Dreamlifts Limited trading as Antonov Airlines

Modern Slavery and Human Trafficking Statement FY 17-18


This statement sets out Dreamlifts Limited’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2017 to 31 March 2018.

As part of the international ad hoc air charter industry, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking, as it may be required to operate in high risk areas across the world.

The company is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Dreamlifts Limited:

The company operates as worldwide general sales and support services agent for Antonov Company. As such it sells, manages and executes ad hoc, world-wide, whole aircraft charter flights using principally the Antonov An124 aircraft. This includes the purchasing of third party services required for the aircraft and cargo at airports all round the world.

Countries of operation and supply

Due to the nature of its’ business the company operates to any and all countries of the world as requested by the customers. The only exceptions being places where there is no suitable airfield or the situation is not safe for the aircraft and crew or there are other physical or regulatory constraints. Since Antonov Airlines began operating in 1989 the aircraft have visited approximately 130 different countries.

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

  • Most of the processes in the supply of third party services to the aircraft and the company involve low risk of slavery since aviation is a highly regulated industry in which most tasks require a significant level of education and qualification. These two factors help to restrict the opportunity for the exploitation of workers. However, when operating to a location for the first time or for the first time in more than three years the operations department will assess the services required, the available providers and the possibility that modern slavery could be an issue in their provision in that location. Priority is given to service providers who are known or profess to adhere to the EU Regulations and guidelines on Modern Slavery or the local equivalent legislation. In the event that no such supplier is instantly and obviously available, when requesting services the operations department will endeavour to ascertain the supplier’s policies in respect of ethics and modern slavery.
  • Where services are provided on a contract basis, for example, at airfields which are visited on a more frequent or more regular basis, suppliers will be retained on a long term contract basis and the assessment of suppliers will include an assessment of the supplier’s attitude and policy in respect of ethics, employment and slavery.
  • In addition much of the current security legislation requires many of the service providers to be audited by airlines and for those audits to be validated by independent validators who are certified as such by EU States’ Government Authorities. Whilst such auditing is designed primarily to assess security issues the process of the audit and the validation will undoubtedly provide the opportunity to assess the risk and the existence of any inappropriate exploitation of staff. The security regulations require regular and recurrent audits which will assist in ensuring that standards are maintained.
High-risk activities

The following activities are considered to be at high risk of slavery or human trafficking:

  • No activity associated with the business is considered high risk. The only activity which is considered of any risk is the provision of aircraft and cargo handling services in developing countries. There is little likelihood of slavery occurring in these activities because of the highly regulated nature of all aviation even in developing countries. However, since there is a perceived greater risk of other unethical practices in some developing countries it seems prudent to allow that slavery may also be an issue; for example in the employment of aircraft cleaners or manual labour used to assist in bulk loading or unloading.

Responsibility for the organisation’s anti-slavery initiatives is as follows:

  • Risk assessments: The Board of Directors is responsible for advising department heads of the company’s liability and responsibility in respect of Modern Slavery and for developing a risk assessment policy based on the department heads advice relating to their individual areas of responsibility and expertise.
  • Investigations/due diligence: As previously explained slavery is most unlikely to occur in the markets in which the company operates. Due diligence is carried out by the Operations Manager and his team as they have the day to day contact with suppliers in areas where any risk of slavery exists. In the event that a particular risk is identified or suspicions raised the Operations Manager will bring this to the attention of the Board who will assess the situation and provide guidance and instruction as appropriate.
  • Training: Employees have been made aware of the company and individuals’ responsibility in respect of modern slavery and the applicable legislation through the staff handbook and the processes applicable to their individual roles. Training is recurrent whenever the handbook or other procedures and policies are amended.
Relevant policies

The company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy – The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can make a confidential disclosure to the Managing Director.
  • Employee code of conduct – The company’s code of conduct within the employee handbook makes clear to employees the actions and behaviour expected of them when representing the organisation. The company strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain. This includes the Code of Business Ethics Document that is issued to every employee annually, and they are asked to sign to agree they have read, understood and will abide by the policies within.
  • Supplier code of conduct – The company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The company works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the company’s supplier code of conduct will lead to the termination of the business relationship. Suppliers are required during the contracting process to confirm their adherence to the terms of the modern slavery act. Since much of the contracting is ad hoc and short notice, it is not easy to verify the assertions of suppliers prior to services being provided. However, any suspicion on the part of the crew receiving the service is required to be reported and will result in investigation and if appropriate blacklisting of the relevant supplier.
  • Recruitment/Agency workers policy – The company does not currently use nor does it expect to use agency workers in the foreseeable future. In the event that agency workers are required only specified, reputable employment agencies will be contracted to source labour The company will always verify the practices of any new agency it is using before accepting workers from that agency
Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier;
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • conducting supplier audits or assessments through the RA3 /ACC3 mandatory security audit and validation process in accordance with EU Regulations
  • using [details of ethical supplier database], where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
Performance indicators

The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation is:

  • requiring all staff to have an awareness of the risks modern slavery in relation to their role.
  • continually reviewing its existing supply chains whereby the organisation evaluates all existing suppliers. As previously explained the process will require recurrent audit to try to ensure ongoing compliance and reduced risk of future difficulty and; –
  • ensuring that supplier contracts contain a clause stating that the suppliers will adhere to all relevant legislation and policy in regards to modern slavery and human trafficking and contain a clause to state that we retain the right to terminate contracts if they are in breach.

The company requires all staff within the organisation to complete training on modern slavery as a module within the organisation’s wider human rights/ethics/ethical trade training programme.

The organisation’s modern slavery training covers:

  • What Modern Slavery is
  • The risks they should be aware of in relation to their role
  • How to report any concerns they have or if they identify Modern Slavery taking place

In addition all employees are expected to read and sign annually the company’s code of business ethics in which the company’s expectations are laid out.

Awareness-raising programme

As well as training staff, the company has raised awareness of modern slavery issues by distributing information to staff

The information explains to staff :

  • the basic principles of the Modern Slavery Act 2015;
  • how employers can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • what external help is available, for example through the Modern Slavery Helpline.
Board approval

This statement has been approved by the organisation’s board of directors, who will review and update it annually.