Modern Slavery Statement

Our mission is to help travelers experience the very best of Hawaii. Heavenly Vacations is a Hawaii-based vacation rental and hospitality company offering professionally managed luxury short-term rental properties across the Hawaiian Islands, including Maui, Kauai, Oahu, the Big Island, and Molokai.

Kauai Exclusive Management is a full-service property management company and real estate brokerage specializing in vacation rental properties on Kauai, Hawaii. We provide guests with oceanfront condos, resort properties, and private homes across the North Shore, East Shore, and South Shore of the island.

Our team is comprised of employees and independent contractors based in Hawaii, supporting guest reservations, property management, maintenance coordination, concierge services, and real estate operations.

We are committed to fair pay, transparent hiring practices, and treating every worker with dignity and respect. We verify the right to work for all employees in accordance with applicable law and do not charge recruitment fees to any worker at any stage of employment.

We respect the human rights of our employees, guests, suppliers, and community by seeking to avoid infringing on the rights of others and working to address any adverse human rights impacts connected to our business. Our commitment is grounded in internationally recognized standards, including the United Nations Guiding Principles on Business and Human Rights.

As a company operating in the hospitality and travel sector, we recognize that our industry can carry elevated risks related to labor exploitation, particularly in areas such as cleaning services, maintenance, and seasonal staffing. We take these risks seriously and are committed to ongoing assessment and improvement.

Any employee, contractor, supplier, or member of the public may report concerns related to modern slavery or human rights to us directly. All reports will be reviewed and acted upon appropriately.

Our Code of Conduct applies to all employees, contractors, and business partners. It reflects our collective commitment to ethical business practices and includes a clear prohibition on any form of exploitation, forced labor, or trafficking.

We expect all suppliers and contractors to share our commitment to high ethical standards and full compliance with applicable labor law. Under no circumstances may any supplier use, facilitate, or benefit from modern slavery or human trafficking, including forced labor, debt bondage, or child labor. We would rather forgo a business relationship than work with a partner who cannot demonstrate compliance with these standards.

We are committed to paying all employees a fair wage in full compliance with applicable Hawaii and federal labor law. We review compensation regularly to ensure our pay practices remain fair and competitive.

Our agreements with suppliers and service providers include provisions requiring compliance with applicable labor and human rights laws, including explicit prohibitions on modern slavery and human trafficking. These terms are included in new, renewed, and existing agreements.

We screen new suppliers prior to engagement, with heightened attention given to those providing labor-intensive services such as property cleaning, maintenance, and landscaping. We assess both new and existing supplier relationships on an ongoing basis and will suspend or terminate any relationship where a violation of our standards is identified.

We have identified the following risk levels across our operations:

• Lower risk: Our direct workforce, technology and software providers.
• Moderate risk: Cleaning and maintenance contractors, and seasonal activity or concierge providers, where subcontracted or informal labor arrangements may be present.

We continue to monitor and strengthen our assessment processes across all risk areas.

We maintain internal procedures for receiving, assessing, and responding to any concerns related to modern slavery within our operations or supply chain. Concerns are escalated to company leadership and addressed promptly. We conduct periodic reviews of these procedures to ensure they remain effective.

All new employees receive information during onboarding regarding our commitment to ethical business practices, including how to identify and report potential modern slavery concerns. Our Modern Slavery Statement and related policies are made available to all staff.

Our managers and team leads receive guidance on modern slavery risks relevant to the hospitality and vacation rental sector, including indicators to watch for in cleaning, maintenance, and labor contracting contexts.

We monitor industry guidance and best practices relating to modern slavery in the travel and hospitality sector and are committed to incorporating relevant training resources as they become available.

We support broader efforts to combat human trafficking and exploitation in the travel and hospitality industry. We remain open to engaging with relevant industry organizations, civil society groups, and anti-trafficking initiatives as our business grows.

We are committed to expanding our collaboration with experts and organizations in this space in order to detect, disrupt, and raise awareness of modern slavery risks across our operations and the communities where we work.

All employees and contractors are expected to report potential or actual violations of our policies, including any modern slavery concerns, to their manager or directly to company leadership. We maintain a strict zero-tolerance policy toward retaliation against anyone who reports a concern in good faith.

Suppliers, guests, and members of the public are encouraged to report any human rights concerns to us directly. All reports will be reviewed and, where appropriate, action will be taken, including suspension or termination of supplier relationships where violations are confirmed.

We are committed to monitoring our progress against the commitments set out in this Statement. Key indicators include: completion of supplier due diligence reviews for significant new contracts; the number of concerns reported and actions taken; and the reach and effectiveness of employee awareness efforts.

This Statement will be reviewed and updated annually. We monitor relevant legislative developments relating to modern slavery and human trafficking transparency and are committed to meeting any applicable reporting obligations.

We remain dedicated to continuous improvement in our policies, supplier practices, and awareness programs in order to strengthen our response to modern slavery risks.