Anti-corruption

The Zurich Airport Group does not tolerate any form of corruption 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, Zurich Airport Ltd. is aware that it is also exposed to certain risks of corruption at its various operating locations. Corruption is understood to mean any instance of abuse of a position of trust to obtain an unjustified advantage.

Zurich Airport Ltd. 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

Zurich Airport Ltd. does not tolerate any corrupt behaviour. It implements anti-corruption measures at all its sites; these are based on several fronts and also depend on individual employees behaving with integrity.

Preventive measures

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

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

Staff in leadership roles at the Zurich site 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.

Procurement

At its Zurich site, Zurich Airport Ltd. is obliged to procure goods and services in accordance with public procurement rules (see also the Regional value creation and Human rights 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.

Equivalent principles are applied to procurement at the sites in Brazil and India. At the Noida site in India, procurement follows the requirements of the company’s own procurement policy, which in turn is based on the requirements in the concession agreement.

Integrity clause in international business contracts 

The company also imposes obligations on its international business partners. Zurich Airport Ltd. includes a model contract clause forbidding active and passive bribery in all its contracts with local partners abroad. This clause stipulates a contractual penalty for any breaches as well as the premature termination of the contract without compensation. The majority-owned subsidiaries in Brazil, India and Chile also include anti-corruption clauses in their contracts.

Gifts

All employees of the Zurich Airport Group 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 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