Slavery and human trafficking statement

Our business

SITA is the world's leading specialist in air transport communications and information technology. We operate globally, and our commitment to ethical, fair, and responsible business is fundamental to everything we do. For more information about our corporate structure, our products and the context of our global presence, see our corporate website.

We recognize the immense human cost of modern slavery and human trafficking, and we are committed to taking meaningful steps to help eradicate it. As a signatory of the United Nations Global Compact (UNGC), we align our strategies and operations with the Ten Principles on human rights, labor, the environment, and anti-corruption. For more information on this, refer to our 2024 Impact Report, 2023 Sustainability Report and the Sustainability section of our corporate website. Our Codes of Conduct¹ also define our expectations in addressing the risk of modern slavery and human trafficking.

Our supply chain

We understand that our responsibility extends across our supply chain. Our suppliers are expected to conduct business ethically and sustainably, including maintaining and promoting ethical and lawful labor practices. In 2024, approximately 90% of our expenditure was directed to 463 suppliers, but we collaborate with a diverse and global base of providers.

In Q1 2025, we started implementation of a new digital procurement management tool that enhances our visibility and oversight across a broad spectrum of criteria, including suppliers’ actions and policies related to labor rights and modern slavery risks. This tool will support more systematic assessment and engagement with suppliers, reinforcing our expectations on human rights and sustainability performance.

Standards and controls

All suppliers are expected to comply with the SITA Supplier Code of Conduct, which outlines expectations on labor rights, ethical conduct, and sustainability. In addition to existing screening and self-assessment requirements, our procurement processes are now supported by enhanced ESG evaluation capabilities through our new sustainability tool.

We continue to apply robust due diligence in supplier selection and contract management, governed by our Global Purchasing Policy, systems and controls and aligned with our broader sustainability and risk frameworks.

Our standard supplier Terms and Conditions set out the requirements for suppliers when supplying SITA, and they refer to the SITA Supplier Code of Conduct, our expected behaviors and ways of working.

Our SITA Code of Conduct and relevant corporate policies are periodically reviewed and revised to reflect the latest best practice of good corporate governance.

Human rights and governance updates

Additionally, we have taken steps toward developing a Human Rights Charter. The Charter, which will apply to SITA globally, including its owned and controlled subsidiaries, will further advance the integration of our operations and supplier relationships with international human rights frameworks, including the UN Guiding Principles on Business and Human Rights.

The Management has acknowledged modern slavery and human trafficking as a potential risk to SITA’s compliance and reputation. Such risk is recorded in the SITA Enterprise Risk Register. The risk scope includes SITA, its owned and controlled subsidiaries, and joint ventures. The Management monitors, implements and operates mitigating actions as well as assesses the latest posture of this risk as part of the quarterly Enterprise Risk Management (ERM) process. The outcome of the ERM reviews is reported quarterly by the Internal Audit and Risk Management (IA&RM) to the Audit and Risk Management Committee (ARMCom), a standing committee of the Board.

Training and awareness

Our employees receive mandatory training on responsible procurement and modern slavery as part of our Code of Conduct program. This training is a requirement for all new hires and needs to be completed annually for all staff.  Completion rates are tracked and reported to the SITA Management teams and ARMCom.

We also foster awareness through regular communications, webinars, and leadership messaging that emphasize our ethical commitments, including our unwavering stance against modern slavery and our acknowledgment of the duty our colleagues at SITA and our suppliers' staff must uphold human rights in our operations and in our supply chain.

Supplier monitoring and reporting

At the point of sourcing and supplier onboarding we conduct robust and applicable due diligence on certain suppliers. There are also formal controls and approval hierarchies for supplier contracts, spend and approving new suppliers. Once onboard, we continue to screen and monitor certain suppliers using, for example, digital screening tools.

To further enhance and mature our approach to supplier monitoring we are also progressing the following:

1. New procurement and supplier management tools implementation that includes focused CSR and ESG modules
2. Supplier Management framework refresh to better cover the important topic of modern slavery
3. SITA Code of Conduct review to provide more proactive controls, elevate expectations and to explore new ways to raise awareness of the associated risks in our extended supply chain.
4. Publication of a Sustainable Sourcing Charter to provide more guidance to the internal teams on our expectations and best practice.

We maintain an independent and confidential whistleblowing channel called RADAR, available to all employees, stakeholders, and third parties. We strictly prohibit any retaliation against those who raise concerns.

Approval

This statement is made in accordance with section 54 of the UK Modern Slavery Act 2015 and has been approved by SITA’s Board of Directors. It represents our position and activities related to modern slavery and human trafficking for the financial year ending December 2024.

David Lavorel

CEO

¹ Respective Codes of Conduct are detailed in the text.