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.
Relevance
Careful decisions have to be made in the challenging environment in which the Zurich Airport Group operates. The operation of the airports requires the company to make new decisions every day which must meet high financial and ethical standards. Ensuring the long-term success of the Zurich Airport Group depends on having a stable and sustainable environment to which the company can contribute. This means not only primarily meeting statutory obligations and voluntary commitments; it also encompasses the fair and considerate treatment of other parties at both an individual and institutional level.
Matters relating to human rights and anti-corruption measures are discussed in more 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. It has set out its fundamental ethical principles in the Group Code of Conduct. The document is available in German, English, Spanish and Portuguese, i.e. in one of the official languages of all countries in which the Group operates majority-owned airports. The majority-owned subsidiaries abroad each have their own code of conduct at country level, which must meet the requirements of the Group Code of Conduct at a minimum.
A Business Partner Code of Conduct has now been adopted to communicate the expectations to business partners as well. This covers the topics of human rights, environmental protection, anti-corruption measures, competition, data and information. The Code of Conduct supplements existing provisions and requires a willingness to be transparent and cooperate as well as the possibility of risk-based audits by Zurich Airport Ltd. itself or commissioned third parties. The company is therefore extending its requirements for responsible management to the value chain as a whole.
Processes to remediate negative impacts
In the event of any negative impacts unjustly resulting from the business activities of the company, Zurich Airport Ltd. acknowledges its responsibility to offer effective remediation to those affected and to support appropriate mechanisms for this purpose.
At the Zurich site, Zurich Airport Ltd. is obliged in certain circumstances to compensate owners for a loss in value of their properties as a result of aircraft noise or very low direct overflights (see Noise section). It is further obliged to operate a sound insulation programme to protect properties from exposure to noise (see Noise section). As an employer, 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 Responsible employer section). In the reporting year, work was carried out on a new, supplementary complaints channel that, from 2025, will be used by third parties to report suspected or actual breaches of the Group Code of Conduct to the company. This relates in particular to the issues of data protection, corruption, antitrust and procurement law, and human rights.
In accordance with their operating licences, the Brazilian airports are obliged to provide low-barrier contact points such as an ombuds office. Accordingly, the airports in Florianópolis, Vitória, Macaé and Natal each have a separate website that provides a facility for submitting written complaints. The focus here is on noise. The airport operators are obliged to discuss the feedback with the national civil aviation authority (Agência Nacional de Aviação Civil, ANAC) and report what action has been taken. The Chilean airports offer contact options by telephone and via their websites.
A formal electronic complaints process is provided for employees in Noida, India. Such a process is currently being set up for all other stakeholders.
Compliance management
Zurich Airport Ltd.’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 based on those requirements, such as the Code of Conduct. 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 any social or business laws and regulations.
Whistleblower office
The Zurich Airport Group is reliant on irregularities and violations of rules and regulations being discovered and rectified. Zurich Airport Ltd.’s whistleblower office, run by the General Secretary, deals with cases where an employee has a justifiable suspicion that a concern they have reported using the regular compliance process via the Human Resources department or via their line manager 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. One report was received in the reporting year and was analysed. The enquiry concerned the classification of third-party documents and their copyright protection. All unresolved questions were clarified during the discussion. The report did not require any further measures to be taken.
The majority-owned subsidiaries in Brazil, Chile and India likewise have dedicated whistleblower offices and corresponding processes. In Brazil, a report was received concerning the morally reprehensible conduct of an employee. This report was investigated in accordance with a regulated procedure and led to personnel adjustments, as a result of which it was possible to rectify the situation. No reports were received in Chile and India in the reporting year.
A separate process exists for reporting safety concerns relating to flight operations at Zurich Airport (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.
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 set out transparently in the operating regulations for Zurich Airport (Annex 4, Attachment 2). Airport charges for using these infrastructures are specified and levied in accordance with a regulated procedure under the supervision of the Swiss Federal Office of Civil Aviation (FOCA). Revenues from both aviation and non-aviation (although not all) activities were taken into account in order to calculate airport fees (so-called “hybrid-till”; see also the section on “Additional disclosures in accordance with the Swiss Ordinance on Airport Charges (OAC)” in segment reporting). These procedures ensure that users are involved in setting airport fees and have, amongst other things, 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 Ltd. 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 Agency (ANAC) on the basis of a so-called “dual-till” system (see ICAO, page 10). This means that aviation and non-aviation revenues are considered entirely separately, and exclusively aviation revenues are taken into account for the purpose of calculating fees. A dual-till system is also used in Chile, regulated by the Ministry of Public Works of Chile (Ministerio de Obras Püblicas, 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 (see ICAO, page 10).
In the reporting year, a report was submitted to the Swiss Competition Commission regarding the use of taxi stands at Zurich Airport. The Competition Commission could not identify any abuse of a dominant position or abuse of relative market power and therefore did not pursue the matter further. Otherwise, there were no legal proceedings in relation to anti-competitive behaviour or infringements of anti-trust and monopoly law, either for Zurich Airport Ltd. or the majority-owned subsidiaries.
Internal Audit
Internal Audit is an independent and autonomous unit within the company. It reports functionally to the Audit & Finance Committee. Through its auditing activities, the unit helps to identify risks and weaknesses in established processes and initiate improvements. Internal Audit takes a risk-based inspection approach which also includes the majority-owned subsidiaries abroad.
Secondary occupations and public office
Zurich Airport Ltd. 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.
