Business ethics

Complying with the law, treating all people with respect, and conducting business as a fair and reliable partner all rank among the fundamental values of the Zurich Airport Group.


The high-profile position of airports as mobility hubs for a region or an entire country brings with it a wider responsibility. Over the long term, the company can only successfully fulfil its mandate in a functioning society, in an intact environment and in an efficient economy. Ethical conduct is not merely about meeting statutory obligations and voluntary commitments, it encompasses the fair and considerate treatment of other parties much more broadly at both an individual and institutional level.

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Matters relating to human rights and anti-corruption measures are discussed in greater detail elsewhere in this report.

Approach and progress

Together with the rights and integrity of people, business partners and institutions, the Zurich Airport Group respects the law at all times. In the year under review it decided to extend its group-wide processes and systems in this area. The first step was the revision of its Code of Conduct which was completed during the reporting year. This sets out the fundamental ethical principles of the company. Group-wide implementation will be completed by the end of 2023.

Code of Conduct
for the group

Processes to remediate negative impacts

In the event of any negative impacts improperly caused by the business activities of the company, Flughafen Zürich AG acknowledges its responsibility to offer effective remediation to those affected and to support appropriate mechanisms for this purpose. At the company's Zurich site the Swiss legal system provides adequate complaint and adjudication mechanisms – both governmental and non-governmental – that allow any party harmed to raise a matter.

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In Zurich, Flughafen Zürich AG is obliged in certain circumstances to compensate owners for a loss in value of their properties as a result of noise or very low direct overflights (see Noise compensation section). It is further obliged to operate a sound insulation programme to protect properties from noise exposure (see Sound insulation section). The company has also set up a staff representation council (PeV) to represent the interests of the workforce and to serve as an initial point of contact for any complaints about the company (see Participation rights section).

In accordance with their operating licence, the Brazilian airports are obliged to provide low-barrier contact points such as an Ombuds Office. The airports in Florianópolis, Vitória and Macaé consequently each have a separate website that provides information and a facility for submitting written complaints. The focus here is on noise. The airport operators are obliged to discuss these complaints with the national regulatory body (Agência Nacional de Aviação Civil, ANAC) and report what action has been taken.

Compliance management

Flughafen Zürich AG's compliance management system is used to systematically identify, understand and comply with statutory requirements as well as with internal corporate guidelines and ethical principles such as the Code of Conduct that are based on those requirements. This is described in more detail in the Risk management section.

In the year under review, no relevant fines or sanctions were imposed due to non-compliance with laws and regulations in the social and economic area.

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Whistleblower office

Alongside its standard compliance process, Flughafen Zürich AG operates a whistleblower office. The company is reliant on irregularities and violations of rules and regulations being discovered and rectified. The whistleblower office, run by the General Secretary, is available for cases where an employee has a justifiable suspicion that a concern they have reported via the normal channels is not being followed up appropriately, or where they fear personal reprisals. As far as possible, the identity of the whistleblower will remain confidential during any investigations. There were no cases processed by the whistleblower office during the reporting year.

A separate process exists for reporting safety concerns relating to flight operations (see Occupational and aviation safety). The human resources department and the staff representation council (PeV) are also available for reporting matters relating to bullying, sexual harassment and discrimination.

The majority-owned subsidiaries in Brazil, Chile and India likewise have a dedicated whistleblower office and corresponding processes.

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Fair supply chains

To ensure social, environmental and ethical standards are followed in Flughafen Zürich AG's supply chain, the company takes a risk-based approach and exercises its duty of care. In specific instances where social, environmental or ethical risks may be assumed because of the source of a product or the nature of the sector concerned, suppliers are assessed on the basis of certificates and standards to ensure compliance with the core labour standards prescribed by the International Labour Organization (ILO) at a minimum. One example of this from the year under review is the tendering process for new uniforms at the Zurich site, where this criterion was stipulated along with further sustainability requirements. Further information may be found in the Regional value creation, Anti-corruption and Human rights sections.

Anti-competitive behaviour

The operations of many business partners of the Zurich Airport Group are dependent on the airport infrastructure. The company therefore holds a dominant market position, and in some cases has a monopoly over infrastructures.

The particular infrastructures for which it has a monopoly are approved by the Swiss government and set out transparently in the operating regulations for Zurich Airport (Annex 4, Attachment 2). The charges for using these infrastructures are specified and levied in accordance with a regulated procedure. These procedures ensure that users are involved in setting the charges and have access to information about the cost basis used.

Market access for ground handling firms and airlines is likewise specified in Zurich Airport's operating regulations. Zurich Airport is obliged to manage and provide stakeholders with access to its infrastructures in a fair, objective, transparent and non-discriminatory way.

The operating licences of the international subsidiaries are also subject to government regulation, which varies depending on the particular country concerned. For instance, the bigger airports in Brazil are regulated by Brazil's National Civil Aviation Authority (ANAC) on the basis of a dual-till system. A dual-till system is also used in Chile, regulated by the Ministerio de Obras Públicas (MOP). The new airport in India will be regulated by the Airports Economic Regulatory Authority of India (AERA) on the basis of a hybrid-till system.

No legal proceedings were brought against Flughafen Zürich AG or its fully consolidated subsidiaries for anti-competitive behaviour or violations of anti-trust and monopoly laws during the year under review.

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Internal Audit

Internal Audit is an independent and autonomous unit within the company. It reports functionally to the Audit & Finance Committee. Its auditing activities help to identify risks and weaknesses in established processes, enabling any gaps to be closed. Internal Audit takes a risk-based inspection approach which also includes the majority-owned subsidiaries abroad. In 2022, Internal Audit took on more staff in order to keep pace with growth in international business and generally increasing complexity.

Political contributions

Flughafen Zürich AG grants cantonal parties in the Canton of Zurich an annual fixed sum supplemented by additional contributions during election years, provided a party has enough members to form a recognised parliamentary group in the Cantonal Parliament and it expresses support for a competitive Swiss aviation industry and airport infrastructure. The applicable principles are documented in writing. No political contributions are made in Latin America or India.

Secondary occupations and political office

Flughafen Zürich AG supports public service through paid leave where necessary. Employees who wish to take up public office or pursue another time-consuming secondary occupation must notify the company so any conflicts of interest are recognised in good time.

Resettlements in India

2377 families from eight villages will be resettled for the development and construction of the new greenfield airport in Noida, India. Most of the area earmarked for the new airport is agricultural land. The Gautam Buddha Nagar Administration, part of the government of Uttar Pradesh, is responsible for and is handling the resettlement and compensation process for the families affected. Compensation for the displaced families is in accordance with established government processes in India and falls under the “Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act” (RFCTLARR Act, 2013). Most families are paid cash for their land and receive an offer of new accommodation. The proportion of women affected by the resettlement is approximately 49%. The process of resettlement started in 2020 and should be completed during 2023.