Modern Slavery Statement

Modern slavery refers to the offences of human trafficking, slavery, servitude and forced or compulsory labour. This can be considered under five headings: 

• The sexual exploitation of adults 
• The trafficking of adults into conditions of labour exploitation 
• The trafficking of adults into conditions of criminal exploitation 
• The trafficking of minors into conditions of sexual, criminal or labour exploitation 
• Other forms of exploitation 

Human trafficking involves the recruitment, transfer or obtaining of an individual through coercion, abduction, fraud or force to exploit them.  Although human trafficking often involves an international cross-border element, it is possible to be a victim of modern slavery within your own country.   

Modern slavery includes victims who have been brought from overseas and vulnerable people who are forced to work illegally against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing. 

The policy of Emerald Airlines is to conduct all of our business in an honest and ethical manner, and to comply with all applicable legislation.  We strive to ensure that neither modern slavery nor human trafficking supports our supply chain or our businesses; this objective is implicit in our policies and procedures.  We have a zero-tolerance approach to violations of anti-slavery and human trafficking laws.      

All employees have an obligation to report knowledge or suspicion of slavery or human trafficking.  Any suspicion is to be immediately reported to their Manager and the Head of People & Culture, who will decide what further action is deemed necessary.  These provisions do not replace any legal reporting or disclosure requirements.  Where statutory reporting requirements and procedures exist, these must be fully complied with.   

We have procedures in place to ensure robust recruitment processes including ‘right to work’ document checks, criminal checks, reference checks, personal data checks and contracts of employment. 

Emerald Airlines acknowledges the risk that a supply chain may involve the use of a hidden or unknown subcontractor reliant on forced labour. Although we consider the risk of modern slavery to be low, we take responsibility to combat modern slavery seriously as demonstrated by its implementation of the following policy measures:  

• The prevention, detection, and reporting of modern slavery in any part of the business or supply chains is the responsibility of all those working for Emerald Airlines.   
• Appropriate due diligence processes must be carried out in relation to modern slavery which may include considering human rights in a sector or country, the type of sector in which a service provider operates, the countries from which services are provided, the nature of relationships with suppliers, and the complexity of supply chain(s).   
• All supply chain lines need to be continually risk assessed and managed in relation to modern slavery and any high-risk suppliers audited.  
• Emerald Airlines encourages anyone to raise any concerns about modern slavery to their manager of Head of People & Culture.   
• Wherever possible, Emerald Airlines will obtain warranties from suppliers that they are free of modern slavery (which can be passed on to subcontractors).   

Our approach to modern slavery and human trafficking risk will continue to evolve and we will continue to mitigate these risks through the provisions mentioned above. 

Any breaches of this policy may result in Emerald Airlines taking disciplinary action against individual(s) and/or terminating its relationship with any organisation or supplier.