Introduction
This statement, made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 (MSA), outlines the steps taken by Air Partner Limited (the Company, our or we) during the fiscal year ending 31 December 2025 to prevent modern slavery and human trafficking within our business and supply chains. It has been approved by the Board of Directors of the Company and will be updated annually pursuant to the MSA.
Organisation Structure, Business and Supply Chains
- Structure & Operations: The Company, founded in 1961, is a global aviation charter business delivering aircraft charter and managed services to commercial, governmental, civil and defence clients.
- Global Presence: The Company is a subsidiary of Wheels Up Experience Inc. (Wheels Up), a Delaware, United States corporation and publicly traded company on the New York Stock Exchange. Wheels Up and its subsidiaries have approximately 1,800 employees globally, operating across three continents, and fulfilling ISO 9001:2015 standards.
- Supply Chain: Our suppliers primarily include airline operators, professional services, and technical or consultancy providers. Owing to the nature of our sector and our suppliers' typical ethical standards, we currently assess the inherent risk of modern slavery within our supply chain to be low but keep this risk under review within our risk management processes.
Policies and Processes Relating to Modern Slavery and Human Trafficking
- We maintain a Business Code of Conduct & Ethics Policy stipulating that we engage only with suppliers demonstrating high ethical, social, and human rights standards, including adherence to minimum working age and freedom from forced labour.
- We prohibit all forms of forced or child labour, corporal punishment, and inhumane treatment. We strictly enforce right-to-work checks across all jurisdictions, ensuring freely entered employment and safeguarding against exploitation.
- A risk-based management framework is maintained to ensure that concerns, including potential modern slavery issues—are promptly raised, managed, and escalated through our senior leadership and directors.
Due Diligence Processes
- In accordance with the companies process manual, we conduct robust due diligence when onboarding new suppliers to confirm compliance with our ethical standards and supplier codeof conduct.
- Payment policies ensure adherence to national living wage standards, minimizing wage-related exploitation risks.
Risk Assessment & Management
While the aviation services sector generally presents a low risk of modern slavery, we continuously monitor geopolitical shifts, service areas, and supplier practices to re-assess risk levels.
Training & Awareness
New and existing employees receive mandatory training in our Business Code of Conduct & Ethics Policy, including awareness of supply chain accountability and staff reporting mechanisms.
Monitoring and Measuring Effectiveness
- We maintain a risk register and corporate policies are periodically reviewed by senior leadership. Any issue — including those related to modern slavery — are raised through the established risk management frameworks.
- While we currently do not publish formal KPIs, tracking of supplier due diligence completion, training participation, and audit outcomes is ongoing and under development.
Future Commitments
- Continue enhancing due diligence across multi-tiered supply chains.
- Strengthen awareness training and reporting mechanisms globally.
- Introduce tangible KPIs such as supplier compliance rates, audit participation, and staff awareness metrics.
Board Approval
This statement has been reviewed and approved by the Board of Directors of Air Partner Limited. It will be published on our website and updated annually in compliance with the MSA.
Signed: Mark Briffa / Director of Air Partner Limited
Date: 05 September 2025
