Modern Slavery Policy Statement

The ASL Group’s success is intrinsically linked to the way we conduct our business in line with our values and responsibility and integrity. These behaviours apply both within the business and in our dealings with suppliers.

In accordance with the (UK) Modern Slavery Act 2015 all bodies corporate and partnerships who (irrespective of where they are incorporated) (1) carry on a business, or part of a business, in the UK supplying goods or services, and (2) have a consolidated global turnover of above £36 million (or Euro equivalent) per annum, are required to prepare and publish an annual “Slavery and Human Trafficking Statement”.

This statement must set out the measures an organisation has taken during its financial year to ensure that slavery or human trafficking is not taking place in any of its supply chains or within itself.

Ireland has similar legislation, primarily the Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013.

This policy statement applies to all ASL Group entities in Ireland and the UK.

1. Modern Slavery

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.

Modern slavery includes victims who have been trafficked from overseas and vulnerable people who are forced to work illegally against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing.

2. Organisation Structure and Supply Chains

ASL Aviation Holdings DAC is a global aviation services group based in Swords, Ireland. The group consists of multiple companies including 4 airlines based in Ireland, Belgium, France, the United Kingdom and affiliate airlines in South Africa, India and Thailand, along with maintenance facilities and a number of leasing entities.  The group employs over 1500 people across multiple jurisdictions.

3. Policy

The policy of ASL is to conduct all of our business in an honest and ethical manner, and to comply with all applicable legislation. ASL is committed to ensure that neither modern slavery nor human trafficking supports our supply chain or our businesses. We aim for a zero-tolerance approach to violations of anti-slavery and human trafficking laws.

If breaches of these laws are found within our supply chain, ASL will review the continuation of business with individuals and organisations found to be involved in slavery, human trafficking, forced or child labour and retains the right to cease business with such individuals and organisations on this basis.

ASL is committed to acting professionally and with integrity in all its business dealings and relationships whether in Ireland, UK or abroad.

4. Reporting Suspected Slavery

All employees within the Group have an obligation to report knowledge or suspicion of slavery or human trafficking. Any genuine suspicion or knowledge of slavery or human trafficking is to be immediately reported. If the issue reported also relates to knowledge or suspicion of money laundering or terrorist financing then a further report is to be submitted in accordance with the Anti Corruption, Anti-Bribery and Anti-Money Laundering Policy. In addition, the Whistleblowing Policy provides for alternative avenues for reporting matters of concern, including in respect of suspicion or knowledge of slavery or human trafficking.

Employees who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal.

These provisions do not replace any legal reporting or disclosure requirements. Where statutory reporting requirements and procedures exist, these must be fully complied with.

5. Customers and Business Partners

ASL is committed to taking all reasonably practicable steps to ensure that slavery and human trafficking is not present either in our business or in our supply chains.

ASL is working on measures to ensure that client acceptance and ongoing monitoring procedures include detailed risk assessments of each client and business partner from an anti-money laundering, counter-terrorist financing and wider risk perspective. These include a review for potential publicly available indications of previous or current involvement with criminality, including modern slavery and human trafficking.

Further details of our risk based due diligence policy are contained in our Anti-Bribery, Anti-Corruption and Anti-Money Laundering Policy.

6. Employment Practices

ASL has procedures in place pertaining to our employment practices.

Robust recruitment processes in line with Republic of Ireland or UK employment law (as applicable), including “right to work” document checks, contracts of employment, and checks to ensure all employees are above minimum working age.

Market-related pay and reward, which is reviewed annually and linked to industry benchmarks.

7. Procurement Practices

We recognise that ASL may be exposed to a slavery and human trafficking risk when dealing with suppliers of products and services, particularly those who have operations and suppliers in other territories.

From a risk management perspective, we have identified potential risk areas within the supply chain and the actions required to address these issues. These actions include identifying and reviewing suppliers and vendors that fall within industries and/or countries that can carry higher risk, including in respect of modern day slavery and human trafficking. A Supply Chain Risk Register is kept and reviewed regularly by the ASL ESG Committee.

8. Statement

We want to help our employees, partners, clients and suppliers to understand more about these issues and understand how to report any suspicions they may have related to modern slavery and human trafficking.

We are continuing to develop training and information for employees on the issues of slavery and human trafficking to be delivered or made available to relevant employees on a periodic basis.

ASL will continue to develop and implement the measures mentioned above in respect of our supply chain and will continue to monitor and update our Supply Chain Risk Register.

Our approach to modern slavery and human trafficking risk will continue to evolve and we will continue to mitigate these risks through the provisions mentioned above.

ASL shall take responsibility for this statement and its objectives, and it will be reviewed and updated as appropriate.