underpins how we create a successful
global online marketplace bringing partners, customers and suppliers together and in turn, opportunities
to life.

Our Supply Chains

ETrawler provides marketing and introductory services for providers of transportation-related products.
ETrawler itself does not provide and is not responsible for the provision of such products, rather it
facilitates the booking of those products by end customers.

ETrawler provides the majority of its services from our HQ in Dublin, Ireland. A proportion of our
customer service calls are outsourced to our dedicated centre in Cairo, Egypt. The Cairo centre allows us
to cater for a diverse multilingual customer experience across multiple time-zones. The centre is
managed and overseen to the same high operational, ethical and reporting standards as our Dublin HQ,
resulting in a strong focus on consistency of operational performance. This level of oversight allows us to
diligently monitor our operations for any potential risks to our workforce and in our supply chain.

ETrawler procures IT services, hardware and software, professional services and office supplies from
reputable service providers.

The nature of ETrawler’s operations ensures that exposure to modern slavery is lower risk than for
companies operating in other sectors but ETrawler is committed to staying vigilant and to doing its part
to increase awareness of issues relating to modern slavery and human trafficking.

Our Approach

ETrawler has a zero-tolerance approach to modern slavery and unethical conduct in our business
relationships. To facilitate this approach our Whistleblowing Policy is on our intranet homepage, has been
distributed to all staff and forms a central part of our new staff induction process as we understand that
a culture of openness and accountability is essential in order to prevent such activities occurring and going
unsanctioned. In addition, in order to proactively identify and address any issues that could adversely
affect our operations, our productivity and our reputation as an ethical organisation, we provide a third
party speak-up reporting facility to allow employees to confidentially report concerns 24/7 either online
or via toll-free telephone.

In addition, our standard supply contract includes a clause which binds transportation suppliers to be
compliant with the UK Modern Slavery Act 2015 and all applicable anti-slavery legislation. We also carry
out due diligence checks on our transportation suppliers in this context.

All staff are trained on an annual basis to be vigilant to the signs and dangers of modern slavery and
encouraged where necessary to speak-up and utilise the Whistleblowing reporting options within the
company. All new staff are also required to read and acknowledge our Anti-Bribery and Corruption Policy
which provides further context around the impact of unethical behavior on our company and the people
we do business with.

Our Ongoing Mission

Over the coming year ETrawler intends to maintain and build on our focus on the identification and
management of modern slavery risks within our business by further developing the measures mentioned

We aim to evolve as a company and will continue to review and assess our company policies in light of
modern slavery.

This statement will be reviewed annually and updated as appropriate.