Supplier Code of Conduct
VALLETTA AIRLINES, LTD. (hereinafter – the "Company") is committed to operating a safe, efficient, and responsible air transportation business. As an airline, we recognize the impact of our operations on the environment, communities, and people, and strive to uphold the highest standards of ethical conduct, sustainability, and corporate responsibility.
We expect the same commitment from our suppliers, who are critical to the integrity of our services and our reputation. This Supplier Code of Conduct (“Code”) outlines the minimum standards we expect from all our suppliers and business partners, including subcontractors, regardless of their geographic location.
By working together, we aim to build a transparent, ethical, and sustainable aviation industry that benefits all stakeholders.
1. Compliance with Laws and Regulations
Suppliers are expected to operate with integrity and in full compliance with all applicable local, national, and international laws and regulations. This includes, but is not limited to, laws related to anti-bribery and anti-corruption, export controls and sanctions, aviation safety and operational standards, environmental protection and sustainability, fair labor practices, human rights, occupational health and safety, and data protection and privacy. Suppliers must ensure that their business practices, as well as those of their subcontractors and partners, adhere to these legal requirements and industry standards at all times, and are aligned with the principles of ethical and responsible conduct in the aviation sector. In addition, suppliers are expected to adhere to the Company’s applicable procedures, policies, and requirements made available to them in relation to supplier conduct, compliance, and operational expectations.
2. Business Ethics and Integrity
2.1. Anti-Corruption and Anti-Bribery
Suppliers must strictly comply with all applicable anti-corruption and anti-bribery laws, regulations, and international standards — regardless of local practices or customs. Under no circumstances may suppliers, directly or indirectly, offer, give, solicit, or accept any item of value with the intent to improperly influence business decisions or secure an unfair advantage.
2.2. Gifts and Business Hospitality
Business decisions must be based solely on merit. Suppliers must avoid giving or receiving gifts, hospitality, or entertainment that could improperly influence decision-making or create a perception of impropriety. All such exchanges must comply with applicable laws, be modest in nature, and align with reasonable business practices.
2.3. Fraud and Misrepresentation
Suppliers must operate honestly and transparently. Any attempt to gain an unfair advantage through fraud, deception, misrepresentation, or misuse of proprietary information is strictly prohibited.
2.4. Conflicts of Interest
Suppliers must avoid situations that create or appear to create a conflict between their interests and those of the Company. Any actual or potential conflicts of interest must be promptly disclosed to the Company.
2.5. Fair Competition and Antitrust
Suppliers must comply with all applicable competition and antitrust laws. This includes avoiding any agreements or practices that may restrict competition — such as price fixing, bid rigging, market allocation, or the exchange of sensitive pricing information with competitors.
3. Human Rights and Labor Standards
Suppliers are expected to strictly prohibit any form of child labor, forced labor, or human trafficking within their operations and supply chains, ensuring that all workers are employed voluntarily and under lawful conditions. They must provide fair wages, benefits, and working conditions that not only comply with local laws and regulations but also promote the well-being and dignity of their workforce. Furthermore, suppliers should respect the fundamental rights of workers, including the employees’ right to voice their concerns and negotiate terms of employment. In addition, suppliers are expected to maintain a workplace environment that actively prevents discrimination, promotes respect, and offers equal opportunities for growth and development.
4. Wellbeing, health, and safety
Suppliers must comply with all applicable health and safety laws and regulations. The Company requires suppliers to adopt practices to minimize health and safety risks, support accident prevention, and ensure a safe workplace for all workers, including employees and/or contractors and other third parties.
5. Environmental sustainability
Suppliers are expected to operate in a way that actively addresses and manages environmental risks across their operations, products, and supply chains. The use and development of environmentally friendly technology shall be promoted and business conducted with as low impact on the environment and public health as possible.
Suppliers should establish an appropriate environmental management system, including policies and procedures designed to effectively manage their environmental performance, which includes:
- Adherence to all applicable laws, regulations, and other environmental requirements pertaining to their operations.
- A commitment to continuous improvement by setting and monitoring environmental objectives and targets, tracking performance, and taking corrective actions when necessary.
- Ensuring that employees have the knowledge, skills, and resources required to perform their duties in an environmentally responsible manner.
- Regular and transparent reporting of their environmental performance and initiatives to stakeholders.
- Collaborating with the Company to raise general environmental awareness whenever needed.
6. Security and Aviation Standards
Given the sensitivity and high regulatory demands of the aviation industry, suppliers are required to fully comply with all applicable aviation security standards — covering areas such as supply chain security, material handling, and accurate documentation — and to ensure that all services they provide, particularly those with a direct impact on safety (including but not limited to maintenance, fueling, and catering), strictly adhere to the requirements set by IATA, EASA, ICAO, and the relevant local aviation authorities, thereby upholding the highest levels of safety, reliability, and regulatory compliance throughout their operations.
Suppliers must do their utmost to ensure safety hazards and potential risks are reported, investigated and appropriate mitigations set in place to minimize the exposure to potential risks.
7. Information and Data Protection
7.1. Confidentiality and Protection of Information
Suppliers are required to protect all sensitive, confidential, and proprietary information to which they have access in the course of their business relationship with the Company. Such information must be protected against unauthorized access, use, disclosure, or alteration. Disclosure to third parties is permitted strictly on a need-to-know basis or when legally mandated. Compliance with intellectual property laws is also expected, including the protection of proprietary rights and trade secrets.
7.2. Data Privacy and Personal Data Protection
Suppliers must fully comply with all applicable data protection and privacy laws, including those governing the collection, processing, transfer, and storage of personal data. They must implement appropriate technical and organizational measures to ensure the security and confidentiality of personal data, preventing accidental or unlawful destruction, loss, alteration, unauthorized access, or disclosure.
Where suppliers process personal data on behalf of the Company, or where personal data is transferred outside the European Economic Area, appropriate contractual arrangements must be in place, in line with applicable legal requirements.
7.3. Cybersecurity
Suppliers shall establish and maintain effective cybersecurity measures to protect both their own systems and any sensitive information belonging to the Company or other third parties. This includes implementing robust physical and digital safeguards, regularly assessing vulnerabilities, and taking proactive steps to mitigate emerging cyber threats. Any suspected or actual data breaches or security incidents must be reported to the Company promptly upon detection.
8. Export and Sanctions
Suppliers are expected to conduct their operations in full compliance with all applicable export control laws, directives and regulations including economic sanctions and embargoes, governing the export and transfer of parts, components and technical data and service. Suppliers must provide accurate and complete information, and are responsible for obtaining any required export licenses, permits, or other authorizations where necessary.
9. Monitoring, Audits, and Enforcement
The Company reserves the right to monitor and assess suppliers’ compliance with this Code through various means, including but not limited to self-assessments, questionnaires, site visits, and formal audits – either directly or through third parties. Suppliers are expected to cooperate fully and transparently during any such review, providing timely access to relevant records, documentation, and personnel.
In cases where non-compliance with the Code is identified, the Company may require the supplier to implement corrective action plans within a specified timeframe. Depending on the severity or recurrence of the issue, the Company may take further steps, including temporary suspension, restrictions on new business, or full termination of the business relationship. The Company also reserves the right to report serious violations to the appropriate regulatory authorities, particularly in cases involving legal or ethical breaches.
10. Reporting and Whistleblowing
Suppliers are encouraged to report any unethical or illegal conduct involving the Company or its representatives. Reports can be submitted confidentially through email: [email protected].
11. Acknowledgement
By engaging in business with the Company, suppliers commit to fully adhering to the principles and requirements set forth in this Supplier Code of Conduct and to actively promoting and enforcing its implementation not only within their own operations but also throughout their entire supply chain.
12. Order of Precedence
If a conflict exists between this Code and applicable law, suppliers must comply with the applicable law and promptly inform the Company of the discrepancy. Where this Code requires obligations beyond applicable laws, suppliers must follow these requirements within the bounds of applicable law.