Modern Slavery Act 2015.
Transparency in supply chain management
Last updated: February 2020
This Modern Slavery and Human Trafficking Statement is made by Gama Aviation Plc and its subsidiaries, (“Gama Aviation”), pursuant to section 54 of the Modern Slavery Act 2015 (the “Act”).
The UK Modern Slavery Act 2015 (the ‘Act’)
While the Gama Aviation group prides itself as one whose operations are conducted to the highest standards with personnel having a depth of both technical and commercial expertise, that is not the whole story and we seek to ensure in addition that our wider business practices both meet those same standards and are seen to do so. The Gama Aviation Plc board is committed to ensuring that we act ethically and with integrity in all our business relationships and I am personally committed to ongoing reviews of our practices across the group to help achieve this.
In particular, we are aware that the risk of labour abuse through any form of slavery, servitude, forced or bonded labour (of adults or minors), or human trafficking (collectively referred to as ‘modern slavery’ in this Statement) is a very significant one for industries that operate on a global basis and it is therefore a key concern for us. Although we consider that the group operates in a relatively low risk industry sector in regard to modern slavery, we are committed to taking the necessary steps to reduce the risk of modern slavery taking place at any level in our supply chain.
The Act obliges business to state the steps taken during the financial year to ensure that modern slavery is not taking place in their operations. Accordingly, continual business reviews include relevant employment practices, our supply chain and an assessment of the scope for future improvements. Gama Aviation’s supply chain includes third party flight support that can encompass ground handling, ground transportation and/or food and beverages services, and also hangarage / parking and maintenance services provision. In addition, we engage professional services as well as utilities, aircraft cleaning services, IT equipment and office-supply companies. These types of services are supplied to Gama Aviation group companies and their clients in various locations and, therefore, there are some suppliers who are based outside of Europe and the U.S.
During the year we have made and are continuing to make clear to our suppliers that we do not and will not tolerate modern slavery in any of its various forms. We endeavour to use only those suppliers who both agree within the applicable service supply terms to adhere to this same principle and who commit to ensure a safe and healthy working environment for their employees. We appreciate that this is not enough by itself and are requiring our first tier suppliers similarly to take active steps to identify whether any form of modern slavery may exist at the second or third tier levels and to audit for this at regular and reasonably frequent intervals.
We see this process as one of the ways in which Gama Aviation can benchmark its activities in this area against those of others in our industry sector and will take the opportunity to use aviation industry associations to share ideas on best practice and to make our intentions clear to our employees, investors and other key stakeholders as well as suppliers.
Due diligence processes, training and reporting
In support of our policy, our action plan includes:
- – undertaking a review to identify potential risk areas in our supply chains, particularly at the second or lower tiers and taking into account factors such as the nature of the operations, situations and/or supplies that represent a particular risk, whether due to the location, industry sector or other characteristics of the business;
- – consulting with our global business partners to ensure consistency of modern slavery policy and its practical implementation across our service supply;
- – devising and putting in place appropriate training for our staff and especially those engaged in procurement activities and recruitment;
- – developing and putting in place appropriate guidance, support and confidential facilities for the purpose of reporting concerns regarding the policy and its implementation, which is outside normal reporting lines and ensures that the information is received by those member(s) of senior management having oversight of modern slavery-related matters.
Further steps to combat modern slavery and human trafficking
Shortly following the current year end, we will assess how effectively our policy has been implemented and what further steps may be necessary.