Modern Slavery Statement

MODERN SLAVERY STATEMENT

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking. All of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

London Luton Airport Operations Limited (LLAOL), as operator and manager of London Luton Airport (LLA) is committed to:

• acting ethically and with integrity in all our business dealings and relationships;
• implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains; and
• ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.

LLA is a main port of entry into the UK, and therefore human trafficking through our airport is a risk within our business and one we wish to manage responsibly. We expect the same high standards from all of our contractors, suppliers and other business partners, as part of our procurement and business processes.

LLAOL is committed to improving our practices to combat slavery and human trafficking.

OUR BUSINESS

London Luton Airport Holdings III Limited, is the parent company of the LLA group of companies (Group). The companies within the Group are: London Luton Airport Operations Limited, London Luton Airport Group Limited, London Luton Airport Holdings I Limited and London Luton Airport Holdings II Limited. We make this statement on behalf of the companies within the Group.

The ultimate owners of the Group are its majority shareholder Aena, the world’s largest airport operator based in Spain, and its minority shareholder InfraBridge, a global investment management firm.

LLA is one of the UK’s largest airports. London Luton Airport Operations Limited is operator and manager of LLA under a concession agreement with the local authority, Luton Borough Council. Further information about our business can be found in our annual report and on our website (www.london-luton.co.uk).

OUR POLICY ON SLAVERY AND HUMAN TRAFFICKING

Our policy reflects our commitment stated above, namely: acting ethically and with integrity in all our business relationships, implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business or supply chains, and ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.

The following LLAOL policies are relevant in tackling modern slavery:

1. Code of Conduct: This applies to all directors, managers, executives and employees. The code sets out what is and what is not acceptable behaviour within LLAOL. It also applies to anyone LLAOL does business with, whether internal or external, and sets out the principles to apply in daily work. The Code of Conduct reinforces that we treat everyone with dignity and respect. It
also reiterates LLAOL’s commitment to adhering to human rights legislation.

2. Whistleblowing Policy: This policy applies to all employees of the Group as well as contractors and consultants. It aims to encourage staff to report any suspected wrong doing and provides an independent and confidential route for reporting any concerns in the workplace. This policy was reviewed in May 2023 and changes were made to the whistleblowing hotline to ensure clarity
on the purpose and use of the hotline. The whistleblowing details have also been added to LLAOL’s internal weekly newsletter to make these details more visible to staff.

3. Equal Opportunities, Inclusion and Dignity at Work Policy: This sets out LLAOL’s commitment in providing equal opportunities in employment and avoiding unlawful discrimination in employment and against customers. Our Equality, Diversity and Inclusion strategy was launched on 1 January 2023 following a diversity and inclusion audit carried out in September 2022.

4. Procurement Policy: This policy sets out LLAOL’s ethics of striving to purchase goods and services that are produced and delivered under conditions which do not involve abuse or exploitation.

5. Anti-Bribery, Corruption and Conflicts of Interest Policy. This policy was updated in October 2022 and together with updates to our Code of Conduct, replaced our Business Ethics Policy. It reiterates LLAOL’s position of conducting its business to the highest legal and ethical standard.

We have continued to issue all new staff with our ‘One Team, One Plan’ staff handbook setting out our mission, vision, and values. ‘Our people’ are a key focus in this strategy and inclusivity forms part of our values. The strategy within the handbook includes developing an empowering environment for employees to thrive and to develop an approach to diversity and inclusion in
which people feel safe to truly be themselves in the workplace..

OUR SUPPLY CHAINS

Our supply chains include companies providing the services, supplies and works required to run an international airport.

We require our key suppliers to comply with the Modern Slavery Act 2015. Many of our suppliers are obliged to issue their own modern slavery statement under the Act.

We also require all our operators at the airport to comply with our policies relating to ethics and anti-slavery.

Our standard contracts also require our suppliers to attend supplier review meetings where any compliance issues can be raised by either party. Suppliers are asked to provide a statement of compliance on our request.

Suppliers are to report any incidents of actual or suspected human trafficking in their supply chains, and are subject to audit at any time.

Any new contracts we enter into with operators at the airport, including retail concessionaires, are subject to the same obligations set out above.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

As part of our initiatives to identify and mitigate risk, we carry out the following:

Procurement

We include the following statement in our procurement processes with potential suppliers:

“Modern Slavery Act: London Luton Airport Operations Ltd has a zero-tolerance policy towards human trafficking and modern day slavery. As such, we do not and will not support any business who does not comply with the Modern Slavery Act 2015. By participating in this bid you are confirming that your company is fully compliant with this. Failure to adhere to this will result in your Bid being rejected and possible exclusion from future business.”

In our invitation to tender documents, bidders are required to confirm that staff and sub-contractors are treated in a fair and ethical manner.

From time to time, our Procurement team also provide training to local businesses to help them understand the standards they should obtain to be a LLAOL supplier. This training was carried out in March and November 2023 with more than 100 businesses in attendance in total. Another training session is planned for April 2024.

Our Procurement team also regularly provide internal training to existing staff and new starters on our procurement and tender process.

Members of our Procurement team have recently achieved Chartered Institute of Purchasing and Supply (CIPS) Corporate Ethics accreditation which lasts until July 2024. Part of the accreditation included modern slavery training. Members of the team intend to achieve this accreditation again after its expiry.

Our Procurement team was also recognised for their commitment to social value at the 2023 UK GO Awards where they won the Social Value Award and the GO Excellence Award. The Procurement team also received the ‘Highly Commended’ team of the year recognition at the 2023 UK GO Awards.

Staff

The majority of our workforce is employed and all new starters and contractors go through a rigorous vetting process. We have a procedure whereby we check and reference all employees. This includes face to face interviews, checking their identification and rights to work documentation and we also carry out a comprehensive 5-year background check. Where any
temporary staff are recruited, contracts with suppliers oblige them to undertake statutory right to work checks. Our vetting process for all security staff and the process for issuing passes at LLAOL are audited by the CAA each year.

Entry into the UK

We have continued to work with A21 Campaign Limited, a charity focused on ending slavery. A21 Campaign Limited have provided us with posters to be displayed in our toilet cubicles at the airport. This will help raise awareness to tackle modern slavery and human trafficking at the airport. Our Guest Experience and Chaplain Teams continue to work closely with Border Force at the airport on modern slavery, often supporting conversations with minors and vulnerable adults when necessary. Border Force at the airport conduct their own activities with relevant bodies which we input to.

TRAINING

Our online training module on modern slavery which was developed in 2022 has now been rolled out to all existing and new corporate staff.

Our airport security officers undergo mandatory security training at the start of theiremployment at LLAOL. During this training, our airport security officers are given the opportunity to ask questions and discuss the content of our Code of Conduct policy.

In September 2023, we also launched an online training module on LLAOL’s Code of Conduct policy which is available to all our corporate employees.

Following the launch of our Equality, Diversity and Inclusion Strategy in January 2023, all senior leaders, members of the HR team and hiring managers have undertaken training on topics such as Inclusive Leadership, Conscious Inclusion, and Hiring Inclusively.

FURTHER STEPS

1. We will continue to raise awareness of modern slavery through our online modern slavery training available to all corporate staff and new starters.

2. We will continue to review relevant employment policies throughout 2024 to ensure inclusivity and fairness.

3. We will continue to provide training to local businesses to help them understand the standards they need to obtain to be a LLAOL supplier, including having measures in place to tackle human trafficking and modern slavery in their business.

4. We will continue to work with our charity partners to raise awareness of modern slavery and human trafficking at LLA.

This statement outlines the steps we have taken and will take to ensure that slavery and human trafficking is not taking place in any part of our business and supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and it constitutes our Group’s slavery and human trafficking statement for the financial year ending 2023.