Modern slavery act

For a description of our business, 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 divisions are:

(a) Operations: this includes engineering, passenger operations and services, passenger and airport security, the fire service, sales and operational planning and responsibility for the aerodrome;

(b) Commercial: this includes marketing, airline relations, retail, property and surface transport and car parks;

(c) Finance

(d) Economics, Regulation and Business Assurance;

(e) Procurement;

(f) Construction;

(g) Corporate Affairs, Planning and Sustainability;

(h) Human Resources;

(i) Technical Officer; this includes IT including cyber security, Innovation and Commercial IT, Development, Capital Programmes;

(j) Legal.

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 concessionaires.

Finally, we are one of the main points of entry into 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.

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: construction; corporate and professional services; IT; passenger and operational services and providers of supplies and equipment.

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.

Again, our third party business partners will, because of their size of turnover, generally be required to comply with the Act.  We seek to include clauses in the contracts with our retailers and ground handlers similar to the ones we ask our suppliers to agree.

The implementation of this, as with our suppliers, depends 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.

We work with the police and other agencies to assist them in detecting and disrupting human trafficking which might be taking place at Gatwick.

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.

We keep under review what training needs to be provided to members of staff. 

We continue to review ways in which we can tackle slavery and human trafficking and to establish how best 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. This helps 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.