Our governance

The Group’s Business Integrity and Compliance function, reporting to the General Counsel and Group Executive, Office of the CEO, ensures that the Group is best positioned to respond to both the rapidly evolving regulatory environment and shifting societal expectations regarding corporate ethics. Our Business Integrity Compliance program is overseen by the Qantas Board, through the Qantas Audit Committee.

Supporting our Code of Conduct and Ethics is a suite of policy documents, procedures and guidelines that outline the minimum standards required of all our employees, and which support our employees to act legally and with integrity. With a focus on continuous improvement.

Risk assessment is a vital tool in bribery prevention and an essential component our corporate compliance program. Our risk assessment methodology utilises known bribery and corruption risk indicators to identify potential risk and, where required, to introduce adequate controls to mitigate that risk.

Our Group training matrix identifies those employees who, due to the nature of their role, are required to complete anti-bribery and competition law training. Training is primarily delivered online, however we may conduct face-to-face training for employees operating in high-risk roles following consideration of factors such as the corruption risk index of the country, the level of interaction with government, and the nature of the business activity. Using this risk-based approach, we may also deliver training to contractors, agents or persons who may act on our behalf.

Our due diligence program assists us to assess and ensure that those we partner with operate with a commensurate level of integrity, operate within the law and meet our requirements.
We support an ethical supply chain through our due diligence program, which assesses potential third-party suppliers, including those who act on our behalf, to identify those presenting an elevated risk of bribery. Where gaps are identified we may require mitigaton action to be taken for example: strengthened policies and procedures; training programs; contractual controls; financial controls; or reporting processes.

The global nature of our business means that we interact with government and their agencies across the regions and countries in which we operate. As governments are key decision makers of issues that directly impact our business, we invest in building effective and collaborative relationships in order to achieve optimal business outcomes for the Group.

We're proud of our joint collaboration with government and broader industry to strengthen Australia’s approach to anti-corruption through our participation in dedicated focus groups, such as the Bribery Prevention Network and our association with industry bodies such as the Global Compact Network.

Our Modern Slavery Statement, pursuant to the Australian Modern Slavery Act 2018 (Cth) (MSA) and s54(1) of the Modern Slavery Act 2015 (UK MSA) sets out the actions taken by the Qantas Group to mitigate and prevent potential modern slavery risks in our operations and supply chains. The Statement provides examples, in the form of case studies, that demonstrate our approach to address issues of potential concern and advance respect for human rights in line with international standards.  The Statement also expresses our commitment to conducting our business, including our response to potential modern slavery risk, in line with the guidance provided under the UNGPs.

The Groups governance framework underpins our response to modern slavery and broader human rights risks, including by providing a structure for accountability. Human rights and modern slavery risks in our operations and supply chains is managed consistently within our established enterprise-wide risk framework, with oversight maintained through the assurance activity of Qantas Group Audit and Risk, and ultimately the Audit Committee.

The Business Integrity and Compliance team monitor global developments with regard to human rights legislation and standards and supports the business to meet the requirements, including through the due diligence and risk assessment of suppliers in our supply chain assurance program.

As an international airline group, we have a diverse global footprint. We recognise the importance of undertaking effective human rights due diligence, including for our operations, business partners and suppliers in higher-risk environments.

We completed our first salient human rights assessment in 2018, and across FY22 and FY23 we engaged an independent business and human rights advisory firm to undertake a review of our salient human rights issues. Our salient human rights issues are the areas where we consider the most severe adverse human rights impacts could occur across our business activities and relationships. 

The review involved a Group-wide, cross-functional workshop to identify potential examples of relevant adverse human rights impacts, the themes of which were subsequently validated in a series of internal stakeholder consultation sessions. We then worked with Pillar Two to assess the indicative severity of these potential adverse human rights impacts by evaluating their scale, scope and remediability in line with international standards and frameworks.

This work informed the identification of five salient human rights issues for Qantas, which we aim to use to help us focus our human rights risk management and help ensure we manage the key risks to people and to the business.

The five areas of focus are:

1. Respecting labour rights in our supply chain,
2. Safeguarding customer safety and welfare,
3. Securing customer and employee privacy,
4. Preserving a clean, healthy and sustainable environment, and
5. Providing safe, respectful & inclusive working environments for our people.

We are committed to partnering with suppliers who share our commitment to compliance with the law and ethical business practices. Through our supply chain assurance program we proactively seek to identify, assess and address modern slavery risk within our supply chain.  We aim to safeguard the respect for human rights, by ensuring that suppliers within our supply chain provide adequate human and labour rights protections to workers, including safe and environmentally healthy work conditions.  

Our expectations of Suppliers are outlined in our Supplier Requirements (PDF) (which includes the Qantas Group Compliance Statement) and Supplier Code of Conduct (PDF), and reflected in relevant contractual arrangements.  Our policies are developed with regard to relevant legislation and internationally recognised standards such as the United Nations Universal Declaration of Human Rights. 

Support for our Suppliers:  

We recognise the importance of providing training and support to our suppliers, to build their capacity to effectively manage modern slavery risks. Our interactions with our suppliers, those in our extended supply chain and our business relationships are valuable experiential learning opportunities. We invest time and resources engaging in two-way dialogue to build an understanding of international standards on human rights, including modern slavery, and providing guidance on implementation of appropriate actions to address potential human rights risks. 

Further detail on our approach to managing modern slavery risk in our supply chain can be found in our Modern Slavery Statement (PDF)Opens in a new tab or window.

The delivery of training to our people is key to helping us maintain the respect for human rights. Our people undertake role-based training on a wide range of human rights related issues.

The objective of the training is to build awareness, understanding and equip our people to act with integrity and with respect for human rights in their dealings with each other, our customers, and the broader community.

In line with the eight characteristics of an effective grievance process outlined in the UNGPs, we understand effective grievance mechanisms should be a trusted and accessible mechanism through which adversely affected people (including employees, suppliers, workers in our supply chain and other stakeholders) can raise matters of legitimate concern, without any fear of retaliation.

We have established reporting procedures and mechanisms where employees and third parties (including suppliers and their workers) can report any concerns regarding unethical or illegal conduct, including in relation to modern slavery. Employees can report to their manager or, if they wish to remain anonymous, employees and third parties (including suppliers and their workers) are able to report through our independently managed Whistleblower channels, via phone and email, via our online portal, or by contacting an eligible recipient as named in our Whistleblower Policy.

The accessibility of appropriate grievance mechanisms to workers in our supply chains and in our suppliers supply chains, forms part of our supplier due diligence and risk assessment processes and remains an ongoing area of focus when working with our suppliers.

The review and refinement of our grievance mechanisms to ensure they remain effective (with reference to the UNGPs) is an ongoing initiative for the Group.

We understand that effecting meaningful change to address modern slavery will take time and, to be successful requires a multi-stakeholder approach between business, civil society, governments, investors, unions and importantly from those with lived experience.  Our stakeholder engagement provides opportunities to understand the perspectives of our stakeholders, to help inform and continuously improve our response to modern slavery and broader human rights issues.

Qantas is an active member of the UN Global Compact Network Australia (GCNA) and is also a member of the GCNA Modern Slavery Community of Practice.  The forum provides an opportunity for  Australian businesses to share insights and learn of leading practices to address modern slavery and human rights risk.

Qantas recognises that airlines have a role to play in preventing human trafficking. We have continued to contribute to industry initiatives to prevent human trafficking, including ongoing consultation on ICAO policy and IATA standards and practices.

We have developed human trafficking awareness training using guidance material for airlines about human trafficking, produced by the International Air Transport Association (IATA).  The training focuses on building key employees’ awareness of indicators of human trafficking, to help us recognise potential trafficking victims who may be travelling passengers and to apply victim-centred response protocols. In addition to this targeted face-to-face training, all employees receive more general human trafficking awareness training when they join the Qantas Group and on a periodic basis.

People are the core of our business, and our commitment to respect human rights, which includes labour rights, starts in our own operations. The Group aims to ensure a safe and fair working environment for our people and we also recognise the rights of our employees to freedom of association with approximately 20,000 of our employees covered by more than 50 Enterprise Agreements (EA’s).

 Our Supplier Code of Conduct creates clear expectations for suppliers in respect of labour rights and working conditions.

We aim to foster a workplace where people respect and tolerate the rights and differences of others. Harassment in the workplace is not tolerated and is a form of discrimination if it is based on an unlawful ground such as gender, race or disability. Likewise, bullying or any form of occupational violence in the workplace is not tolerated.

Our inclusion and diversity strategy is focused on driving an improved people experience (and in turn, better business outcomes) by removing barriers to inclusion and creating greater opportunities for participation.  We do this by mitigating unconscious bias and improving access to flexibility, talent programs and dedicated leadership development.

Learn more about Inclusion and Diversity.