In agreement with a responsible management approach, Fraport is committed to upholding the principles of nationally and internationally recognized standards of behavior:
In order to integrate them even further into the company, Fraport has adopted two Codes of Conduct: One for our employees and one for our suppliers. The umbrella for these voluntary commitments is Fraport’s Policy.
Unlike manufacturing companies, Fraport’s management does not focus on the supply chain, but on the quality of the services offered and the functionality of the infrastructure required for this. Irrespective of this, it is crucial that business partners and suppliers are selected carefully. The Group companies each have their own procurement management.
In Germany, Fraport AG compels business partners and suppliers to comply with its Supplier Code of Conduct as part of its General Terms and Conditions (AGB). The Supplier Code of Conduct details how to treat employees correctly, including compliance with human rights, environmental and climate protection, and integrity in the course of business, for example the prohibition of corruption and bribery. A violation of this code may result in the termination of the business relationship. A contractual penalty may be imposed and a claim for lump-sum damages may be raised in the event of antitrust violations and serious misconduct. Business partners and suppliers must also undertake to observe these principles in dealings with their own suppliers.
Fraport AG undertakes to focus on sustainability criteria when purchasing products and services. In addition, the company was one of the first in Hesse to sign a target agreement initiated by the Hessian Ministry of the Environment, Climate Protection, Agriculture and Consumer Protection in 2016. Consequently, social and ecological criteria are considered in purchasing decisions in addition to economic criteria.
Fraport AG has a heterogeneous requirement structure. Its requirements range from architectural services to the construction of entire buildings and maintenance of such buildings, from office materials to IT services and aircraft push-backs. The biggest part of the order volume was awarded to suppliers and service providers based in Germany, approximately 1% to those based in the EU and about 1% to those based in the US and Switzerland. As there are comparable legal standards in these countries, in particular in relation to respect for human rights and anti-corruption and bribery matters, the first level of Fraport AG’s supply chain is not deemed critical. Although orders with business partners and suppliers based outside the aforementioned countries seem insignificant in relation to the total order volume, of which they make up less than one percent, business relationships with suppliers from risk countries, known as the “Primary Impact Countries” (in accordance with the FTSE4Good Index), in particular require particular care. For this reason, an examination of the first level of the supply chain by contractors’ country of origin is an essential part of regular monthly reporting for the “Central Purchasing, Construction Contracts” central unit.
If contracts for product groups that include suppliers or service providers from risk countries are to be put out to tender and awarded, the potential contractors will be reviewed depending on the order value. This also applies to orders for work clothes, for example. The location of production sites is periodically checked. If a business relationship is started with a supplier from one of these countries, sanction lists are extensively checked in advance. Sanction lists are official lists of people, groups or organizations subject to economic or legal restrictions. If there are irregularities, further checks are planned which may result in the withdrawal of an order.
A separate procurement process via the Group company Fraport Ausbau Süd was defined for the Expansion South project, in particular Terminal 3 at Frankfurt, due to the size and complexity of the project. By submitting an offer in this procurement process, building companies are obliged to comply with all requirements in the Posted Workers Act (Arbeitnehmer-Entsendegesetz, AEntG) and the Minimum Wage Act (Mindestlohngesetz, MiLoG), to make contributions to the collective bargaining parties’ joint facilities, and also to only engage subcontractors or other third parties that meet these requirements. The Fraport Supplier Code of Conduct also forms part of any agreement.
A due diligence review process was defined for purchases made for the construction of Terminal 3, which has since been carried out depending on the order value. In addition to mandatory checking of sanction lists and company information, this includes extensive research online on potential business partners before business relationships are started.
The international Group companies must also comply with all components of the Group CMS policy. This applies in particular to large construction projects such as the new terminal at Lima Airport. In that project, compliance with the Fraport Supplier Code of Conduct is a mandatory part of the tender for the general contractor.
The Fraport Group has undertaken to comply with the most important internationally recognized codes of conduct – the principles of the UN Global Compact, the OECD Guidelines for Multinational Enterprises, and the Core Labor Standards of the International Labor Organization (ILO). In accordance with the values in the Fraport Code of Conduct, Fraport intends to operate in a socially, economically and ecologically sustainable manner. This responsibility is defined in the Code of Conduct for all employees. The same values are contained in the Fraport Supplier Code of Conduct. Fraport expects its suppliers and service providers to comply with the same standards.
Fraport rejects any form of forced or child labor. Among other things, the minimum age permitting full-time employment in compliance with the relevant national regulations is observed within the Fraport Group. The Code of Conduct and the Group Compliance Management System (CMS) policy are available to all employees on the internal information portals. In the course of semi-annual compliance reporting, the Executive Board is notified about the activities of the department dealing with compliance at the Fraport AG and the status of measures.
The certified electronic whistleblower system (BKMS® System) is an important tool for preventing and uncovering violations. Fraport has also engaged an external lawyer to act as ombudswoman for all of the Group’s employees as well as customers, suppliers, and other business partners. Her job is to receive, legally review and forward information about unlawful conduct that damages the company. An internal representative is also available to employees in Germany.
Regulations on working hours and complaints mechanisms, for example, are implemented in large financing projects, some of which are also demanded by external lenders. The Environmental and Social Action Plan (ESAP), which requires the implementation of a human resource policy as well as a management and a monitoring system, is, for example, a prerequisite for the financing of Fraport Greece (see the section “Notes on Reporting” in the Group management report). The plan applies not only to Fraport’s employees, but also to suppliers and subcontractors. The ESAP also regulates the conditions for employees along the supply chain in order to prevent, for example, suppliers from employing refugees under inappropriate working conditions.
Fraport supports the police where possible in pursuing and combating international human trafficking – for example at Frankfurt Airport by providing video material in certain justified cases. Before any data is exchanged, the relevant data protection officers are asked to review the data and approve the transfer. Furthermore, technical security systems were installed in cooperation with the German Federal Police and the German Customs Office. One example of this are ID card locks that prevent repeated use of the same ID card on doors within a short period of time. Wherever possible, check points for staff between Schengen and non-Schengen areas will be installed in close proximity to a border inspection post. In addition, there are clear guidelines for all ID card holders in the airport user regulations and the identification regulations as well as rules for abuse thereof up to the withdrawing of ID cards or access permissions.