AirTrunk supports all internationally recognised human rights understood, at a minimum, as those enshrined in the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights as well as the core international human rights treaties and the ILO Declaration on Fundamental Principles and Rights at Work.
Our approach has been developed with reference to the United Nations Guiding Principles on Business and Human Rights and the UN Global Compact.
Where national law and international human rights differ, we will aim to follow the higher standard; where they are in conflict, we will adhere to national law, while seeking ways to respect international human rights, to the greatest extent possible.
We are committed to conducting our business with respect for human rights. This means we will:
develop and implement internal control systems and procedures to identify, prevent and respond to human rights risks in our operations as well as in connection with our business relationships;
communicate how we address human rights risks internally and externally; and
continuously review and update this Policy.
2. Roles and Responsibilities
This Policy applies to AirTrunk Operating Pty Ltd and anybody corporate or entity related to either of them (“we“, “us” or “AirTrunk“). It sets out AirTrunk’s expectations of:
all individuals working for AirTrunk, including directors, officers, employees (whether full-time, part-time, casual or temporary, including interns and seconded employees), independent contractors, and any other person whose work is supervised by AirTrunk (“AirTrunk Personnel“); and
our Suppliers. “Supplier” means any person (other than AirTrunk or AirTrunk Personnel) providing goods or performing services to or on behalf of AirTrunk and acting in such capacity, such as consultants, advisers, contractors and subcontractors.
The AirTrunk Board of Directors has overall responsibility for ensuring this Policy complies with AirTrunk’s legal and ethical obligations.
The Head of Risk & Sustainability has primary and day-to-day responsibility for implementing this Policy, monitoring its use by AirTrunk Personnel, ensuring its effectiveness is regularly reviewed and dealing with any queries about it.
3. Our expectations
AirTrunk Personnel
AirTrunk Personnel must:
comply with all applicable national laws and regulations wherever we operate. Where national law and international human rights differ, you should aim to follow the higher standard; where they are in conflict, you should adhere to national law, while seeking ways to respect international human rights to the greatest extent possible;
read, understand and comply with this Policy and any relevant AirTrunk policies, including the Modern Slavery Policy, Sustainable Procurement Policy, Privacy Policy and, where applicable, Supplier Code of Conduct;
hold our Suppliers to the standards expected of them under relevant AirTrunk policies;
never knowingly engage in any activity that might lead to non-compliance with our policies; and
report concerns, known or suspected violations of this Policy.
Our Suppliers
Our Suppliers must comply with AirTrunk’s Supplier Code of Conduct, which includes that they must:
whether directly or through their supply chain, comply with all applicable human rights related laws in respect of their employees;
conduct their business activities in a manner which respects human rights and not hold another person in slavery or servitude, employ, engage or otherwise use forced or compulsory labour, trafficked labour or child labour; nor engage in or condone the use of corporal punishments or mentally, physically or sexually abusive or inhumane treatment of workers; and
have in place adequate procedures to identify, prevent, mitigate and account for modern slavery and other human rights impacts in their operations and supply chains.
4. Breaches of this Policy
AirTrunk Personnel
Non-compliance with this Policy may result in the following consequences for employees:
disciplinary action for unsatisfactory performance or misconduct. The outcome of the disciplinary action may include redeployment, demotion or termination of your employment;
suspension from duties, with or without pay, where we consider it necessary to adequately investigate allegations of misconduct or impropriety against you; or
immediate termination for serious misconduct.
In the case of other AirTrunk Personnel who are not categorised as employees, AirTrunk may raise non-compliance with the principal or employer of such AirTrunk Personnel for appropriate action.
Suppliers
We may exercise our rights to take contractual action against and/or terminate our relationship with Suppliers, if they breach this policy or any relevant laws.
5. Reporting Concerns
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken.
AirTrunk encourages the reporting of suspected misconduct within the company so that it can be dealt with appropriately. AirTrunk will endeavour to protect and support anybody who raises a concern in accordance with this Policy against detrimental conduct.
You should report any non-compliance with this Policy using our Global Whistleblowing Policy unless your complaint falls within the scope of AirTrunk’s Japanese or Australian Whistleblowing Policies or the Appropriate Workplace Behaviour Policy, in which case reports of non-compliance should be made in accordance with those policies.
