2020 Statement on Modern Slavery

Gama Aviation (UK) Limited and Gama Aviation (Engineering) Limited, 2020 Statement on Modern Slavery

Transparency in Supply Chain Management

This Modern Slavery and Human Trafficking Statement is made pursuant to section 54 of the Modern Slavery Act 2015 (the “Act”) pursuant to section 54 of the Modern Slavery Act 2015 (the “Act”) by Gama Aviation (UK) Limited and Gama Aviation (Engineering) Limited, (collectively, “Gama Aviation” or “we”), each being an operating subsidiary in the Gama Aviation Plc group.

The UK Modern Slavery Act 2015 (the ‘Act’)

While each of the Gama Aviation Plc group’s operating subsidiaries strives to be a business whose operations are conducted to the highest standards, having personnel with a depth of both technical and commercial expertise, that is not the whole story. Each of them seeks to ensure in addition that its wider business practices, including the practices of those businesses that contribute as suppliers to us of goods and services, both meet those same standards and are seen to do so.

Our 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 to help us achieve this. We are aware that the risk of labour abuse through any form of slavery, forced or bonded labour of adults or minors, restrictions on freedom of movement 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 we operate in a relatively low risk industry sector regarding 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; for example, in relation to services such as such as aircraft cleaning and catering.

The Act obliges business to state the steps taken during the financial year to ensure that modern slavery is not taking place anywhere in their operations. Accordingly, ongoing business reviews will include our own and our suppliers’ employment practices throughout our supply chain wherever we operate, and an assessment of the scope for future improvements. Supplier compliance is and will continue to be the focus of our attention during the 2021 financial year.

Gama Aviation’s supply chain includes a wide range of third-party flight support services, which 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, IT and IT equipment, and back-office support services, such as invoice processing. These types of services are supplied to Gama Aviation and our clients in various locations around the world and there are some suppliers who are based outside of Europe and the United States.

During the year we have made and are continuing to make clear to our suppliers that we have a zero-tolerance approach to modern slavery and are fully committed to eliminated and preventing modern slavery and human trafficking throughout our operations and supply chain. We intend and are committed to engaging only those suppliers, who expressly agree within the applicable service supply terms to adhere to this same principle and who also commit to ensure a safe and healthy working environment, both for their own employees and those of their sub-contractors and suppliers.

We fully 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.

We are pleased to confirm that we have not been made aware of any allegations of human trafficking/slavery activities against any of our suppliers in the past year, but if and when we are, we would act immediately against the supplier, terminating the supply relationship at the earliest reasonable opportunity and reporting violations of which we become aware to the relevant authorities, where they exist.

This statement for 2020 sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2021.

In support of our policy and commitment, we continue:

  • to seek to identify potential risk areas in our supply chains, particularly at the first tier, taking into account factors such as the risk profile of individual countries based on the Global Slavery Index, the goods or business services rendered by the suppliers, the presence of vulnerable demographic groups, news analysis and the insights of labour and human rights groups. This assessment will determine our response and the risk controls that we implement.
  • following policies for identifying and preventing slavery and human trafficking in our operations which includes a Whistleblowing Policy. We encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We will provide a confidential helpline to protect the identity of whistle-blowers. We will have both an Employee Code of Conduct, breach of which has dismissal as the ultimate sanction, and a Supplier Code of Conduct, which is currently being updated, in each case in order to facilitate our employees and suppliers to do the right thing by clearly stating the actions and behaviour expected of them when representing the business or providing goods or services to our business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and in managing our supply chain.
  • Procurement Policy – we will update our Procurement Policy and supplier contracts and other documents, including to make explicit reference to slavery and human trafficking, among other things.
  • Supplier Terms & Conditions – update the standard Terms & Conditions of Purchase to include a reference to our business integrity policy.
  • conducting due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes assessing risks in the provision of particular services; auditing the suppliers, and their health and safety standards, labour relations and employee contracts; requiring improvements to sub-standard employment practices and sanctioning suppliers that fail to improve their performance in line with our requirements
  • raising awareness of modern slavery issues by communicating Social Value to all our staff, which explains our commitment in the fight against modern slavery, provides examples of the types of “red flags” to look out for potential cases of slavery or human trafficking and how employees should report suspicions of modern slavery
  • rolling out a fresh e-learning course to all employees and first tier supplier contacts, which covers topics such as various forms of modern slavery in which people can be held and exploited, the size of the problem and the risk to our organisation, how employees can identify the signs of slavery and human trafficking, how employees should respond if they suspect slavery or human trafficking, how suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation , what terms and guidance should be provided to suppliers in relation to slavery policies and controls, amongst others.
  • defining a set of key performance indicators and controls, which help to combat modern slavery and human trafficking in our organisation and supply chain.

Further Steps to Combat Modern Slavery and Human Trafficking

Shortly following the current financial year end, we will assess how effectively our policy has been implemented and what further steps to improve compliance across our supply chain may be necessary.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the modern slavery statement of each of Gama Aviation UK) Limited and Gama Aviation (Engineering) Limited for the financial year ending 31st December 2020, as approved by the Board of each company on 2nd September 2021

Signed by:
Marwan Khalek, Director
Gama Aviation (UK) Limited
Gama Aviation (Engineering) Limited