Modern Slavery Act

Introduction and Scope

Aquila Air Traffic Management Services Limited (Aquila) considers that modern slavery and human trafficking is an international crime that inflicts unacceptable harm on vulnerable adults and children. Aquila is absolutely committed to preventing slavery and human trafficking in its corporate activities and to ensure that its supply chain is also free from slavery and human trafficking.

Aquila fully supports the principles of the UK Modern Slavery Act of 2015 (MSA) and is committed to its implementation. As an integral part of the provision of services and assets to Ministry of Defence (MOD) Air Traffic Management (ATM) Service Provision, Aquila acknowledges its responsibility to take a zero tolerance approach to slavery and human trafficking in accordance with legislation by adhering to supply chain, Human Resources, and other Aquila policies which incorporate preventive measures.


Aquila’s Business Scope

Aquila is contracted to supply military ATM capability, goods and services at all MOD-operated Marshall airfields and flying ranges in the UK and in permanent RAF bases overseas. Aquila also provides limited, ATM-related services to the UK windfarm industry.


Who is responsible in Aquila for ensuring compliance with MSA?

The Aquila Service Delivery Director is responsible for ensuring compliance to the MSA Policy and obligations under the MSA of the Procurement function and its supply base. The Service Delivery Director reports directly to the Aquila Chief Executive Officer.


How is Aquila implementing the MSA?

Internal Aquila policies

In early 2016, Aquila issued its Modern Slavery Act Statement and Policy. Aquila’s MSA policy includes the following:

  • A description of the principles of the MSA; 
  • A list of initiatives that Aquila has already implemented, and intends to maintain, to meet the principles of the MSA; and
  • A description of how Aquila complies with the MSA plus a number of policies which complement the MSA including the Whistleblowing Policy, Employee Code of Conduct and Recruitment Policy.

Awareness Communications of Aquila Personnel

Aquila has raised awareness of modern slavery and human trafficking issues by distribution of this policy and circulating emails to staff that explain:

  • The basic principles of the MSA;
  • How employees can identify and prevent slavery and human trafficking;
  • What action employees can take to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • What external help is available, for example through the modern slavery helpline.

To ensure Aquila prevents modern slavery activities within its own business, specific policies exist that comply with industry and best practice standards including:

  • Fair employment practices: Aquila has policies covering flexible working, maternity leave, and performance reviews. Aquila also offers a fair and competitive financial package for all our staff including an annual bonus, private healthcare and the option to select discounted benefits.
  • Prevention of harassment, bullying, and discrimination: Aquila has a policy on Anti-Harassment and Bullying as well disciplinary and grievance procedures. All employees have access to an Employee Assistant Programme which provides independent advice and counselling services should that be required.
  • Whistleblowing policy: By publishing to our employees our Whistleblowing Policy, Aquila encourages all its employees to report instances where they suspect practices that are of concern. The Aquila Whistleblowing policy is designed to make it easy for employees to make disclosures without fear of recrimination.
  • Code of conduct: Aquila’s code of conduct makes clear to employees the actions and behaviours expected of them when representing the organisation. Aquila strives to maintain the highest standards of employee conduct and ethical behaviour when operating in the UK or abroad and when managing its supply chain.
  • Recruitment policy: Aquila has a reputable single supplier resourcing partner who uses only reputable employment agencies to source labour and always verifies the practices of any new agency it may use before accepting workers from that agency. The resourcing partner is obliged to adhere to the Aquila Resourcing policy and through regular contract review is monitored for compliance with the MSA.

Customers and Supply Chain

Aquila’s customers are obliged to comply with the MSA, and are therefore obliged to highlight any practices they suspect may have human trafficking connotations to us directly. Other business partners are required to notify Aquila in accordance with their contracts, Aquila’s supply chain policy, ISO90001, environmental plans and under the requirements of the Public Interest Disclosure Act (PIDA).

Aquila’s Supply Chain department is responsible for investigations and due diligence in relation to any suspected instances of slavery or human trafficking within the supply chain. Aquila undertakes due diligence in the tender process when considering taking on new suppliers and regularly reviews its existing suppliers.

Aquila has raised awareness of modern slavery and human trafficking issues by distribution of this policy and circulating emails to staff that explain:

  • Ensuring suppliers are contracted to the appropriate commercial governance that requires compliance to the MSA;
  •  Regular audits through the supply chain on compliance to the MSA;
  • Evaluating the modern slavery and human trafficking risks of any new supplier;
  • Conducting supplier audits or assessments through Aquila's own staff or a third party auditor including ISO9001 auditing; and
  • Using details from an ethical supplier database, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular.

Performance indicators

Aquila has reviewed its Key Performance Indicators (KPIs) in light of the introduction of the MSA. The following relevant KPIs are in place:

  • A system for supply chain verification has been in place since 1 April 2015 whereby Aquila evaluates potential suppliers before they enter the supply chain; and
  • A system for reviewing its existing supply chain is in place whereby Aquila re-evaluates all existing suppliers at least annually.

Conclusion

Aquila has assessed its services and activities in the UK and overseas and considers its activities to carry a very low risk in relation to slavery or human trafficking. In reaching this conclusion Aquila has assessed both its own practices and the practices of its suppliers – an assessment which will be repeated throughout the lifetime of the business.