2Excel (Holdings) Ltd Statement on Modern Slavery
This Modern Slavery Statement (“Statement”) is made pursuant to section 54 of the Modern Slavery Act 2015 (the “Act) and sets outs the steps taken by 2Excel (Holdings) Ltd and its subsidiaries (collectively “2Excel” or “we”) during the financial year ending March 2025 with the aim of ensuring there is no Modern Slavery in our business or our supply chain. This Statement forms part of our commitment to acting ethically in our business relationships.
Modern Slavery is used as an umbrella term for all offences of slavery, servitude, forced or compulsory labour and human trafficking.
The Act obliges us to state the steps we have taken during the financial year to reduce the risk of Modern Slavery taking place in any part of our business or supply chain. In accordance with section 54 of the Act, our Statement is structured under the following headings:
- Organisation and Supply Chain Structure
- Policies
- Due Diligence Process
- Risk Assessment
- Key Performance Indicators
- Training
1. Organisation and Supply Chain Structure
2Excel (Holdings) Ltd is a holding company for the 2Excel Aviation Ltd Group of companies (2Excel) and at the end of the financial year ending March 2025 we employed 382 staff.
On 16th April 2024, 2Excel Group Ltd was created which incorporates 2Excel (Holdings) Ltd, along with its subsidiaries and 2Excel Engineering Ltd into a group structure. This change took place during the financial year so for 2025, our Statement is for 2Excel (Holdings) Ltd only. Next year, our statement will be made at 2Excel Group level.
We are an aerospace services company split into four main revenue generating areas:
- Capability Development gets our customers’ and our own ideas airborne safely, compliantly, usefully, quickly, affordably and sustainably.
- Special Missions provides cutting-edge contract air services including market leading aerial dispersant services globally and, nationally, Search and Rescue, surveillance and on scene control.
- Charter provides impeccable air travel in Britain, Europe and beyond and keeps Support at readiness for Special Missions’ availability contracts.
- Insight turns remotely sensed data into actionable insight to address real world challenges at national scale.
These are underpinned by our Support functions (Finance, HR, Communications, Commercial and Business Support, Operations, Training, Compliance, Safety, Security, Continuing Airworthiness Management and Engineering support services).
2Excel is a UK-based Group but some of our services may be delivered in, from or to other countries, for example when we carry out a Charter flight. Additionally, as 2Excel has international ambitions, during the financial year an associated company, To Excel Ireland Ltd, that had been established in the Republic of Ireland in the previous financial year, began trading.
2Excel’s supply chain is wide ranging including, but not limited to, infrastructure, maintenance, aircraft parts, flight support services, utilities, office stationery and IT. Our supply chain is mainly based in the UK for services and the USA for aircraft parts but, other countries feature on an infrequent basis. Our supply chain can be complex where specific aircraft parts are required and may result in us buying low-cost items infrequently from many different suppliers.
2. Policies
Through our Sustainability Policy and its subordinate policies and plans we are committed to assessing, preventing and mitigating the risk of modern slavery. Measures include, but are not limited to, our Social Value Policy, Recruitment Policy, Grievance Policy, Whistleblowing Policy, Code of Ethics for our employees and a Code of Conduct for our suppliers. These documents strengthen our controls related to modern slavery and detail how we should select businesses within our supply chain. Furthermore, through our Whistleblowing provisions, employees are encouraged to raise concerns or suspicions on slavery or human trafficking to a supervisor, manager, Director or the HR Department at any time.
We continue to aspire to bolstering our procurement processes with a centralised procurement team and a dedicated Procurement Policy.
3. Due Diligence Processes
We ensure due diligence is carried out when hiring any employee to minimise the risk of modern slavery in our business. This is done through the Baseline Personnel Security Standard (BPSS) check for all new joiners which allows us to satisfy ourselves about the identity of the individual. In addition, all our roles pay at least the National Minimum Wage.
We assure our supply chain through regular auditing by our Compliance Monitoring team in line with aviation regulatory requirements.
We are pleased to report that we have not been made aware of any allegations of Modern Slavery against any of our suppliers in financial year 2024-25. If we were to be, we would act to investigate any relationship with the supplier as soon as reasonably practical and report to the relevant authorities as appropriate.
Going forward, alongside centralising procurement, we are striving to introduce specific modern slavery elements as part of our supplier auditing process to further strengthen our due diligence processes. To that end, we are working towards:
- Introducing a New Vendor Questionnaire
- For any supplier where we spend, or are likely to spend, more than £100,000 in the financial year, or where we determine it necessary through our internal risk assessment, we may require the supplier to provide a commitment that they will take appropriate steps to prevent modern slavery within their own business and their supply chains.
- Where we have a choice of supplier, we will consider not using suppliers who fail to provide the above commitment.
4. Risk Assessment
Aviation is a low-risk industry sector regarding modern slavery. Nevertheless, we are committed to taking necessary steps to reduce the risk of modern slavery taking place in our business or at any visible level in our supply chain.
A Modern Slavery Risk Assessment will be introduced during financial year 2025-26. We will seek to use our aviation industry associations to share best practice and generate further ideas.
5. Key Performance Indicators
2Excel has introduced objectives across the business and at various levels. We may use terms like Business Objectives, Action Plans, Three Line Objectives or KPIs interchangeably to refer to these. In addition, for some of our contracts, customers set specific KPIs. 2Excel has assessed its current objectives and KPIs and do not believe they indirectly or directly increase or influence the modern slavery risk that the Group carries.
2Excel will consider introducing Modern Slavery KPI(s) during the financial year 2025-26 which may include:
The number of employees who have undertaken anti Modern Slavery Training (as a percentage of total employees);
The number of suppliers, where our spend in financial year exceeds £100,000 or, where deemed necessary by our internal risk assessment, are audited for Modern Slavery processes;
The number of suppliers used who have agreed to comply completely with our commitment to prevent Modern Slavery (as a percentage of total suppliers above the £100,000 threshold).
6. Training
2Excel has been providing Modern Slavery Training to our employees for several years via a third-party online e-learning platform. The training raises awareness of modern slavery, including how to identify victims and how to report. In financial year 2022-23 we committed to making this a mandatory annual training requirement for all employees.
Where required and appropriate, more in depth and/or specific training can be sourced for individual employees or functions that have that need.
7. Updates and Approval
This Modern Slavery Statement will be reviewed annually and updated as necessary.
This Statement has been endorsed by the 2Excel Board and the Environmental, Social Value and Governance (ESG) Steering Group.
This Modern Slavery Statement has been approved and authorised by:
Name: Louise Campbell
Position: Group HR Director
Date: 15th October 2025
Signature: 
