Code of conduct
Sydney Airport’s Code of Conduct sets the standards for how we work together. It helps to guide decision making and ensure we put ethical and responsible behaviour in to action every day. It also contains guidelines for how we report any instances of unethical conduct.
Sydney Airport has no tolerance of fraud, bribery or corruption. Our Fraud and Corruption Control Policy is part of Sydney Airport’s risk management framework and sets out key principles that must be adhered to in relation to fraud, bribery, corruption, facilitation payments and political donations. The policy is consistent with our Code of Conduct and Whistleblower Policy.
We do not make donations to political parties or candidates for elections. However, like many other large organisations, we do pay to attend events organised by political parties or events at which a political representative may be speaking. Requirements with regards to political donations are set out in our Code of Conduct.
As an ASX-listed company, we strive to be open and transparent in all our dealings with investors, the public and other stakeholders. As part of this commitment, we voluntarily adopted the Tax Transparency Code in 2016 and publicly release an annual Tax Governance Statement. This statement seeks to provide a greater understanding of our tax structure and tax governance policy.
Our Whistleblower Policy provides our people, suppliers, service providers and other stakeholders an avenue to raise concerns about actual, suspected or anticipated wrongdoing in a way that offers protection from reprisal or disadvantage.
People wishing to raise a concern can do so via Sydney Airport’s whistleblower hotline HALO, which is accessible 24/7. They can also make reports to authorised people within the business including the General Counsel, members of the Executive Leadership Team or the General Manager of Human Resources, who is also the Whistleblower Protection Officer. Reports can be made anonymously, and people who report concerns will be supported and protected from reprisal or detriment.
Our Supplier Code of Conduct includes information for suppliers to report concerns about illegal, unethical or improper conduct via HALO.
Fraud and corruption control
Sydney Airport has no tolerance for fraud, bribery or corruption in any parts of its business.
The Fraud and Corruption Control Policy sets out key principles in relation to fraud, bribery, corruption and political donations, and bans facilitation payments. The policy is part of Sydney Airport’s risk management framework. It is a tool which assists in identifying key principles that must be adhered to in relation to fraud, bribery, corruption, facilitation payments and political donations. It is consistent with, and is supported by, Sydney Airport’s Code of Conduct, Gifts and Benefits Policy and Whistleblower Policy.
Sydney Airport is committed to participating responsibly, ethically and openly in the development of public policy and decision-making processes.
Employees must obtain prior approval from the Chief Executive Officer for involvement in any business-related event which is organised by or on behalf of a political party or candidate where a payment or an attendance fee is required.
Disclosure of these events will be made publicly as part of Sydney Airport’s annual reporting and lodged with the relevant political donation regulatory bodies.
Otherwise, no political donations, cash or in-kind contributions may be made by or on behalf of Sydney Airport to any political party, government official, political candidate, official or party in Australia or overseas.
We are committed to supporting the protection of human rights. In meeting our commitment we are guided by the UN Guiding Principles on Business and Human Rights, the International Bill of Human Rights (including the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights) and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. Our Human Rights Policy sets out this commitment.
Modern slavery is a key human rights risk, both in operations and supply chains. Sydney Airport is committed to ensuring it is not doing business with individuals or companies who knowingly profit from modern slavery.
We have a number of controls in place to manage the risk of modern slavery in our business, including our Supplier Code of Conduct (see Procurement below). We continue to review and strengthen these risk controls. Sydney Airport is required to submit a modern slavery statement to the Commonwealth Government under the Modern Slavery Act 2018 in 2021. Our latest statement can be found here.
Our Procurement Policy sets out core principles and the expectations of Sydney Airport’s people when conducting market engagements and in general dealings with suppliers. The Policy is underpinned by our Strategic Sourcing Framework and Sustainability Supply Chain Management Framework. Our Supplier Code of Conduct sets out how we manage our relationships with suppliers and the minimum expectations we set for suppliers to Sydney Airport. Key areas of focus include safety and wellbeing, corporate governance and ethics, workplace conditions and human rights, environmental management and community.
Sydney Airport’s approach to ethical and responsible decision making is also outlined in our annual Corporate Government Statement.