Anti-corruption

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

Relevance

Corruption has a significant social and economic impact. It can lead to criminal consequences and damage a company’s reputation. As an international enterprise with many business relationships and close contact with authorities, Zurich Airport Ltd. is aware that corruption risks exist at all sites. Corruption is understood to mean the abuse of a position of trust to obtain an unjustified advantage.

As the headquarters of Zurich Airport Ltd., Switzerland is actively involved in combating corruption both nationally and internationally. It has ratified various international conventions and transposed them into national law. The resulting requirements for the prevention and combating of corruption apply directly to the entire Group.

Approach

Zurich Airport Ltd. does not tolerate any corrupt behaviour. At all sites, it focuses on comprehensive corruption prevention that covers several areas of action and requires that all employees conduct themselves with integrity. Key measures for the early detection and prevention of corruption include clear guidelines, a practised culture of transparency and comprehensive awareness-raising among employees. Zurich Airport Ltd. takes the following precautions to prevent corruption.

Codes of conduct and complaint channels

The Code of Conduct of the Zurich Airport Group sets out guidelines governing the behaviour of all employees. The majority-owned subsidiaries must also apply these requirements as a minimum. In addition, codes of conduct were introduced in the reporting year for business partners of the Zurich Airport Group and at all sites with majority interests. In the context of developing the whistleblower management system, the “Integrity Line” was also established as an external reporting channel for stakeholders outside the organisation. This supplements the existing internal channel for whistleblower tip-offs.

Further information on the tools mentioned can be found in the section entitled Business ethics.

Contracts

Contracts can only be legally signed by two people (dual control principle). The allocation of powers further clearly defines the extent of employees’ financial powers, and hence also their authority to sign contracts.

Procurement

At its Zurich site, Zurich Airport Ltd. is obliged to procure goods and services in accordance with public procurement law (see also the sections entitled Regional contribution and Human rights). This requires a transparent, regulated procedure and for 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. 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 and invitations

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). Exceptions are possible for courtesy gifts that do not call into question the recipient’s independence and freedom of choice. The maximum amounts per year at which a gift may be accepted or granted are set out in the country-specific codes of conduct. Any gifts above this fixed cap must be reported. At the Zurich site, the list of reports received is presented to the Nomination & Compensation Committee of the Board of Directors once a year. Limits additionally apply to the acceptance and provision of invitations abroad.

Training and awareness-raising

Mandatory compliance training sessions were held for defined target groups at the Zurich site in the reporting year. The content focused on key compliance topics such as corruption prevention. The sessions were held in the form of e-learning with the aim of providing solid foundational knowledge and promoting long-term awareness of the importance of these topics. With the same intentions in mind, an e-learning programme has also been introduced for the majority interests in Chile, which must be completed by all employees.

In Brazil, the key points of the Code of Conduct and Ethics are conveyed in an annual training course. This course is mandatory for all employees and is also offered to third parties. It covers anti-corruption policies and fraud prevention principles, as well as zero-tolerance policies on bullying and harassment.

Violations