HUMAN RIGHTS

Air France-KLM respects human rights and supports protection of it, combats corruption and explicitly opposes all forms of child and forced labor.

Our standards are based on accepted international norms, including the UN Global Compact, the OECD Guidelines for Multinational Enterprises, the Core Conventions of the International Labor Organization (ILO) and the Children’s Rights and Business Principles.

We have policies on respect for international human rights, anti-corruption and bribery. As required by the UK’s Modern Slavery Act, Air France-KLM published a statement on the websites of Air France and KLM.

With this timeline, we explain the steps that Air France-KLM has taken over the past 15 years towards respecting human rights. It shows how we move from endorsing internationally accepted standards to putting this into practice.

Human rights for our employees

Since 2006 and 2008 respectively, Air France-KLM introduced its CSR Statement and the Social Rights & Ethics Charter. The Social Rights & Ethics Charter affirms the Group’s commitment to fostering a climate of trust and mutual respect in the workplace.

These values and rights are the foundation for social, economic and cultural cohesion within each company and within the Group. The Air France-KLM Group’s employees have the right to work in an environment in which there is respect and care for their health, safety and dignity, and in which social dialogue is possible. The charter applies to employees of Air France, KLM and of their subsidiaries.

Currently, Air France-KLM is working on amending the Social Rights & Ethics charter by integrating its human rights policy. It is our objective to come to a policy document that formulates not only the rights of our employees and the employees of our suppliers but also gives direction for execution and implementation, including risk assessment. We have embarked on this journey together with the European Works Council, aiming to have an approved policy before the end of 2019.

The Group already has a thorough process in place to identify and manage risks related to the health and safety of employees. We also execute audits to secure health and safety of our employees worldwide.

To create a good understanding of the way in which we protect the human rights of our employees, an overview was created of the policies and procedures we have in place for employees in France and the Netherlands per relevant human right. The overview includes the legislative basis, internal policy documents, the complaints procedures, compliance operating mechanisms and process owner, for the following human rights: Privacy, Equality / Non-discrimination, Decent working conditions, Employee health, Employee safety, Labor relations and Child labor / Forced labor. Currently, we are refining and specifying our risk mapping process for employees on regarding human rights.

Human rights in our supply chain

As a sustainable group, we are mobilized to make our suppliers join us in this commitment, based on a shared set of values and principles. As a means to ensure commitment to our principles we expect our suppliers to agree with our sustainable development charter and our Supplier Code of Conduct. Currently, 67% of the suppliers have signed the sustainable development charter or have provided an equivalent document. We have set a target of 70% for 2019. In our contracting we retain the right to ask for sustainability assessments through the services of EcoVadis. These assessments are a key element, especially for the higher risk suppliers to help us manage and monitor compliance of our suppliers.

To determine the level of risk of our suppliers, we use a Supplier Risk Mapping tool. This may result in the decision to ask certain suppliers to take part in a sustainability assessment. These assessments may be followed or replaced by on site audits of our suppliers. The number of companies whose CSR performance was evaluated on EcoVadis increased by 9% in 2018, from 325 to 355. Furthermore, as part of a continuous improvement process, in 2019 the company’s goal is to evaluate 50 additional suppliers. In 2018, 55 “high risk” suppliers flagged by the risk mapping process were evaluated.

Suppliers that are not in compliance with our requirements are encouraged to improve and demonstrate their compliance after the implementation of their corrective actions. Air France-KLM communicates to its suppliers that their sustainability performance and level of compliance can be a part of our procurement decisions.

We have a Sustainable Procurement Policy in place for our employees, which we have recently updated. Focus is now being put on communication so as to activate a broader supplier compliance. We aim to train our procurement team and make them aware about external laws and regulations as well as our internal sustainability policy.


BUSINESS ETHICS

Context and strategy

The prevention of bribery and anti-competitive behavior is an important factor in fair business practice. As unethical or inappropriate behavior can have considerable negative consequences, preventing unfair practices is of key importance.

We are committed to conduct business with loyalty, fairness, transparency, honesty and integrity, and in the strict respect of the anti-corruption laws in all the countries where we operate.

  • Our Anti-Bribery Manual serves as a code of conduct for all employees and establishes the guidelines for preventing corruption and for identifying and handling risk situations with regard to the anti-corruption legislation.
  • In addition to the Anti-Bribery Manual, a Gift and Hospitality Policy has been introduced. This Policy aims to provide clear guidelines for staff, including financial limits, on giving and receiving gifts and hospitality.
  • Both the Anti-Bribery Manual and the Gift and Hospitality Policy document are available to all staff in three languages.

In terms of anti-competitive practices, we maintain our policy aimed at the prevention of anti-competitive acts by circulating a Competition Law Compliance Manual.

The KLM Group has implemented a KLM Code of Conduct which contains an overview of the rules governing the KLM Group’s business conduct and suppliers working with the KLM Group. The areas covered are safety, business integrity, social responsibility and reporting on violations.

Measures and action plans

New legislation or requirements, relating, for example, to anti-bribery or data privacy are taken into account when establishing the compliance programs, and are given additional emphasis via awareness-raising campaigns.

The Compliance Officers within Air France-KLM, Air France and KLM are tasked with pursuing the implementation of the Compliance programs within the Group. They are supported by a network of compliance representatives in the subsidiaries.

Topics that require greater awareness and transcend businesses, like the prevention of bribery and anti-competitive behavior, are brought to the attention of employees.

  • These awareness-raising campaigns are supplemented by dedicated training that is available to individual employees.
  • Employees can always raise questions or concerns with the Compliance Officers and legal experts.
  • Following the anti-bribery e-learning training campaign at the end of 2017, efforts have been made to further strengthen the anti-bribery awareness and knowledge of staff through, for example, information meetings and discussions, improved access to compliance documents, and communication by the Group’s general management.

Whistleblowing procedures:

Since all employees are required to respect these rules, employees in all the Group’s entities are encouraged to discuss any compliance concerns with their line managers. They can also contact a Compliance Officer directly.

Employees also have the opportunity to report on a problem through whistleblowing procedures. These procedures include the possibility of reporting any serious situations relating to the duty of vigilance (human rights, fundamental freedoms, health and safety, environment), pursuant to the legal requirements. Reports under the whistleblowing procedures are being investigated and appropriate corrective actions are taken and implemented.


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