AGS Group Modern Slavery Act 2015 Statement
AGS Airports Holdings Limited, including its group of Airports, Aberdeen International Airport Limited, Glasgow Airport Limited and Southampton International Airport Limited, and its subsidiaries AGS Airports Limited, AGS Airports Investments Limited, AGS Airports Pension Trustees Limited, BAA Lynton Limited and Airport Holdings NDH1 Limited (herein referred to as the “AGS Group”) is publishing this statement in compliance with section 54(1) of the Modern Slavery Act 2015.
This Modern Slavery statement has been approved by the Board of Directors of AGS Airports Limited, on behalf of the AGS Group. Information contained within this statement is correct at the date of publish. It details the steps taken by the AGS Group in order to comply with the provisions of the Modern Slavery Act to aid the prevention of modern slavery and human trafficking for the financial year ending 31 March 2018.
AGS Airports Holdings Limited, a consortium of Ferrovial S.A. and Macquarie Infrastructure and Real Assets (MIRA), owns Aberdeen International Airport Limited, Glasgow Airport Limited, Southampton International Airport Limited, AGS Airports Limited, AGS Airports Investments Limited, AGS Airports Pension Trustees Limited, BAA Lynton Limited and Airport Holdings NDH1 Limited.
Macquarie and Ferrovial have a long established and successful relationship, working together across a number of infrastructure projects and partnerships in airports.
Our Supply Chain
AGS’ supply chain covers a large number of goods and/ or services across the airports, and covers many industry sectors. These goods and services are grouped into the follows categories:
- Professional services
- IT Services and Telecoms
- Commercial (includes airlines, ground handlers and retailers)
Each department within the airports will to a greater or lesser extent have a supply chain in which it depends on, and the interdependencies of the various departments, as well as the commonality of goods and services required across the AGS Group, results in some suppliers that have dealings with more than one department and/or airport.
During 2016 and 2017, AGS Procurement reviewed all suppliers in the supply chain for compliance with the Act. As a result of this, we have reduced our supply chain to remove any suppliers who did not satisfy our requirements.
As a result of this supplier cleanse, we have in the region of 870 suppliers across the AGS Group. A large number of these will have turnovers which trigger the compliance requirements of the Modern Slavery Act 2015, and have produced a Modern Slavery Statement.
Procurement Governance and Monitoring
AGS’ Group Procurement team monitor the AGS supply chain on an annual basis and at the commencement of a new sourcing process for modern slavery compliance in order to demonstrate that the AGS Group’s compliance with the obligations of the Act.
Prior to a tender process, all new suppliers are sent a Pre-Qualification Questionnaire (“PQQ”), which includes a section on modern slavery. The Supplier may not progress to the tender stage if they are highlighted as having a risk at this stage.
When AGS otherwise engage with a new supplier out with a tender process, a new supplier questionnaire, which includes a modern slavery section, is issued to the supplier to satisfy AGS requirements with respect to the Act.
AGS Procurement review the response to these questionnaires and determine whether there are any risks associated with the response, assess suitability of the supplier and any steps required to manage the modern slavery risk based on the response provided.
If a supplier provides insufficient details to the questionnaire, or is highlighted as being a high risk supplier in the Modern Slavery Act, such as manufacturing companies or uniform providers, Procurement will carry out further investigations into the suppliers modern slavery compliance either by carrying out a desk-top audit, telephone audit or by visiting the suppliers premises to carry out a full audit on the company.
The audit documents delve deeper into a business’s ethical behaviour, duty of care to employees, and the policies they have in place to satisfy procurement that the modern slavery risk is satisfactorily managed by the supplier. AGS also provide feedback and actions to mitigate any potential risks.
If after an on-site audit a supplier is deemed to be non-compliant with the provisions of the Modern Slavery Act, the supplier will be removed from the supply chain, and an alternative supplier will be sourced.
Our AGS Sustainable and Ethical Procurement Policy reflects our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere within our business or supply chain.
To ensure an understanding of the risks of modern slavery and human trafficking, the procurement team have all undertaken appropriate training in this area. We are currently developing an online training module for non-procurement staff to raise awareness and understanding for our employees across the Group.
Our Commitment to Modern Slavery Compliance
The AGS Group is committed to persistently monitoring and tackling modern slavery and human trafficking. We continually review our supply chain, and will focus on continuous improvement and the delivery of effective strategies to meet our commitment of compliance with the Modern Slavery Act 2015.