Modern slavery act
Slavery and human trafficking statement
We have a zero tolerance policy towards modern slavery and human trafficking, and are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business, and to doing what we can to prevent our airport from being used by human traffickers.
1. Our business
For a description of our business please, including profit and loss, balance sheet and shareholders please read our latest annual report and financial statements.
Our business is organised into a number of business units; the broad structure is set out below:
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business, and there are three broad areas to which we have regard.
The first is the supply chains serving the various business units described above.
The second is non supply chain business partners; principally our airlines, groundhandlers and retailers.
Finally, we are one of the main points of entry in to the United Kingdom, and therefore have a responsibility to do what we can to prevent human trafficking through our airport. This statement will look at all three of these areas in turn.
2. Supply chains
Each department will to a greater or lesser extent have supply chains on which it depends, and the interdependency of the various departments means that one supplier may have dealings with more than one department.
We have in the region of 750 suppliers; in the following broad categories professional consultants, technical consultants, construction services, IT services, vendors of equipment, suppliers of cleaning and catering services.
A large number of our suppliers will have turnovers which trigger a requirement to comply with the obligation to produce a Slavery and Human Trafficking Statement under the Modern Slavery Act 2015 (the “Act”).
We will require companies who supply us, whether or not they are independently required to comply with the Act, to give us legally binding obligations (as and when contracts are entered into or renewed) to:
- comply with all applicable laws relating to slavery and human trafficking (including the Act),
- undertake their own due diligence into their own supply chains and business partners; and
- ensure that any contracts with their subcontractors have similar obligations.
To ensure all those in our supply chain and contractors comply with our values and ethics we intend to establish a supply chain compliance programme. The detail of the programme will be informed by the outcome of the review mentioned in paragraph 7, below.
3. Business partners
Again, our third party business partners will, because of their size of turnover, generally be required to comply with the Act. We will however be seeking to include clauses similar to the ones we will be asking our suppliers to agree with our retailers and ground handlers. The implementation of this will, as with our suppliers, depend on renegotiating contracts and operating licences as and when they come up for renewal. Airlines of course have a special role to play in relation to modern slavery and human trafficking, and while we do have express contracts with some of the larger airlines the majority will operate under our conditions of use. The review that is referred to in paragraph 7 below will look at the feasibility of requiring airlines to enter into agreements relating to modern slavery and human trafficking in the light of the general obligations that airlines have in relation to this.
4. Use of airport
We work with the police and other agencies to assist them in detecting and disrupting human trafficking which might be taking place at Gatwick.
In addition, we are training our security officers to recognise the way in which people who are being trafficked might present at the airport, and to offer assistance to those who might be vulnerable. This training is being further rolled out to other passenger facing staff, and has resulted in a number of individuals being helped. Training is being undertaken in conjunction with A21, a charity dedicated to preventing human trafficking, protecting the victims of human trafficking and prosecuting the traffickers.
5. Our policies on slavery and human trafficking
Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains or across the wider business.
In addition to the specific training provide to airport security officers and other passenger facing staff, GoodCorporation will, as part of the review referred to in paragraph 7 below, investigate what other training needs to be provided to other members of staff. Once training needs have been identified the appropriate training will be provided.
7. Our effectiveness in combating slavery and human trafficking
We have appointed an independent third party, GoodCorporation, to conduct an externally facilitated review to bring insights on ways to we can tackle slavery and human trafficking. GoodCorporation uses key performance indicators to assess how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains.
The review will help us to:
- Identify and assess potential risk areas in our supply chains and in the wider business
- Mitigate the risk of slavery and human trafficking occurring in our supply chains and the wider business
- Monitor potential risk areas in our supply chains and the wider business
- Protect whistle blowers.
8. Further steps
Once the review has been completed, we will work with GoodCorporation to implement their recommendations.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2016.