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 London Luton Airport 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. LLAOL 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 wrongdoing and provides an independent and confidential route for reporting any concerns in the workplace. The whistleblowing details are also included in LLAOL’s internal weekly newsletter to make these details more visible to staff. In 2024, LLAOL extended the hotline so that anyone (not just LLAOL staff) can use the details for whistleblowing reporting.
  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 and is still being implemented.
  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 reiterates LLAOL’s position of conducting its business to the highest legal and ethical standard. It was updated in October 2024 to include further guidance on ensuring LLAOL staff continue to conduct business with the highest legal and ethical standard.

We have continued to issue all new staff with our staff handbook which was updated in 2024 and renamed “People Guide”. The People Guide sets out our mission, vision, and values and now includes details on how colleagues can raise concerns about wrongdoing or unprofessional conduct in the workplace. It encourages colleagues to speak up if they have any concern regarding unethical activity.

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 documents 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. The last training was carried out in November 2024 with 35 businesses in attendance. Another training session is planned for 2025.

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 attained the Chartered Institute of Purchasing and Supply (CIPS) Corporate Ethics accreditation which was in place until 20 December 2024. The team successfully renewed the accreditation in early 2025. Part of the accreditation includes modern slavery training to the Procurement team.

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 anti-slavery posters which are displayed in our toilet cubicles at the airport. This helps 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

We have continued to roll out our online training module on modern slavery to all existing and new corporate staff.

Our airport security officers undergo mandatory security training at the start of their employment 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. This mandatory training for new security officers also now includes modern slavery training, and this training has been rolled out to existing security officers also.

Our online training module on LLAOL’s Code of Conduct policy which is available to all our corporate employees is ongoing.

Further Steps

  1. We will include modern slavery awareness training as part of our procurement training to existing and new starters.
  2. We will continue to raise awareness of modern slavery through our online modern slavery training available to all corporate and security staff and new starters.
  3. We will continue to review relevant employment policies throughout 2025 to ensure inclusivity and fairness.
  4. 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.
  5. 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 2024.

Signed by

Approved by the Board of Directors of London Luton Airport Holdings III Limited

on 7 March 2025.