Introduction
Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
As a business, Liverpool Airport Ltd, comprising Liverpool John Lennon Airport (LJLA), Air Traffic Control Services Limited (ATCSL) and Liverpool Airport Services Limited (LASL) are committed to being honest and having strong moral principles in all of our business activities. We are therefore committed to playing our part to ensure that there is no modern slavery in any part of our business and being alert to the potential for slavery within supplier or contractor activity. To support this we have engaged with the Slave Free Alliance during the year to undertake an independent review of our policies and activities to ascertain potential areas for improvement.
This statement relates to activities taken to address modern slavery in the financial year ending 31st March 2020. Travel restrictions related to Covid-19 have severely affected the air travel sector since our year end and have resulted in staff being placed on furlough as well as redundancies. This statement is published later than usual due to the impacts of the pandemic on the business and its operations as permitted under UK Government reporting guidelines and is approved by the Liverpool John Lennon Airport Executive Management Team.
Structure, Business and Supply Chain
Opened in 1933, LJLA is one of the UK’s longest established airports. It is comprised of three separate trading companies: Liverpool John Lennon Airport, plus two subsidiaries, Air Traffic Control Services Limited and Liverpool Airport Services Limited, referred to jointly herein as ‘the Company’. Ownership is shared jointly by three separate entities: Ancala Partners (infrastructure investment manager), Peel Holdings and Liverpool City Council. There is a further link with Doncaster Airport, via Peel Holdings and Liverpool continues to provide Air traffic control services via Air Traffic Services Ltd, including radar from Liverpool and on-site Air Traffic Control.
Services managed directly by the airport include fire, engineering, air traffic control, airfield operations, car parks and all operational activities such as marketing and accounts, totalling approximately 220 employees. Additionally, there are between 2,000 and 3,000 staff working on site through a variety of other businesses / suppliers including:
- Baggage and passenger handling
- Security services
- Airlines
- Passenger mobility services
- Waste management
- Retail and catering concessions.
The Company further engages with a variety of contractors in respect of maintenance and construction projects. Aspects of the supply chain will entail levels of subcontracting.
Governance
Senior group sponsorship of the modern slavery programme sits with the CEO who is actively engaged with the process. It is further devolved to the HR and Community Director to lead and coordinate with the Directors of Finance, Operations, Commercial and Aviation Services reporting into the Board of Directors. This is further supported through a cross-functional working group that will develop KPIs to enable us to monitor progress, celebrate successes and identify areas of challenge as we continue to progress our modern slavery agenda.
Policy
As part of our strategy to understand and address the risk of modern slavery within the business and its supply chain, a number of polices are in place including;
- Modern Slavery Policy
- People Strategy
- Grievance Policy
- Whistleblowing Policy
- Employee Training and Development Policy.
We aim to provide clear guidance to our workforce and suppliers (both direct and subcontracted) in respect of our expectations and standards as well as accessible, trusted and independent mechanisms (SafeCall) to report concerns, including regarding modern slavery. We will continue to review and develop these, as appropriate, during the next 12 months.
Due Diligence
Since the purpose of the Company is to provide services to the travelling public, primary areas of the supply chain relate to providing those day-to-day operations. Additionally, key suppliers will include major project areas such as construction, for which a tender process is in place to gain inclusion on approved supplier lists.
In addition to relevant technical competencies, there are stringent security processes in place for both land-side and air-side suppliers and their employees.
The preference within LJLA to use directly recruited staff offers more control over recruitment processes than would be the case if labour providers were used. Applicants undertake face-to face interviews as well as appropriate security checks and all recruits have an induction which is completed with their supervisor. This covers Health & Safety, access to facilities and key policies etc. The induction process now includes modern slavery awareness.
Areas of risk in the business and supply chain
Any areas where there is a high degree of subcontracting (such as on construction sites) or extended supply chains that are less visible, may harbour modern slavery risk. It is our aim to develop a progressive programme to further map such supply chains and evaluate that risk as we return to more normalised operations and staffing levels following the pandemic.
The Company does not have visibility of the contractual arrangements or recruitment processes used by all parties present at the airport, which may be relevant to modern slavery. However, wide publication of modern slavery awareness and whistleblowing methods through posters in areas used by all provides some opportunity to reach everyone on site.
We are also very alert to the fact that airports can provide gateways for the trafficking of people and of the need to promote awareness and reporting options for passengers. Whilst travel restrictions during the pandemic have served to reduce the likelihood or numbers of victims amongst passengers; changes to visas and insecure employment around the globe are potential aspects that may increase risk in the coming months as we emerge from lockdown. Collaboration with partners such as the airport police, security and border force are valuable to share intelligence and good practice for the identification and safeguarding of potential victims.
Effectiveness in ensuring modern slavery is not taking place
Whilst benefitting from the necessary regulatory and security environment in which the airline sector operates, which may provide some deterrence to those seeking to exploit workers in or supplying the Company, LJLA is not complacent to modern slavery risk.
We will continue to develop our capacity to;
- Evaluate risk through mapping our supply chain,
- Identify potential victims
- Collaborate with internal and external partners to develop best practice
- Effectively respond to any incidents
Training
In addition to the induction undergone by all employees, including on how to whistle-blow, the Company has in place a programme of reviews that encompasses performance, development and training through regular engagement. We continue to review our training in respect of modern slavery as appropriate for roles at all levels of the organisation.
John Irving
CEO
