Modern Slavery Act
Slavery and human trafficking policy statement
Bristol Airport has a zero tolerance policy towards modern slavery and human trafficking. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or any other parts of our business, and to preventing Bristol Airport from being used by human traffickers.
Bristol Airport’s structure
Bristol Airport Limited (BAL) is an airport operator in the United Kingdom. BAL’s immediate parent company is South West Airports Limited, a company incorporated in England and Wales. We are owned by Ontario Teachers’ Pension Plan, a major pension provider and investor, with over $CAN 175bn in net assets.
BAL has around 290 direct employees, and works with a range of business partners and contractors who, together, provide services to airlines and passengers at the airport.
In 2016 we were the 9th busiest airport in the United Kingdom, handling over 7.5m passengers, a 12% increase compared to 2015. Airlines with operating bases at the airport include easyJet, Ryanair, Thomas Cook, Thomson Airways and bmi regional.
For a more detailed description of our business, including financial information, please refer to the published annual reports and financial statements of BAL.
Our supply chain
BAL and its subsidiaries operate exclusively in the highly regulated UK airport sector. BAL uses a wide variety of local, national and in some cases international supply chains to source equipment and services for the operation and development of the airport. Our supply chain spans a variety of industry sectors, which can be broadly grouped as follows:
- Capital Construction and Property;
- Engineering, Maintenance & Facilities Management;
- Professional Services;
- Passenger Experience;
- IT Services and Telecoms;
- Office Services, Supplies, Uniforms and Travel; and
- Other Service Contracts (including statutory services, rent, rates, utilities, policing etc.)
Bristol Airport is committed to complying with all applicable laws and regulations as well as conducting its supply chain in a fair, transparent and professional manner at all times.
Policies and controls
Bristol Airport will not tolerate slavery or human trafficking in its business or supply chain. We aim to maintain effective systems, controls and internal policies to prevent this, and take all allegations of slavery and/or human trafficking seriously.
Supply chain controls
Factors and controls in place that reduce the risk of slavery in our supply chain are as follows:
- The majority of work is carried out at the Bristol Airport site, where employees of BAL and our contractor supply chain are subject to security verification of their identity, background and/or criminal record checks, or will be escorted at all times while on site.
- Our work is generally skilled and requires competent skilled staff who hold industry or professional qualifications.
- We use established, regular and, where possible, local contractors, who work predominantly within the regulated UK economy. Our supply chains are generally short and transparent.
- Contractors on site are subject to a high level of scrutiny from BRS employees allowing for a high degree of visibility of our contractors’ staff.
- The vast majority of our material supplies are sourced through UK companies, which will be subject to, and compliant with, the Modern Slavery Act 2015.
- Supplied goods/services from outside the UK are uncommon and generally relate to specialist high-tech equipment or services. The nature of these suppliers is likely to ensure that relevant controls are in place.
- There is a high degree of engagement from senior management, both with employees and the operational functions of the business, which allows any concerns over slavery and human trafficking to be raised, should they occur.
- Our Whistleblowing Policy encourages individuals to report any wrongdoing, which extends to slavery and human trafficking. All Whistleblowing reports are treated in the strictest confidence and are investigated fully with appropriate remedial actions taken.
We expect all companies who supply us to be (a) compliant with all applicable laws relating to slavery and human trafficking, (b) undertake their own due diligence on their own supply chains and business partners, and (c) ensure that any contracts with their sub-contractors have similar obligations.
In order to further ensure compliance, BAL will undertake the following activities:
- A rolling review and amendment of standard contractual terms, to incorporate the requirements of the Act as and when contracts are placed or renewed.
- Large companies subject to the Act will be expected to provide their slavery and human trafficking statements for our records and review.
Employee controls
Factors and controls in place that reduce the risk of slavery in our company are as follows:
- All employees are on full written contracts of employment that are compliant with the Act.
- We ensure that all pay and conditions of our direct employees are of a high standard, above those stipulated in the Act.
- All staff directly employed by BAL are paid above the National Living wage.
- Unpaid work experience or internships are closely controlled in liaison with the appropriate third party.
- To further ensure an understanding of the risks of modern slavery and human trafficking across our business we have committed to raising awareness and understanding among employees of the importance of preventing any form of modern slavery and human trafficking.
The Head of People and Performance is responsible for ensuring compliance with these requirements.
Risk assessments for Bristol Airport and its supply chain
We will carry out a formal assessment of key risks to contravention of the Act within our own business and our contractor and equipment/material supply chains. If this identifies areas of concern, we will implement mitigating actions to manage the risk as effectively as possible.
Measuring the effectiveness of the policies
We will explore what information or performance indicators are appropriate and practical to measure the effectiveness of our Policy.