The Oceania population of humpback whales (Megaptera novaeangliae) using Tongan waters is a listed Endangered subpopulation that supports a large swim-with whale industry focussed primarily on mothers and calves. This raises concerns about the industry's potential to impact on the subpopulation's breeding success and recovery. This study investigated whether whales responded differently to approaches by swimmers from boats than to boat approaches alone and whether different types of swimming (quiet approach, loud splashing or diving following a quiet approach) induced different avoidance responses. An avoidance response was defined as whales moving away from boats or swimmers and the strength of the response was defined by how far the whales moved away and whether there was an increase in surface activity. Animals responded more quickly to a loud splashing approach than to quiet approaches. There were no significant differences in measures relating to the strength of the response caused by swim type, however closer approaches by a boat did significantly increase the level of whale activity. These results suggest that managing swimmer behaviour around whales, particularly ensuring quiet approaches, will contribute to the ability of the industry to minimise disturbance of the animals and support the industry's sustainability.