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
The decisions taken by Zurich Airport Ltd. in a challenging environment must meet high standards, not only financially but also ethically. With its ethical conduct, the company helps create stable framework conditions in which sustainable business success is possible. This primarily includes compliance with the law and voluntary commitments as well as fair and considerate treatment of others, whether at an individual or institutional level.
Respect for human rights and Anti-corruption are discussed in detail in the relevant sections.
Approach and progress
The Zurich Airport Group upholds the law and respects the rights and integrity of people, business partners and institutions 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 interests abroad each have their own code of conduct at the country level, which must meet the requirements of the Group-wide code as a minimum.
In order to communicate requirements and expectations to business partners along the value chain, these are set out in a Code of Conduct for Business Partners. 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.
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. It is described in more detail in the section entitled Compliance management system.
In the year under review, no relevant fines or sanctions were imposed due to non-compliance with any social or business laws and regulations.
Complaints channels and redress
Zurich Airport Ltd. promotes a culture in which suspected or actual breaches of the Group-wide Code of Conduct or other guidelines are reported. In addition to direct superiors, the People & Culture department or the standardised compliance process, employees at the Zurich site also have access to the staff representation council (PeV) to report issues relating to bullying, sexual harassment and equal treatment in particular (see the section entitled Responsible employer). If there are reasonable grounds to suspect that a regular report is not being followed up to the required extent, or if employees fear adverse consequences personally as a result of a report, they may contact the internal whistleblower office of Zurich Airport Ltd., which is staffed by the Secretary General. As far as possible, the identity of the whistleblower will remain confidential during any investigations.
Since the start of the reporting year, an additional complaints channel has been provided on the company’s website and is primarily aimed at external parties. The “Integrity Line” is available for reporting suspected or actual breaches of the Group-wide Code of Conduct. This relates in particular to the issues of data protection, corruption, antitrust and procurement law, and human rights. A total of seven reports were processed by the reporting offices at the Zurich site during the reporting year.
A separate process exists for reporting safety concerns relating to flight operations at Zurich Airport (see Occupational and aviation safety).
The sites abroad also improved or set up complaint channels in the reporting year that also cover the requirements of a whistleblowing channel. In both Brazil and India, independent external bodies are mandated to receive and process reports. In Chile, the reports received are processed internally by the Compliance department, as in Zurich. Three reports were processed in India in the reporting year, one in Brazil, and none in Chile.
The plan is to integrate the existing contact channels, which are stipulated for the Brazilian airports by the concession agreement and relate to the topic of noise, into the new complaint channels.
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 compensation in the Noise section). It is further obliged to operate a sound insulation programme to protect properties from exposure to noise (see Sound insulation in the Noise section).
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 the use of these infrastructures are determined and levied in an officially regulated procedure defined as part of aviation legislation under the supervision of the Federal Office of Civil Aviation (FOCA). Revenues from both aviation and non-aviation (although not all non-aviation) activities were taken into account in order to calculate airport charges (known as “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 charges and have, amongst other things, access to information about the cost basis used.
Market access for ground handling companies and airlines is likewise specified in Zurich Airport’s operating regulations. Under EU law, which applies on the basis of bilateral agreements, Zurich Airport Ltd. is obliged to grant these stakeholders access to the infrastructure in accordance with appropriate, objective, transparent and non-discriminatory criteria and to manage the infrastructure accordingly. In the reporting year, Zurich Airport Ltd. awarded entitlements for ground handling to four service providers in a public tender based on these criteria. A service provider that was not considered has petitioned the Federal Office of Civil Aviation (FOCA) to conduct a review of the award decision. The proceedings have not yet concluded. Apart from this, Zurich Airport Ltd. did not face any legal proceedings relating to anti-competitive behaviour or breaches of antitrust and monopoly law in the reporting year.
Zurich Airport Ltd. also strives to ensure fair competition in the non-regulated area, where Swiss antitrust legislation applies at the Zurich site. On a regular basis, it publicly invites tenders for entitlements for central services such as taxi concessions or the use of billboards and advertising space. This ensures free market access.
The operating licences of the international subsidiaries are also subject to government regulation, which varies depending on the particular country concerned. For example, the larger airports in Brazil, which include those of the Zurich Airport Group, are regulated by the Brazilian National Civil Aviation Agency (ANAC) via a “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 charges. A dual-till system is also used in Chile, regulated by the Ministry of Public Works of Chile (Ministerio de Obras Públicas, MOP). The new airport in India is regulated by the Airports Economic Regulatory Authority of India (AERA) using a hybrid till system (see ICAO, page 10).
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 that also includes the majority-owned subsidiaries abroad.
