Anti-corruption

The Zurich Airport Group does not tolerate any form of corruption or bribery and has taken precautions to prevent such abuses.

Relevance

Corruption has negative social and economic consequences and furthermore may lead to criminal prosecution and reputational damage. As an international enterprise with a wide variety of business relationships and close contacts with government agencies, Flughafen Zürich AG is aware that it is also exposed to certain risks of corruption at its various operating locations.

Flughafen Zürich AG is headquartered and anchored in the legal system of Switzerland which has ratified various international conventions. The group is thus directly subject to stringent anti-corruption regulations.

Approach

Flughafen Zürich AG does not tolerate any form of corruption and bribery at any of its locations. It seeks to practise effective corruption prevention to avoid both active and passive corruption and bribery. Such prevention requires action on a number of fronts and also depends on individual employees behaving with integrity.

Preventive measures

In accordance with its statutory and regulatory obligations, the Zurich Airport Group has taken a number of preventive measures to prevent corruption or expose any instances that nevertheless occur. The guidelines for the behaviour of all employees are laid down in the Code of Conduct. The subsidiaries in the various countries must also include these obligations as a minimum.

The four-eyes principle applies: contracts require two signatures to be legally binding. The allocation of powers further clearly defines the extent of employees' financial powers, and hence also their authority to sign contracts. Finally, Internal Audit is available to check and report on specific transactions at any time.

Staff in leadership roles at Zurich are explicitly trained and made aware of these matters. Those who are new to a management role with financial powers attend an induction event in which their attention is drawn to corruption prevention issues. The Legal, Risk & Compliance department also offers specific anti-corruption training courses.

Procurement

Flughafen Zürich AG is obliged to procure goods and services in accordance with public procurement rules (see also the Regional value creation, Human rights and Fair supply chains sections). This requires a transparent, regulated procedure and contracts to be awarded on the basis of clearly defined criteria. Tenders are always evaluated by multiple people. In addition, all staff working in procurement sign a “no conflict of interest” declaration. This declaration obliges all employees concerned to stand aside in the event of any conflicts of interest, to avoid any contact with potential suppliers during the procurement process beyond that of the direct process itself, and to maintain confidentiality.

Integrity clause in international business contracts

The company also imposes obligations on its international business partners. Flughafen Zürich AG includes a model contract anti-corruption clause (active and passive) in all its contracts with local partners abroad. In the event of a breach, this clause stipulates a contractual penalty and the premature termination of the contract without compensation. The subsidiaries in Brazil, India and A-Port in Chile also include anti-corruption clauses in their contracts.

Gifts

All employees of Flughafen Zürich AG are forbidden to give or receive cash, goods, in-kind benefits, invitations or other advantages. The same applies to undisclosed commissions ('kickbacks'). An exception may be made for courtesy gifts, in which case a maximum amount is specified for each individual gift and cumulatively per year in each country. Any gifts above this fixed cap must be reported. The list of reports received is then presented to the Board of Directors once a year. Limits additionally apply to the acceptance and provision of foreign trips.

Violations