For the financial year ended 31 December 2024
This statement summarises the measures that ACC Aviation, as a group, has taken and continues to take to ensure that modern slavery and human trafficking do not take place within our business or supply chains, pursuant to Section 54(1) of the Modern Slavery Act 2015.
This statement relates to ACC Aviation’s actions and activities during the financial year from 1 January 2024 to 31 December 2024.
Modern slavery encompasses slavery, servitude, human trafficking and forced or compulsory labour. ACC Aviation has a zero-tolerance approach to all forms of modern slavery.
We are committed to maintaining high standards of corporate practice and ethical conduct. We undertake to act ethically and with integrity in all our business dealings and relationships and to take all reasonable measures to require members of our supply chains to uphold the same standards.
ACC Aviation comprises NEWACC (2018) Limited and its subsidiaries:
The directors of each subsidiary are responsible for ensuring that modern slavery and human trafficking do not take place within our business or supply chains.
Founded in 2002, ACC Aviation is a global aviation services group providing worldwide solutions to the aviation industry, commercial organisations, governments and private individuals.
Our divisions provide specialist services in aircraft wet leasing, aircraft charter, asset management and aviation consultancy.
We deliver market-leading solutions, and our commitment to service and reliability has helped establish ACC Aviation as a respected global aviation services provider.
ACC Aviation’s suppliers primarily consist of airline operators and professional services providers, including IT, legal, consultancy, accounting and recruitment organisations.
These services are generally provided by established organisations that maintain their own supply chain principles, compliance procedures and ethical standards.
Aviation is a technical, highly skilled and closely regulated industry. Given the nature of the services we provide, the principal locations in which we operate and the suppliers we engage, we consider the overall risk of modern slavery within our supply chains to be low.
ACC Aviation is committed to conducting its business ethically. This commitment is reflected in our policies, practices and operating standards.
We only work with suppliers that demonstrate high standards of environmental and social responsibility. When entering new business relationships or expanding into new business areas, we use appropriate due diligence procedures to help ensure that consistent standards of business conduct are maintained throughout ACC Aviation.
We ensure that new and existing employees and workers receive appropriate training on relevant policies and procedures and understand our commitment to preventing modern slavery.
ACC Aviation also seeks to ensure that all activities are carried out with proper regard for the health and safety of everyone involved in our operations, as well as members of the public.
The following policies describe our approach to identifying modern slavery risks and the measures we take to prevent slavery and human trafficking within our operations and supply chains.
We encourage employees, workers, customers and other business partners to report concerns relating to our direct activities or supply chains.
This includes any circumstances that may create or indicate an increased risk of slavery or human trafficking.
Our whistleblowing procedure is designed to enable employees and workers to raise concerns or make disclosures without fear of retaliation.
Our Code of Conduct explains the standards of action and behaviour expected from employees and anyone else working for or representing ACC Aviation.
We are committed to maintaining high standards of professional conduct and ethical behaviour throughout the organisation.
We use specified and reputable employment agencies to source employees and workers. We assess the practices of new agencies before accepting employees or workers supplied by them.
When recruiting new team members, we carry out appropriate checks, including verification of relevant right-to-work documentation, to help ensure that individuals have freely entered into employment.
ACC Aviation’s policies are communicated to employees and workers throughout the organisation. They are reviewed and updated annually, or every two years where appropriate, to ensure that they remain current and effective.
We consider the overall risk of modern slavery within our supply chains to be low.
ACC Aviation recruits employees and workers across multiple jurisdictions. Some of the countries in which we operate may present an increased risk of modern slavery or human trafficking. Our global recruitment policy must be followed in every jurisdiction.
As part of our supplier onboarding procedures, we require suppliers to confirm their compliance with applicable modern slavery legislation, conduct appropriate due diligence within their own supply chains and agree to contractual provisions covering ethical conduct.
We encourage employees and workers to report concerns to Human Resources or a senior manager within the organisation. Where appropriate, concerns may also be reported to the Modern Slavery and Exploitation Helpline or the relevant authorities.
ACC Aviation will continue to review, develop and promote its policies and practices to identify and mitigate risks relating to modern slavery and human trafficking within its business and supply chains.
Online modern slavery training was introduced in 2021. All employees and workers are required to renew this training annually, with completion monitored by Human Resources to support compliance.
We review our Modern Slavery Statement annually to ensure that potential concerns and areas for improvement are identified and addressed.
Any concerns relating to modern slavery or human trafficking are documented, investigated and, where required, reported to the relevant authorities. Appropriate disciplinary action may also be taken.
Know Your Customer and Know Your Supplier procedures are used when entering relationships with new customers and suppliers.
All ACC Aviation employees and workers are required to complete relevant online training and confirm that they have read and understood applicable policies at the beginning of their employment or engagement.
Where appropriate, employees and workers must repeat this training and policy acknowledgement annually.
Training materials are updated by the online training provider, and ACC Aviation’s latest Modern Slavery Statement is included within the relevant training resources.
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015.
It was approved by the Board of Directors of NEWACC (2018) Limited on 29 October 2025, made available on the ACC Aviation website and will be reviewed and updated annually in accordance with the Act’s reporting requirements.