Fraport USA maintains a commitment to compliance with all laws, regulations, and our own internal code of conduct.

The employees of the Fraport Group are obliged to observe all current laws and internal guidelines. If violations occur, however, we are interested in receiving reports on this kind of misconduct. We are grateful for every information provided by employees, customers, suppliers and business partners that helps to identify and rectify such irregularities. It is the only way to prevent economic disadvantage and reputational damage for our company.

Whistleblowers reporting actual or suspected violations are in no way “informers” but help to ensure the integrity in our business processes – and, as a result, our success as airport managers. We appreciate your support.

This system should be used to report any incident related to the following aspects:

  • Corruption.
  • Robbery/ Fraud, Scam or Deceit/ Documents forgery.
  • Breach of occupational health and safety standards.
  • Breach of values and principles of Fraport USA.
  • Breach of the airport security regulations.
  • Other violations of laws.

Please read carefully the “Security Warning” instructions. Once received, a committee will assess the case and send you a reply.

To access the Electronic Report System, please click here.

Complaints Procedure

Scope of Application

Reports of violations of human rights and breaches of environmental laws and regulations within the Fraport Group and at direct suppliers can be submitted through the following complaints/whistleblowing channels:

Complaints Channel: Click Here

Responsibilities and contact person

Complaints are handled by the Compliance department of Fraport AG and, where necessary, with the support of other experts. The contact person is the head of the Compliance department, Elke Breuer.

How the Complaints Procedure Works

Complaints are received by the Compliance department. The whistleblower receives a confirmation of receipt and is kept informed of the next steps that will be taken and the progress of the procedure.

In a first step, an initial assessment is carried out to check whether the reported breach falls within the material scope of the complaints procedure. Other requirements for instituting an investigation to establish the facts include whether the incident that has been described can be judged on the whole to be plausible and generally possible and might indicate a violation of any law or a serious breach of an internal regulation. In this process, it is examined whether any collection, processing, or use of data that takes place in the course of the investigation is permissible under data protection law.

The aim of the investigation is to clarify the facts of the matter that are the subject of the report in a neutral, competent, and objective manner. The investigation of the facts is carried out by suitable persons, who are required to act independently and maintain confidentiality. They contact the whistleblower, check the validity of the report that has been received, and, if necessary, request the whistleblower to provide more information. Reports of breaches at a direct supplier are investigated jointly with the supplier. The investigation is conducted on the basis of documents and interviews and is recorded comprehensibly in a case file. Case files are deleted once a year if there is no legitimate interest in retaining them. The whistleblower receives feedback on the progress of the procedure within three months following confirmation of receipt of their report. Feedback is provided only insofar as this does not affect any internal investigations and the rights of the persons who are the subject of a report or who are named in the report are not adversely affected.

Each case concludes with a written final report, which remains strictly confidential. The list of people to whom the report is distributed depends on the nature and severity of the breaches that are identified and is determined on a case-by-case basis. Information is disclosed only if this is necessary and permitted under data protection law. The final report includes penalties and suitable actions for remedying irregularities and preventing similar breaches in the future. After the investigation has been concluded, the whistleblower is notified of the follow-up actions to be taken, if this is permitted by law.

Protection Against Reprisals

At Fraport USA, special protection is given to whistleblowers who pass on information in good faith in order to expose irregularities. The Compliance department guarantees that they are protected by maximum confidentiality and whenever legally possible, by ensuring their anonymity.

In terms of case management at Fraport USA, this means that the identity of the whistleblower is disclosed solely to the persons who are responsible for receiving information or for instituting follow-up actions.

Fraport USA ensures through the whistleblower system that whistleblowers who have sufficient reason to believe that their information is true are not obstructed, restricted, or influenced when they submit the information.

Whistleblowers who have been identified by name need not fear any reprisals, such as suspension, termination, relocation to other duties, disciplinary measures, discrimination, bullying or similar retaliation, from their Fraport USA employer after they have submitted a report.

Information that is submitted with malicious intent or in bad faith to implicate employees is explicitly unwelcome. Information of this kind that is clearly intended only to harm, denounce, or disparage other people will not be processed. The whistleblower will not be given special protection against reprisals and can be subject to liability in these cases

Code of Conduct for Suppliers

P1 Code of Conduct for Suppliers
  Prepared by (modified) Checked by (formal) Approved by (Responsible) Approved by (Responsible)
Unit Legal and Compliance Legal and Compliance Fraport Cleveland Inc  Fraport Maryland Inc Fraport Tennessee Inc  Fraport New York Inc Fraport Newark LLC Fraport Washington Partnership LLC Chief Executive Officer
Fraport USA
Name and Surname Claire Swauger Claire Swauger Sabine Trenk Sabine Trenk
Date 11.07.2023 11.07.2023 11.07.2023 11.07.2023


Edition number Edition date Comments Author
1.0 11.11.2022 Draft T. Uihlein
1.0 11.22.2022 Version 1.0 C. Swauger
2.0 07.24.2023 Version 2.0 C. Swauger
3.0 11.07.2023 Version 3.0 C. Swauger


Copyright © 2023 Fraport USA

All rights reserved. No part of this publication may be reproduced, remodelled, stored in a retrieval system, used in a spreadsheet, or transmitted in any form or by any means, without the permission in writing from the owner of these rights.


1.         Principles

2.         Human Rights and Fair Working Conditions

3.         Environmental and Climate Protection

4.         Business Integrity

5.         Due Diligence in Supply Chains

6.         Corrective Measures

7.         Complaints Procedure

8.         Availability of the Current Supplier Code of Conduct

9.        Inspection Rights to Verify Compliance with the Supplier Code of Conduct

Code of Conduct for Suppliers of Fraport USA Inc. Group

  1. Principles

The Supplier Code of Conduct stipulates the requirements and principles for all business transactions between Fraport USA Inc. and its subsidiaries (hereinafter referred to as “Fraport”) and its contractors, suppliers, and service providers (hereinafter referred to as “Business Partner”).

Companies doing business with Fraport USA Inc. or its affiliates are required to accept and comply with the respective national laws and the internationally accredited standards, guidelines and principles. These include the principles of the United Nations Global Compact (, the Universal Declaration of Human Rights, the United Nations Charter, the Core Conventions of the International Labour Organization (ILO), the OECD Guidelines for Multinational Enterprises, and the German Act on Due Diligence in Supply Chains (LkSG). The Business Partner has the obligation to ensure that all other companies (e.g. sub-tier suppliers, third-party companies, etc.) involved in the provision of services consistently distribute and apply these standards.

2. Human Rights and Fair Working Condition

2.1  Occupational Safety and Health

Our Business Partner shall ensure a safe, secure, healthful and hygienic work environment and take the necessary measures to prevent accidents and adverse health effects that may arise in connection with their activities. The Business Partner is, therefore, obligated to ensure that occupational safety standards shall be complied with in their dealings with employees and business partners. The Business Partner shall take appropriate measures to this end and shall operate systems in order to identify and prevent any potential health risk due to accidents, injuries, and occupational illness on the part of their employees.

2.2  Remuneration and Working Hours

The working hours shall be in accordance with applicable national laws and regulations and with the relevant Core Labour Standards of the International Labour Organization (ILO). The Business Partner is obligated to grant their employees the legal remuneration or the compensation provided in collective labor agreements for the duration of the contract performance, and to employ only such sub-tier suppliers or third parties that also adhere to these standards.

2.3  Combatting Illegal Employment

The Business Partner shall comply with the applicable statutory regulations relating to the employment of personnel and is under a duty to effectively combat illegal employment and unreported employment (“moonlighting”).

2.4  Forced Labor

The Business Partner shall abstain from any form of forced labor; all forms of forced or compulsory work as well as involuntary prison labor shall be declined.

2.5  Child Labor

Any and all form of exploitation of children and juveniles shall not be tolerated. Child labor as defined in the ILO Conventions and in national laws is prohibited.

2.6  Right of Association and Right to Collective Bargaining

The Business Partner shall respect the right to freedom of association and the right to collective bargaining as defined by national laws. In the event that national standards should restrict the right of association and the right to collective bargaining, the Business Partner shall take steps to ensure that the free and independent association of employees for the purpose of conducting negotiations be made possible and granted.

2.7  Discrimination

The Business Partner shall refrain from any engaging in any form whatsoever of discrimination. No employee may be discriminated against based on their gender, age, skin color, race, culture, ethnic or national background, sexual orientation, disability, constitutionally acceptable political activities or membership in an employee organization, religion or creed or worldview.

2.8  Disciplinary Measures

All employees shall be treated with dignity and respect. Sanctions, fines, other punishments or disciplinary measures shall only be imposed in so far as they are in accordance with national and international standards in force as well as internationally recognized human rights.

The Business Partner shall take appropriate measures to ensure that no employee be subjected to verbal, psychological, sexual or bodily violence, duress or harassment

3. Environmental and Climate Protection

The Business Partner shall observe and adhere to environmental and climate protection with regard to applicable standards and legal provisions and shall establish systems and measures to minimize environmental impact and pollution on an ongoing basis. This includes preventing emissions and waste as well as taking steps to enhance resource efficiency.

4. Business Integrity

4.1 Prohibition of Corruption and other criminal acts

Fraport does not tolerate any form of corruption or other unfair business practices. The Business Partner affirms that they will not offer, promise, or grant any impermissible advantages to influence their decision-making. The Business Partner shall take all necessary measures to prevent corruption or any other criminal acts. In particular, the Business Partner is obliged to take all necessary measures in their company to avoid any misconduct on the part of their legal representatives and their employees.

4.2  Conduct in Competition

The Business Partner shall comply with all applicable national and international antitrust laws as well as the laws against unfair competition. Agreements on prices or conditions with competitors are therefore to be refrained from, as are other agreements restricting competition, which include in particular agreements with competitors for the purpose of market or customer sharing.

4.3  Avoidance of Conflicts of Interest

The Business Partner is obliged to take their decisions on the basis of objective considerations and not to allow themselves to be improperly guided by personal interests. A business partner who becomes aware of a potential conflict of interest shall take internal measures to remedy these conflicts and notify Fraport without delay.

4.4  Money Laundering

The Business Partner is required to uphold the relevant legal provisions on money laundering prevention and duly comply with their reporting obligations.

4.5  Data Protection and Data Security

The Business Partner shall comply with the applicable laws and regulations regarding data protection and data security.

5. Due Diligence in Supply Chains

The Business Partner is required to give appropriate consideration to human rights and environmental due diligence obligations and address these appropriately throughout the supply chain.

6.    Corrective Measures

The Business Partner shall inform Fraport immediately in writing of any identified risks to and violations of the principles set out in the Supplier Code of Conduct and shall take appropriate corrective measures to prevent, end, or minimize the violation. The Business Partner is obligated to always inform Fraport without delay in writing about the course and result of the clarification of the facts as well as about the measures taken, if any.

Fraport may draw up a concept for ending or minimizing a violation. The supplier will agree with Fraport on the extent to which the contract is to be adapted in order to implement this concept.

If the parties do not agree on this within a reasonable period of time or if the business partner does not comply with the requirements even after a grace period has been set, Fraport is entitled either to suspend the contract until the violations have been eliminated or to terminate the contract extraordinarily.

The Business Partner indemnifies Fraport against all claims raised against Fraport due to violations of human rights or environmental due diligence by the Business Partner. The Business Partner shall pay for the damages and costs – including the necessary legal defense – resulting from such disputes unless the Business Partner is not responsible for the violation of rights.

7. Complaints Procedure

The Business Partner shall inform all their employees as well as all business partners involved (sub-tier suppliers, suppliers, service providers) about the contents of this Code of Conduct and all relevant legal provisions in a manner that is accessible for them.

The Business Partner informs their employees and suppliers on how to access and use Fraport’s anonymous complaints procedure and requires them to pass on information about this whistleblower system throughout the supply chain.

The internet-based Business Keeper Monitoring System can be accessed via the following hyperlink:

8. Availability of the Current Supplier Code of Conduct

The Supplier Code of Conduct may be consulted and printed out from Fraport’s company website (www.

9. Inspection Rights to Verify Compliance with the Supplier Code of Conduct

Fraport shall be entitled to verify the compliance of the above-mentioned requirements itself or to have it examined by a third party who is bound by a non-disclosure obligation. The Business Partner shall assist with this process, in so far as it is reasonable. The Business Partner shall grant Fraport, or any third party instructed by Fraport, access to their premises and the opportunity to inspect their business records.