A Safety, Environmental and Labour rights Guide for Suppliers to British Airways Introduction The relationship between British Airways and its Suppliers is crucial in achieving our Mission of providing Service that matters for people who value how they fly. Procurement plays an integral part in fulfilling our Corporate Mission, by ensuring that all goods and services provided to British Airways are of the highest quality, without compromising on safety and by complying with relevant industry regulations and requirements. This has been prepared for Suppliers as a guide in order to enable all contracts for British Airways to be carried out efficiently and safely aiming to minimise environmental and social impact for all concerned. This guide only addresses the issues of Health and Safety, Data Protection, Environment, Business Continuity and Labour Rights. The UK legislation on which this guide is based represents the minimum worldwide British Airways standards. Suppliers outside the UK must also ensure compliance with local legislation. If there is a conflict between the British Airways standard and local legislation, the legal requirements of the local jurisdiction must take precedence. If there are such conflicts, please contact your British Airways Representative. Disclaimer This document is provided for guidance purposes only to facilitate the current and any future relationship with British Airways, and is not intended to be contractually binding. It is supplemented to, and is not a substitute for, any contractual arrangements you have with British Airways. In no way does British Airways represent or warrant that compliance with the guidelines contained herein will result in the fulfilment by the Supplier of any regulatory or statutory obligations, or that said compliance will reduce or increase the Supplier s actual or potential liability in any present or future action that may be brought against it, including without limitation any action in tort, negligence, or personal injury. Definitions Supplier This term refers to contractors, operators of hired equipment, or any person who may be working on premises owned or controlled by British Airways or on other premises engaged in work relating to British Airways. Supplier Guide 1 08/07/04
British Airways Representative This term refers to any Representative of British Airways or agent thereof who has been nominated to co-ordinate the activities of Suppliers. Risk Assessment A Risk Assessment evaluates relevant hazards and risks and identifies the control measures required to reduce exposure. 1.0 General Safety Requirements 1.1 Contract Management. A service supplier to British Airways should submit and keep updated the following: Company Safety Policy Document or equivalent appropriate to the contract A work plan detailing how the activities will be carried out Risk Assessments covering all work to be carried out for British Airways Copies of Workplace Inspections Business Compliance Questionnaire Before any contract has commenced, a responsible and competent manager representing the Suppliers must discuss the safety requirements and associated documentation, eg Risk Assessments, method statements with the appointed British Airways Representative. It is expected that all persons employed will be appropriately qualified to carry out the requirements of the contract. The Supplier shall be responsible for maintaining accurate records to verify that all current employees and any subcontractors are suitably trained and competent to undertake the duties for which they are employed. Suitable records should also be maintained for vehicles and equipment, which should as a minimum, provide evidence that they comply with local legislation requirements and are maintained in accordance with manufacturers specifications. The Supplier may be required to produce the record of inspection for a British Airways Representative. The Supplier is responsible for the direction; management and control of other Contractors, Sub-contractors and other Suppliers that he chooses to employ and must advise the British Airways Representative of their use. Supplier Guide 2 08/07/04
The Supplier should refer to their contract for specific contractual requirements. 2.0 Airport and Cargo Operations Ground/Cargo/Passenger Handling Agents must ensure they act in accordance with British Airways corporate requirements as outlined in the appropriate manual eg Ground Operations Manual, British Airways World Cargo Standard Operating Procedures, Customer Service Manual. 3.0 Service Suppliers Safety Policy 3.1 Access Controls British Airways employs strict security procedures throughout its buildings. Airport authorities also impose strict access limitations. Your British Airways Representative should arrange the appropriate access. If a security pass is required this must be displayed at all times whilst on British Airways and airport premises and kept secure when not in use. Security passes must be returned at British Airways request. Failure to follow security procedures will be treated seriously and may result in the withdrawal of the security pass. Lost passes must be reported immediately. 3.2 Dangerous Substances The use and bringing of dangerous substances onto the airport or any British Airways premises is strictly forbidden unless prior authorisation has been granted. 3.3 Drugs and Alcohol British Airways operates an Alcohol and Drugs policy. A copy will be provided to Suppliers. Suppliers will be expected to produce and ensure compliance with this policy for all the Supplier s workers assigned to British Airways work. 3.4 Smoking British Airways operates a non- smoking policy in all buildings. Smoking is not allowed in any buildings unless in a designated area. 3.5 Radios If the contract involves the use of radios for company communications at or in the vicinity of an airport these should only be used in accordance with Airport By-laws. Supplier Guide 3 08/07/04
4.0 Protection Of Personnel 4.1 Personal Protective Equipment and Clothing (PPE) The Supplier shall ensure that appropriate items such as high visibility clothing, hearing protection, hard hats and safety footwear as determined by Risk Assessments or local legislation or British Airways requirements. Employees working on and around an aircraft stand must wear high visibility clothing, hearing protection and safety footwear at all times. 4.2 Accidents and Incidents All accidents, near misses and dangerous occurrences, which take place in the course of the British Airways contract, must be reported to the British Airways Representative or where appropriate to the local authority. It is a British Airways corporate requirement that all Suppliers maintain an accident reporting procedure. The Supplier will investigate all incidents and take the necessary action to prevent a recurrence. British Airways reserves the right to undertake its own investigation into any accident/incident involving Suppliers in the course of the British Airways contract. British Airways expects the co-operation of Suppliers should an investigation be necessary after an accident. The Supplier will provide regular Safety Performance Reports and meet with the British Airways Representative on a regular basis to discuss safety performance. The British Airways Representative will provide the Supplier with details of the information to be provided and the frequency. 5.0 Protection Against Fire The service supplier shall ensure that all statutory fire requirements, British Airways requirements and airport directives as applicable are complied with at all times. 6.0 Data Protection Where the service supplier processes personal data (information relating to a living individual) under instruction from British Airways, such processing is subject to the UK Data Protection Act (1998). Under this Act, the service supplier (defined as a data processor ) must provide sufficient guarantees of the security measures they take with regard to personal data and expect that these measures be monitored by British Airways (defined as the data controller ). Suppliers must also carry out the processing of personal data under a written contract with British Airways, which ensures they act only on instructions from British Airways and Supplier Guide 4 08/07/04
comply with the same security requirements, which are imposed on British Airways. If the Supplier wishes to subcontract any processing of personal data, it must obtain prior written consent from British Airways and the subcontracted company will also be subject to the above requirements. Data Protection Definitions Data is any data held by British Airways, which is transferred or disclosed by or on behalf of British Airways and any data which is obtained or collected on behalf of British Airways. Data may be held or processed on a computer, any other automatic system, or possibly in manual form (for certain structured filing systems). This will include central computers, mini computers, PCs, digital recording systems, CCTV. Personal Data is data about a living individual who can be identified directly or indirectly from that data. Processing is any activity carried out on personal data, from its collection through to its destruction, and includes holding the data. Data Controllers are persons, organisations, societies etc. who control the content and use of personal data. Data Processors are any person (other than an employee of the data controller) who processes personal data on behalf of the data controller. 7.0 Environmental Guide 7.1 Contract Management A supplier to British Airways should submit and keep updated the following: Environmental policy General Environmental Requirements Supplier should provide evidence that they comply with local legislation requirements for environmental management. Accidents/Spillages The Supplier shall notify British Airways of any significant environmental incident such as a fuel or chemical spill. The Supplier shall have in place a documented procedure for the clean up and reporting of an environmental incident. Supplier Guide 5 08/07/04
Water Suppliers should not discharge any wastewater without the appropriate discharge consent. Waste Supplier should be aware of British Airways policy to prevent and reduce waste. The Supplier is strictly forbidden to bring any waste onto the airport or any British Airways premises. All waste should be segregated and disposed of in the appropriate facilities, according to the type of waste. Any recyclable waste must be segregated and deposited in the appropriate facility, for e.g. paper. Energy Supplier should be aware of British Airways policy to reduce energy consumption. All lights must be switched off when leaving rooms/premises. Emissions The Supplier should be aware of our commitment to reduce emissions, limit our contribution to global warming and improve local air quality. The supplier shall ensure that any vehicle on airport or British Airways premises is not left running at any time when not in use. Suppliers are expected to drive responsibly, keep to speed limits, keep own vehicles well maintained and avoid unnecessary heavy accelerations and braking observe good practice. Airside vehicles must meet the current Operator Standing Instructions and to use emission abatement technology, preference is to have EURO II engines or greater. Suppliers should not use HFCs or HCFCs, ozone depleting substances for refrigerants. Noise The Supplier should be aware of our commitment to reducing nuisance to local communities. The Supplier should endeavour to keep noise levels to a minimum whilst on or travelling to airport or British Airways premises. 8.0 Business Continuity It is a British Airways corporate requirement to ensure that all areas within the company are resilient and able to respond to sudden or unexpected interruptions to normal activities. A supplier to British Airways should establish and maintain Business Continuity Plans that include the following: Denial of access to building Loss of systems Loss of key staff Supplier Guide 6 08/07/04
Copies of such plans should be made available to the British Airways Corporate Business Continuity team on request for audit purposes. British Airways expects suppliers to support the company in the activation or testing of British Airways Business Continuity Plans. Any supplier who has critical suppliers of their own should ensure that they are equally resilient. 9.0 Labour rights General Conditions 1. Suppliers shall comply with the laws of their respective countries and regions as well as all other applicable laws, rules and regulations including but not restricted to those governing labour rights, health & safety and environmental protection. 2. Suppliers shall allow British Airways access during normal business hours on any business day, by appointment, to audit, copy and reproduce the books, records, correspondence, instructions, receipts and memoranda of every description relating to these standards. 9.1 Child Labour 1. Suppliers shall only employ staff above the age of 15 or the local legal minimum age. All applicable laws and regulations governing the nature and amount of work performed by those above the minimum working age and under the age of 18 shall be followed. 2. Employees above the minimum working age and below the age of 18 shall not be engaged in hazardous work. This can be defined as any type of employment or work that by its nature or the circumstances in which it is carried out is likely to jeopardise the health, safety or morals of the employee. Locally applicable child labour laws shall be observed at all times. 3. Suppliers shall maintain official documentation of all employees including date of birth. 9.2 Equal Opportunities and Diversity 1. Suppliers shall hire, employ, train and promote staff without regard for race, colour, gender, disability, sexual orientation, marital status, religion, political opinion, national extraction or social origin. 2. All terms and conditions of employment will be based on one s ability to perform his her or her job without regard for race, colour, gender, disability, sexual orientation, marital status, religion, political opinion, national extraction or social origin. 9.3 Freedom of Association & Collective Bargaining Supplier Guide 7 08/07/04
1. Suppliers shall not interfere by way of threat, intimidation or penalty with their employees right to join any labour union, organisation or affiliation of their choosing. 2. Suppliers shall not interfere with an employee s right to lawfully and peacefully collectively bargain, assemble, associate or demonstrate. 3. Employment terms should not require non-union membership or withdrawal from union membership. 9.4 Forced Labour Suppliers shall not use any form of forced labour including prison, indentured, indebted bondage labour. All employees will retain the right to voluntarily terminate their employment after reasonable notice. 9.5 Wages, Benefits and Working Hours 1. Employees shall be paid wages that meet, at a minimum, national legal standards. Wages should always be enough to meet basic needs and to provide some discretionary income 2. Employers shall provide, at a minimum, all legally required employment benefits and leave entitlement. 3. All suppliers that are subject to European law shall abide by the European Working Time Directive with respect to working hours, overtime hours and rest days. 4. Outside the remit of the EU WTD, working hours and overtime shall not be excessive and shall comply with national laws. Employees will be allowed on average 1 rest day in 7. 5. Employees shall be paid no less than the legally required overtime premium for all overtime work performed. 6. Employees shall retain the right to decline overtime without any threat of penalty, discipline or dismissal. 7. Employees shall receive a wage statement at the end of each pay period that adequately explains the wage and benefit calculations. 9.6 Harassment and Bullying/Dignity at Work Every employee shall be treated with respect and dignity. No employee shall be subject to any physical, sexual, psychological or verbal harassment, abuse or discipline or other form of intimidation. Questions or Comments If you have any questions or comments solely relating to this guide please contact Business Compliance Manager Mr e-mail: sunil.1.chadha@britishairways.com Supplier Guide 8 08/07/04