We insist that all Group employees act with the utmost integrity at all times. To this end, we have established a robust compliance policy with a view to monitoring and preventing potential risks to our company. The policy is focused on upholding the good reputation of Royal Schiphol Group and achieving our ambition to become Europe’s preferred airport.

As outlined in our code of conduct, another priority is ensuring that our people behave ethically at all times. As a minimum, Schiphol employees must refrain from undesirable behaviour, including sexual harassment, discrimination and bullying. Staff must also adhere to all applicable laws and regulations, including anti-discrimination, competition, public procurement, privacy, fraud, corruption and bribery laws. All Schiphol employees are required to complete an online training session on the code of conduct once a year.

While Schiphol's managers are expected to set the tone and lead by example, all workers play a role in monitoring compliance with the code of conduct and reporting inappropriate behaviour. Any issues are reported via the Integrity Committee, which is responsible for investigating reports and undertaking necessary actions as required. The Committee reports its anonymised findings to Schiphol's Corporate Compliance Officer on an ongoing basis, and also reports to the Central Works Council once a year on the number and nature of cases and the actions taken. The Committee also reports to the Supervisory Board's Audit Committee on an annual basis, as well as the Management Board and Schiphol's external auditor.

In 2018, 23 issues were reported to the Integrity Committee (2017: 26), none of which concerned bribery, corruption or material fraud. The reports have been investigated and followed up. Some involved minor incidents which the Integrity Committee is not required to investigate in depth. Where appropriate, the necessary action has been taken or the employees involved have been called to account.

Preventive behavioural programme

In 2018, we continued rolling out a new behavioural programme that was put in place in 2017. A collaboration between Schiphol Group and social psychologists, the programme aims to prevent future compliance and integrity incidents by providing teams within the individual departments with a set of actions aimed at achieving the desired employee behaviour. More than half of the designated departments have completed the programme so far, with evaluation interviews held during the final quarter of the year to assess its impact. Other departments initiated the programme in 2018 or will do so in 2019.

Compliance & Ethics Officer

In the third quarter of 2018, we created a new position: Compliance & Ethics Officer. The role is part of Schiphol's continuing efforts to build a solid integrity culture; the holder is tasked with shifting the focus from simply creating awareness of issues relating to compliance and ethics, towards achieving tangible changes in employee behaviour. Liaising closely with HR, Audit, Risk and other relevant departments, the newly appointed officer will be working to create a comprehensive, aligned approach to compliance and ethics, by bringing together the different cultural programmes in place across the Group.


The majority of our business partners are situated and operational in the Netherlands, as our purchases primarily relate to infrastructural and construction works, personnel and facilities. As a commissioning organisation, we can only ensure our integrity if our suppliers also subscribe to ethical business principles. It is therefore essential that we take care when selecting our suppliers. In particular, we note that there is a risk of bribery and corruption in contracting practices related to large tenders and contracts. Furthermore, some countries are prone to human rights violations, which is a factor we must bear in mind when purchasing goods or services from overseas.

Royal Schiphol Group has a Supplier Code that clearly states what we expect from our suppliers in terms of integrity and Corporate Responsibility. Specifically, the Code outlines the requirements regarding working conditions, human rights, anti-corruption and anti-bribery. This follows the line of the OESO as well as the ILO guidelines. Under the terms of the Code, suppliers must report instances of negligent or unethical behaviour through their contact person or Schiphol's Integrity Committee. They must also agree to cooperate in any investigations into (suspected) violations of the Code. In the event of a possible violation or vulnerable markets, we perform audits.

Contractors who knowingly breach the law (e.g. with regard to discrimination or sub-standard working conditions) or who violate Schiphol's own rules of conduct have their contracts terminated immediately. This stipulation is made clear in our Corporate Purchasing Policy. Meanwhile, we maintain ongoing dialogues with our suppliers with a view to introducing integrity into our collaborative relationships more effectively. Going forward, we aim to formalise our process for monitoring the activities of our suppliers and their compliance with our Supplier Code and Corporate Purchasing Policy.


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