Introduction

This statement contains a summary of the measures taken by Air Partner Limited and its subsidiary companies (Air Partner) to implement the requirements of the Modern Slavery Act 2015.

Overarching Objective

The Air Partner Group is committed to the best corporate practices and ethical values. The Air Partner Group undertakes to act ethically and with integrity in all its business dealings and relationships, in line with its corporate values and policies, and to take all reasonable measures to require the members of its supply chains to do the same. This includes the prevention of modern slavery and human trafficking.

The Air Partner Group’s employees are expected to report any concerns of non-compliance with Air Partner’s values and policies, using identified reporting channels. Air Partner’s executive team and the Board are committed to act promptly upon any concern raised.

Business and Organisational Structure

Founded in 1961, Air Partner is a global aviation services group providing aircraft charter and aviation safety & security solutions to industry, commerce, governments and private individuals, across civil and defence organisations. The Group has two divisions: Air Partner Charter, comprising Group Charter (formerly Commercial Jets), Private Jets, Freight and Remarketing; and Air Partner Safety & Security (formerly Consulting & Training), which comprises Baines Simmons, Redline Assured Security and Managed Services. Group Charter charters large airliners to move groups of any size. Private Jets offers the Company's unique pre-paid JetCard scheme and on-demand charter for up to 19 people. Freight charters aircraft of every size to fly almost any cargo anywhere, at any time. Specialist Services comprises Air Partner’s other aviation

services that complement its Charter business: Remarking, ACMI, scheduled group travel, tour operations, air evacuation and flight operations.

Baines Simmons offers Aviation Safety Management and Fatigue Risk Management. Redline Assured Security delivers government-standard security training, consultancy and solutions to regulated, high value and high threat environments. Managed Services offers wildlife hazard management and aircraft registry services.

Air Partner has 16 locations across three continents, with its headquarters located alongside Gatwick airport in the UK. The group employs around 450 aviation professionals globally and operates 24/7.  Air Partner is listed on the London Stock Exchange (AIR) and is the only publicly listed air charter broker and safety consultancy. It is ISO 9001:2015 compliant for commercial airline and private jet solutions worldwide. More information is available on the company’s website (www.airpartner.com)

Our Supply Chain

The suppliers to the Air Partner Group primarily consist of airline operators and professional services (including, but not limited to, IT, legal, consultants and accounting). These are typically supplied to us by large organisations that have their own supply chain principles and ethical standards.

Aviation is a technical and skilled industry. Given the nature of the service we provide, the primary locations in which we operate and the suppliers we use, we believe the risk of modern slavery in our supply chain is low.

Policies

The Air Partner Group reinforces its policy covering ethical business practices through the training of new and existing staff. This includes a Business Ethics policy that provides that the Air Partner Group will only work with suppliers that have high standards of social and ethical responsibility and that, when entering into new business relationships or expanding into new business areas, the same standards of business practice can be maintained across the Group through appropriate due diligence checks on our suppliers. The Air Partner Group thus seeks to obtain assurances from all its suppliers that they will comply with the same standards as described in the Group’s policies. Further, all Air Partner Group activities will be carried out with proper regard for the health and safety of all those involved in its operations and that of the general public.

The Air Partner Group’s employees are encouraged, on a confidential basis if they wish, to raise concerns, red flags, report on losses and near misses, within a well-defined risk management framework, as described in Air Partner’s Annual Report and Accounts. An overall risk register for the Group and associated policies, as well as any concerns raised by employees, are regularly reviewed by Air Partner’s Executive Team and Board. Any issues which would arise in the Air Partner Group’s supply chain, including related to modern slavery and human trafficking, would be managed and promptly acted upon within the same risk management framework.

Recruitment

As a global services organisation, the Air Partner Group recruits staff in multiple jurisdictions including, but not limited to, the UK, Europe, the USA, the Middle East and Asia. In recruiting new members of staff, we apply appropriate checks (including the relevant 'right to work' documentation) to ensure that our employees enter freely into employment and not to employ anyone vulnerable to modern slavery or human trafficking. We ensure all current employees’ salaries meet at least the minimum wage for their location and check all new vacancy salary ranges meet at least minimum wage for the location.

We have a robust Diversity and Inclusion Policy which makes it clear we oppose all forms of unfair discrimination or victimisation.

We ensure all employees are paid by bank transfer and do not allow payment to be made into third party bank accounts.

We are seeking assurances that all recruitment agencies we use have anti-modern slavery and anti-human trafficking policies in place or provide positive commitment that no activities of such nature are to take place.

Process Improvement

Air Partner will continue to develop due diligence processes and focus on training and awareness across the group.

Approved by the Company

This statement is made pursuant to section 54(1) of the Act, has been approved by the Board of Directors of Air Partner Limited and will be updated annually in line with the Act's reporting requirements.

Mark Briffa

Chief Executive Officer