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The following statement is reviewed and signed annually in pursuant to section 54 of the UK’s Modern Slavery Act 2015.

Our business

SITA is a global provider of IT and communications solutions to the air transport industry. For more information about our corporate structure, see About SITA.

We fully recognise the issue of modern slavery and human trafficking and the emotional and physical impacts of this problem for individuals and communities. SITA takes its responsibilities concerning these issues seriously, and we are committed to doing business the right way – acting honestly, fairly, and with high standards of integrity.

We are proud to be signatories to the United Nations Global Compact (UNGC), a strategic policy initiative for businesses committed to aligning their operations and strategies with ten universally accepted principles in the areas of human rights, labour, environment, and anti-corruption. For more information on this, please refer to our Responsible business page.

Our supply chain

We know that responsibility goes beyond what we can do alone as a business and that our supply chain has an important part to play. We need our employees, suppliers and third parties to ensure they act in an ethical and sustainable manner when carrying out business on behalf of SITA and reinforce positive labour standards across supply chains.

Like many businesses, SITA has a complex supply chain that works with many suppliers around the world, of which 426 suppliers accounted for around 90% of our spend in 2020. Our supply chain includes key suppliers that provide IT software and hardware, professional and support services, and other service industries that support our business.

Our respective Codes of Conduct1 define our expectations in addressing the risk of slavery and human trafficking.

Standards and controls

We expect our suppliers to follow the SITA Supplier Code of Conduct which is available on our website. For specific goods and services, SITA expects suppliers to complete a self-assessment that enables us to track their performance in a range of areas.

In addition, our Purchasing Policy governs the purchase of all goods and services, providing details on both the selection criteria and the due diligence requirements on new and existing suppliers.

Our standard Terms and Conditions set out the requirements for suppliers when supplying SITA, and they refer to our Supplier Code of Conduct and the expected behaviours and compliance expectations.

Our SITA Code of Conduct and relevant corporate policies are periodically reviewed and agreed by our Executive Team.

Risk assessment

Our exposure to the risk of slavery and human trafficking has been acknowledged and is monitored in SITA’s Enterprise Risk Register. The register is reviewed quarterly by SITA’s Audit and Risk Management Committee, which consists of SITA’s Board Members.

SITA has selected a third-party supply chain evaluation platform to understand the level of risk in the countries where SITA and our suppliers operate and to capture information from key suppliers to SITA. This enables SITA to gain a better insight into the potential risks by supplier and location.

Training and communication

We provide mandatory online training around responsible procurement and on slavery and human trafficking for UK and procurement employees as part of our global compliance program. It is required for all new joiners and refreshed yearly. These training modules are also available to all SITA employees. Reports of completion are available to the Ethics and Compliance Office.

Beyond training, communicating the ethics and compliance message is accomplished through internal webinars, bulletins, websites, sales materials, and similar tools, all of which go hand-in-hand with a strong leadership tone.

Monitoring

The Purchasing Team monitor supply chains in cooperation with SITA’s Corporate Social Responsibility Office. Areas of concern are shared with the Ethics and Compliance Office, which oversees our ethics and compliance programs.

A confidential and anonymous whistleblowing process is available to all employees to raise any concerns they may have on issues related to human trafficking or slavery. SITA will not tolerate any form of retaliation against anyone who has raised a concern and/or assisted in an investigation in good faith. 

Approval

This statement is made pursuant to section 54 of the UK’s Modern Slavery Act 2015 and has been signed by a Director. This statement constitutes SITA's slavery and human trafficking statement for the financial year ending December 2020.

 

Barbara Dalibard
CEO

1SITA's Code of Conduct, SITA's Supplier Code of Conduct