Better Health for All

Trainline's digital platform faces significant barriers for vulnerable populations, with 28% of blind and partially sighted people being digitally excluded, directly limiting their access to the service.

Its external health equity program, offering £10 off travel to 500 people with Parkinson's, reaches only 0.3% of the 166,000 individuals living with the condition in the UK, indicating a very limited scale. The company's core service of facilitating rail travel has a complex net health effect. While promoting rail travel contributes significantly to public health by reducing air pollution (86% less CO2 than air travel, 80% less than car travel), the rail system it facilitates presents severe accessibility barriers for vulnerable groups, threatening their mental and physical health. Trainline does, however, disclose these environmental health benefits transparently by showing customers CO2 emission savings. Internally, Trainline demonstrates strong support for mental health, with 39 additional staff trained as Mental Health First Aiders, an Employee Assistance Programme, and Wellbeing Week activities including yoga and puppy therapy. The company also launched a Parkinson's badge initiative to reduce anxiety for customers with the condition. Trainline's operations do not involve health-related products, health data, or healthcare workforce development, making several health KPIs not applicable.

Fair Money & Economic Opportunity

Trainline PLC operates a platform for selling rail and coach tickets, generating revenue through commissions and transaction fees.

The company does not offer lending, deposit, or other financial services to consumers. Therefore, KPIs related to consumer credit products, APRs, loan/insurance books, or debt products are not applicable, resulting in a score of 0 for these categories. While the company has fee structures, there is no quantitative data on a 'fee multiple versus market median' to assess pricing fairness. Data accessibility initiatives focus on transport data and open data for ticketing, not 'customer finance data' or 'open-banking APIs'. Inclusion initiatives are related to workforce diversity and general travel accessibility, not financial inclusion for underserved segments. Similarly, 'financial wellbeing talks' lack sufficient detail on reach and outcomes to qualify as structured financial literacy programs. All KPIs map to a 0 score as the company's core business model falls outside the scope of financial services as defined by the rubric.

Fair Pay & Worker Respect

Trainline's CEO to median employee pay ratio (50th percentile) was 30.4:1.

As of April 5, 2024, the median gender pay gap for Trainline.com Limited showed women earned 77p for every £1 men earned, representing a 23.0% lower median hourly pay for women. The mean hourly pay for women was 20.0% lower than men's. In 2023, the median gender pay gap was 21% and the mean was 21%. The company paid a £2000 cost of living payment to employees in August 2022, excluding the Extended Leadership team. Trainline has an explicit commitment to equal pay for men and women doing the same job at the same level. The company maintains a whistleblowing policy with an external independent service and has policies against fraud, bribery, corruption, and human rights violations, as well as a Dignity at Work Policy.

Fair Trade & Ethical Sourcing

Trainline PLC, as a technology company operating a platform for selling rail and coach tickets, does not procure or trade physical commodities. Consequently, KPIs related to fair-trade certifications, traceability of physical goods, and sourcing of high-risk materials are not applicable to its operations. The company reported no incidents of slavery, human trafficking, forced labour, or child labour during financial year 2025.

Trainline has a Supplier Code of Conduct that underlines its no-tolerance approach to modern slavery and human trafficking.

Honest & Fair Business

Trainline PLC's audit scope covers 100% of Group revenue and 99% of Group total assets.

The company has an Anti-Fraud, Bribery, and Anti-corruption Policy in place, maintaining a zero-tolerance approach, providing regular training to employees, and operating a dedicated Fraud Management team. A whistleblowing policy is also in place, offering an independent, third-party, 24/7 hotline for employees and suppliers to confidentially report concerns, with all reported cases formally investigated and reported to the Audit and Risk Committee. However, in November 2024, the RMT union criticized Trainline for allegedly leading customers to purchase invalid or overpriced tickets , with over 90% of surveyed rail workers reporting instances of Trainline failing to provide best value fares , and around 80% reporting unusable tickets. Trainline refuted these allegations. An employee review in February 2024 also cited a 'toxic' company culture, poor leadership, and HR effectiveness concerns.

Kind to Animals

Trainline, as a digital ticketing platform, does not engage in activities such as animal testing, animal agriculture, or the use of animal-derived products, rendering most animal welfare KPIs not applicable. However, the company actively supports animal welfare in its operational context by providing detailed information on pet travel policies across various train operators

. Trainline partnered with Dogs Trust to create a guide for safe and stress-free train travel with dogs, offering tips on introducing dogs to train travel, essential skills, planning, and safety measures . The company also introduced the 'Tailcard' to signify a dog's readiness for train travel , encouraging responsible pet inclusion in travel plans and contributing to higher standards for pet travel.

No War, No Weapons

Trainline PLC explicitly states it does not engage in arms manufacturing, military contracts, or conflict facilitation, indicating zero revenue from such activities and a clear corporate stance against them.

The company also states it is not explicitly engaging in peacebuilding initiatives, resulting in no revenue allocated to such programs. Trainline's board has ultimate responsibility for its sustainability strategy. The company does not intend to make political donations or incur political expenditure. As a travel service company operating primarily in Europe, it has no conflict-region operations requiring human rights due diligence, no weapons red lines needed, no exposure to controversial weapons. Trainline is committed to upholding the principles of the UN Guiding Principles on Business and Human Rights through its human rights policy.

Planet-Friendly Business

Trainline's total Scope 1, 2, and 3 greenhouse gas emissions were 21,475 tCO2e in FY2025.

The company has SBTi-approved net-zero targets , including a near-term target to reduce absolute Scope 1 and 2 GHG emissions by 55.2% by FY2030 from a FY2020 base year , and long-term targets to reduce absolute Scope 1, 2, and 3 GHG emissions by 90% by FY2040 from a FY2020 base year . Trainline commits to reaching net-zero greenhouse gas emissions across its value chain by 2040, with defined interim targets . In FY2025, 11.75% of the company's electricity was sourced from renewables . Trainline confirms that its climate-related financial disclosures are consistent with all four themes and 11 recommended disclosures from the TCFD Final Report and Annex .

Respect for Cultures & Communities

The company donates an extremely small percentage of its £5.9 billion annual ticket sales to cultural heritage organizations

, with approximately £2,500 directed to Minority Rights Group International out of £10,000 in total charitable donations . No cultural appropriation incidents have been reported , and the company does not have a formal cultural impact assessment protocol , which is considered not applicable given its business model as a ticketing platform. Free, Prior, and Informed Consent (FPIC) processes are also not applicable to the company's operations. Similarly, the company's operations do not involve physical presence or land use that would directly disrupt cultural or heritage sites, and no such disruptions have occurred. There is no specific tracking of indigenous or minority-owned suppliers, which is considered not applicable to the company's operations. The concept of a social license to operate is not applicable to the company's business model. While the company partners with the Community Rail Network to support local communities , there is no evidence of formal partnership agreements directly with indigenous or local community groups.

Safe & Smart Tech

Trainline reported no customer-related personal data breaches that met the formal notification threshold in the last year.

The company has a comprehensive AI ethics program, including an AI Lab to assess emerging challenges, a privacy-first approach for LLMs, de-identification of personal data for tool training, and multi-disciplinary teams. Trainline holds PCI DSS Level 1, ISO 22301, and ISO 27001 certifications. All employees undergo regular security and privacy training, with additional targeted training for specific teams like annual secure code development. While regular AI audits are mentioned, specific details on scope or validation are not provided. There are no documented incidents of unauthorized data use, with access strictly limited to those with a business need and third parties contractually bound to protect data. Users have comprehensive data rights, including access, correction, erasure, portability, and the ability to close accounts and delete data, with requests responded to within one month. Authentication security includes PSD2 Secure Customer Authentication and 3DS version 2 for payments, and social logins. Vulnerability management is industry-leading, with annual third-party penetration tests, regular vulnerability scans, a 24/7 Security Operations Centre, a managed detection and response (MDR) solution, and security KPIs targeting a mean-time-to-detect (MTTD) of less than 60 minutes and a mean-time-to-contain (MTTC) of less than 4 hours. A bug bounty program exists, remediating approximately 120 critical/medium issues annually, but it does not currently offer payment. Privacy-by-design is evident through investment in anonymization, mandatory Data Protection Impact Assessments (DPIAs) for new features, and privacy impact assessments for novel processing activities. Security testing coverage includes annual independent external penetration testing, regular internal and external vulnerability scans, static and dynamic code testing, and continuous monitoring via an MDR solution. Data retention for application data is a maximum of two years, with data anonymized or deleted when no longer required. Trainline maintains a very strong regulatory compliance program with dedicated staff and enhanced training, processing data in line with data protection laws and using standard contractual clauses for international transfers. The company acknowledges the need to address algorithmic bias and ensure ethical AI development, including regular audits and transparency, but specific remediation effectiveness is not detailed.

Zero Waste & Sustainable Products

Trainline has implemented several waste reduction initiatives and integrated circular design principles into its operations. The company has established a 'Design Waste Crew' within its UX team to optimize design processes

and a 'Green Team' committed to minimizing plastic use and increasing recycling in office spaces . A significant initiative is the promotion of digital tickets, which 99% of customers choose , leading to digital tickets accounting for over 40% of sales revenue and significantly reducing paper waste . This shift aligns with circular design principles by reducing reliance on single-use items . Furthermore, eco-friendly measures in offices, such as using recycled and FSC-certified materials and recycling old furniture, have reduced waste to landfill by 8,767 kg . Trainline also optimizes waste in product development by systematizing design processes to increase efficiency and reduce resource consumption , and aims to implement a circular economy approach by recirculating product development waste .