Our compliance policies

Policies

This page outlines Skyports’s commitment to compliant business practices, and the individual compliance policies we have in place.

Within this page you can find individual sections that reflect our compliance policies towards:

1. ‍Anti-Bribery and corruption
2. Human rights policy‍
3. Code of conduct for business partners‍
4. ‍Speak out policy‍
5. Employee code of conduct

Reporting non-compliance

Skyports provides a Speak Out Channel for employees, Business Partners, and third parties to report any behaviour that does not comply with our compliance policies. Skyports ensures confidentiality and protection for all those who “speak out”.

The Speak Out channel can be accessed using the link below:

https://whistleblowersoftware.com/secure/Speak-Out-Skyports

1. Anti-Bribery and corruption

Version: 2.0 – Dated: 20 October 2025

1. Policy statement

The Bribery Act 2010 came into force on 1 July 2011 and creates a framework of five criminal offences:

• Giving, promising, and offering of a bribe;
• Agreeing to receive or accept a bribe;
• Bribing a foreign official;
• Failure of commercial organisations to prevent bribery; and
• A senior officer of a commercial organisation consenting to or conniving in an act of bribery.

Skyports Limited (“Skyports”) conducts business in an honest and ethical manner. Skyports takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.

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Skyports will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including in the UK, the Bribery Act 2010, which applies to conduct both in the UK and abroad.

2. Scope

All Skyports employees and others acting on behalf of Skyports must comply with this Anti-Bribery and Corruption Policy and it extends to all business dealings and transactions in the UK and in all countries in which Skyports operates. It is essential that Skyports conducts an effective process of due diligence prior to entering into significant business relationships and that a record of this process is maintained.

Any breach of the policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned. This could constitute gross misconduct for which an offending employee may be dismissed without notice. It may also cause serious damage to the reputation and standing of Skyports.

3. Gifts and hospitality

This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, any gift or hospitality:

• must not be made with the intention of improperly influencing a Third Party or Employee to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
• must comply with local law in all relevant countries;
• must be given in the name of the organisation, not in an individual’s name;
• must not include cash or a cash equivalent;
• must be appropriate in the circumstances;
• must be of an appropriate type and value and given at an appropriate time taking into account the reason for the gift; and
• must be given openly, not secretly.

Skyports appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country. The intention behind the gift should always be considered.

It is not acceptable for an employee (or someone on their behalf) to:

• give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or Skyports will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
• give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure;
• accept payment from a Third Party where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage;
• accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by Skyports in return;
• threaten or retaliate against another member of staff who has refused to commit a bribery offence or who has raised concerns under this policy; or
• engage in any activity that might lead to a breach of this policy.

4. Facilitation payment and ‘kickbacks’

Skyports does not make, and will not accept, facilitation payments or ‘kickbacks’ of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.

As Skyports continues to expand geographically, employees may find themselves interacting with low level public officials for routine transactions, such as obtaining visas. In some regions, local customs may differ, and employees might encounter requests for small unofficial payments or gifts to expedite these services.

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Example:

Imagine you are an employee at Skyports responsible for securing visas for a team travelling to a new international location. You contact the local government office to expedite the visa process. A low level public official suggests that the process could be accelerated if you provide a personal payment or gift.

In this situation, you should:

1. Recognise the request: Understand that the request for a personal payment or gift to expedite the visa process is a facilitation payment, which is against the Skyports’ Anti-Bribery and Corruption Policy.
2. Respond appropriately: Politely decline the request and state that you are unable to make the payment requested and expect to process the visa in the standard manner.
3. Escalate internally: Immediately report the incident to your Line Manger or the Company Secretary, providing details of the interaction and seeking guidance on how to proceed.
4. Charitable donations and sponsorship

Skyports only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with Skyports internal policies and procedures.

6. Record keeping

Skyports maintains appropriate financial records and has appropriate internal controls in place

which evidence the business reason for gifts, hospitality and payments made and received.

7. Guidance for interacting with public officials

A public official is anyone in a position of authority conferred by a state, i.e. someone who holds a legislative, administrative, or judicial position, whether appointed or elected. This includes:

• Those working directly in the government or a government owned entity;
• Service providers engaged to carry out activities that would otherwise be carried out by the government;
• Officials of international public or non-governmental organisations such as the United Nations or International Monetary Fund.

The following practices are strictly prohibited by Skyports in relation to public officials:

• Promising, offering, or providing (directly or indirectly through third parties) payments, gifts, travel, entertainment, donations or any other undue advantages to public officials as a way of obtaining an advantage for Skyports.
• Promising, offering, or providing facilitation payments i.e. payments made to a public official (directly or indirectly through third parties) to secure of expedite routine government services, such as visa processing.

Relationships with local or foreign public officials must be managed only by employees authorised by the Skyports Leadership Team. These relationships must be conducted ethically and transparently as well as in compliance with this Policy and the Skyports Code of Conduct.

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Skyports maintains the following requirements in relation to the management of relationships with public officials:

• Communication with public officials must be carried out by authorised employees in a clear and objective manner through official Skyports channels such as corporate phones, corporate emails, and official letters on official corporate letterhead.
• Employees should not exchange personal messages with public officials through social media and or messaging applications which are not approved by Skyports. Business communications through messaging applications such as Whatsapp, including with government officials and regulators, are permitted as long as they comply with the principles of this policy.
• Any interaction of a strategic nature involving employees and public officials, such as lobbying or business development, must be approved by the Skyports Leadership Team.
• Formal meetings with public officials must be recorded in minutes and must be submitted in an email from the Skyports attendee(s) present to the Company Secretary, where a bribery and corruption concern has been identified.

Skyports also upholds the following practical considerations for interacting with public officials via meetings or inspections:

• Meetings or inspections involving public officials must be attended by at least two authorised representatives of Skyports;
• Meetings or inspections involving public officials should be held during business hours;
• Participation by Skyports employees in events held by public officials must be recorded in an email sent to the Company Secretary;
• If a bribe is requested as part of a meeting or an inspection involving a public official, the relevant employee must immediately refuse (except where there is a risk to life, limb or liberty) and inform the Company Secretary of the incident in writing.

8. Responsibilities and raising concerns

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for Skyports or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees are required to notify Skyports management as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Any concerns relating to a breach of the Policy should be reported to the Company Secretary.

9. Communication and review
10. Further information and guidance

This policy sets out the key principles which Skyports must adhere to. The UK Bribery Act 2010 can be viewed at: http://www.legislation.gov.uk/ukpga/2010/23/contents?view=plain

2. Human rights

Version: 2025 – Dated: 20 October 2025

1. Introduction and commitment

At Skyports (“us”, “the Organisation”), we are committed to upholding the highest standards of integrity, honesty, transparency, and compliance in all aspects of our operations. We expect our Employees, representatives, and those acting on our behalf to act ethically, with professionalism and fairness, and in adherence to all applicable laws and regulations.

We are dedicated to running our business in a way that respects human rights and the dignity of all individuals, while complying with all relevant laws and regulations. However, where national laws and regulations differ with international human rights standards, we commit to respecting the higher standards. Where there is a conflict between the two, we aim to respect international standards to the greatest extent possible.

This policy defines human rights as encompassing, at the very least, all recognised rights outlined in the International Bill of Human Rights, including the Universal Declaration of Human Rights, and the International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work. We are committed to upholding these rights and expect our employees, suppliers, customers, and other partners to do the same.

Skyports is dedicated to identifying, assessing, preventing and mitigating any adverse impacts on human rights for people involved in its operations and global supply chain. To achieve this, Skyports is working towards alignment with the following global guidelines:

• United Nations (UN) Guiding Principles on Business and Human Rights (2011); and
• Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises (2011).

2. Scope and application

This Human Rights Policy applies to all directors, executives and employees of Skyports as well as all Skyports activities. The Policy outlines our commitment to respecting the human rights of all people in our sphere of influence, including through our role as an employer, procurer and provider of services.

The Skyports Leadership Team will ensure everyone follows this Policy and that it is referenced in other policies and procedures across the company as required.

All employees of Skyports must adhere to this policy, promoting a unified approach to human rights throughout our operations and supply chain.

The issues outlined within this Policy will be picked up through our Code of Conduct for employees and our Supplier Code of Conduct for business partners.

3. Commitments to human rights

Commitments to Workers in the Supply Chain

We are committed to upholding the rights of our employees, temporary staff and business partners. We expect everyone to follow the ILO Declaration on Fundamental Principles and Rights at Work and to uphold the following commitments, which align with the commitments of our parent, Actividades de Construcción y Servicios S.A (ACS Group):

• Eradication of Child Labour: We reject all forms of child labour and slavery, ensuring compliance with ILO standards to promote safe childhoods and ensure adherence to applicable laws regarding minimum legal age.
• Elimination of Forced Labour and Human Trafficking: We oppose forced labour, slavery, and human trafficking, working to minimise these risks in our operations and supply chain. To uphold these principles, we actively work to prevent slavery and human trafficking in our business and supply chains. Our Modern Slavery and Human Trafficking Statement explains our approach.
• Decent Work: We support fair wages and decent working conditions, ensuring pay meets basic needs and complies with national laws. Workers should have clear rules on hours, breaks, and pay.
• Diversity and Inclusion: We promote a diverse and inclusive workplace, free from discrimination and harassment. We have zero tolerance for discrimination based on gender, race, religion, age, disability, sexual orientation and/or socio-economic background.
• Fair Recruitment Practices: We protect workers’ rights in the recruitment process, ensuring no recruitment fees, deception, or coercion. Workers should always have access to their documents and be free to leave employment without penalty.
• Health and Safety: We provide a safe and health working environment with necessary protective equipment. We aim for zero accidents and comply with all relevant health and safety regulations.
• Accommodation and Living Conditions: Where provided, accommodation for Skyports workers must be safe, clean, and offer access to essential services like water and electricity.
• Freedom of Association: We support workers’ rights to join unions and engage in collective bargaining (where local law permits) without interference, discrimination, retaliation, or harassment.
• Work-Life Balance: We respect the right to rest and promote actions for employees’ well-being.
• Equal Opportunities: We ensure equal opportunities for all employees, with promotions based on merit and abilities.
• Education and Training: We offer training to help employees grow and understand their rights and duties.

Commitments to Consumers and End-Users

We aim to meet the needs of our consumers and end-users by focusing on quality and service excellence:

• Data Privacy: We protect personal data and ensure confidentiality according to the law.
• Quality and Safety: Our services are safe and accessible, with emergency plans in place.
• Responsible Development: We aim to use products sustainably, considering their social and environmental impacts.
• Non-Discrimination: We reject discrimination in all consumer interactions and ensure accessibility for all.

Commitments to the Environment and Local Communities

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We are dedicated to protecting the environment and local communities:

• Clean Environment: We acknowledge how environmental degradation can lead to adverse impacts on human rights. We commit to respecting the right to a clean, healthy, and sustainable environment and we implement pollution prevention measures to protect natural resources and community health.

4. Speak Out and raising concerns

If you know of, or suspect, any breach of this policy, you must report it using the channels provided. Besides the informal ways of raising a concern (for example, speaking with your line manager) you can also report through our formal Speak Out platform which is available on our website and can be accessed using the below link:

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https://whistleblowersoftware.com/secure/Speak-Out-Skyports

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This channel operates under principles of confidentiality and respect, ensuring that all rights and guarantees are upheld throughout the process. This includes analysing and verifying reports, resolving issues, and taking corrective actions if needed.

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Skyports will ensure that no retaliation occurs against the Reporter from supervisors or anyone else involved in the reported matters. The confidentiality of the complaint is protected, along with the privacy and reputation of everyone involved, directly or indirectly.

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If you have questions about this Policy or the commitments above, you can ask your line manager or the Company Secretary.

5. Breach of policy

Failure to comply with this Policy may have serious consequences for both Skyports and the individuals involved.

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Any breaches may result in disciplinary action in line with applicable employment laws and the disciplinary framework, in addition to any other legal liabilities that may arise.

6. Entry into force and review

This policy takes effect upon its approval by the Skyports CEO. The Company Secretary is responsible for reviewing the policy, every 2 years, to ensure it remains aligned with current business practices and regulatory expectations. The Skyports Leadership Team is ultimately accountable for human rights. Any ongoing policy updates will be submitted for consideration and approval to the Skyports Leadership Team, who will escalate major updates to the Skyports CEO as appropriate.

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3. Code of conduct for business partners

Version: 2025 – Dated: 20 October 2025

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1. Purpose

Skyports is dedicated to maintaining strong relationships with its suppliers, advisors, and all business partners. This commitment is rooted in adhering to laws across the regions where we operate and upholding our values. This Code of Conduct for Business Partners outlines the ethical standards expected from our Business Partners. If Business Partners subcontract work for us, they must ensure their subcontractors also follow this Code where applicable.

2. Scope of Application

This Code applies to all Business Partners of Skyports, irrespective of their location. Business Partners must formally accept this Code by signing the attached agreement. However, if they have a similar Code of Conduct or equivalent internal rules and Skyports agrees, they may be exempt from signing.

3. Principles of the Code

Integrity and Legality

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Business Partners are expected to operate with integrity, ensuring compliance with all applicable laws and regulations in their respective jurisdictions. They should establish monitoring and control mechanisms to uphold these standards and be able to report to Skyports regarding their overall compliance programme, when requested.

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Prevention of Conflicts of Interest

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Business Partners should act in the best interests of both their organisation and Skyports, avoiding decisions based on personal interests. They must anticipate and prevent potential conflicts of interest and promptly disclose any unavoidable conflicts to Skyports.

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Anti-Bribery and Corruption

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Business Partners must adhere to all anti-corruption laws, prohibiting any form of corruption, including bribery, fraud, and extortion. They should avoid making or accepting improper payments or gifts and implement measures to prevent such practices, reporting to Skyports where appropriate.

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Fair Competition

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Business Partners should engage in honest and fair competition, complying with antitrust laws and avoiding practices that undermine free competition. They must not misuse market power or engage in deceptive conduct and should report on their compliance measures to Skyports when requested.

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Tax Liability

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Business Partners are responsible for complying with tax regulations, actively preventing tax evasion, and cooperating with tax authorities. They should ensure accurate reporting of financial information and avoid obtaining undue tax benefits.

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Confidentiality and Data Protection

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Business Partners must maintain the confidentiality of all non-public information received from Skyports and implement data safety measures to protect this information. Any data breaches or incidents must be reported to the Skyports Data Protection Officer.

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Business Partners must also respect and protect intellectual property rights, both their own and those of third parties. They should ensure data privacy and implement necessary security measures to safeguard this information.

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Respect for Human Rights

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Business Partners are expected to uphold human rights and labour rights, avoiding forced labour, child labour, and discrimination. They should respect freedom of association, provide fair working conditions, and ensure diversity and inclusion within their operations.

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Specifically, Skyports sets the following expectations for its business partners with regard to human rights:

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No modern slavery, forced labour, or child labour:

• No modern slavery, including forced, compulsory, or bonded labour
• No human trafficking
• Employment is freely chosen and workers are free to leave employment
• Prohibit confiscation of workers original identification documents and the use of work-paid recruitment fees
• Adhere to applicable laws regarding minimum legal age and do not engage in child labour
• No employment of young persons under 18 in hazardous conditions

Fair wages, benefits, and working hours:

• Adhere to all applicable laws with regards to working hours and overtime
• Fair approach to remuneration, and pay at least the applicable minimum wage
• All workers are provided with written and understandable information about their employment before they enter employment

Freedom of association and right to collectively bargain:

• Workers can freely associate with others, join unions and bargain collectively without interference, discrimination, retaliation, or harassment, where law permits

Equal opportunity:

• Uphold an inclusive environment where everyone is treated with respect and dignity;
• Prohibit any discrimination on the basis of gender, race, religion, age, disability, sexual orientation and socio-economic background, among other characteristics protected by local law;
• Policies support an environment which is free from abuse, harassment, victimisation, and bullying.

Health and Safety

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Business Partners must comply with health and safety regulations, implementing measures to identify, evaluate, and mitigate workplace risks. They should inform Skyports of any relevant health and safety hazards and the measures in place to address them.

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Environmental Protection

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Business Partners should commit to environmental protection, following principles of sustainability, resource efficiency, and pollution prevention. They must report to Skyports any significant environmental incidents that could impact the Company.

4. Communication Channels

Skyports provides a Speak Out Channel for employees, Business Partners, and third parties to report any behaviour that does not comply with this Code. Business Partners are encouraged to use and internally promote this Speak Out channel to report non-compliance. Skyports ensures confidentiality and protection for all those who “speak out”.

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The Speak Out channel can be accessed using the link below:

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https://whistleblowersoftware.com/secure/Speak-Out-Skyports

5. Non-Compliance with the Code

Skyport’s Code of Conduct for Business Partners is mandatory and integral to our professional relationships. Violations can have serious consequences and may lead to legal action. Business Partners must promptly report any non-compliance with this Code. If a breach occurs, Skyports will take immediate action within the relevant legal framework, with responses proportionate to the severity of the breach. This may include corrective actions, suspension or termination of contracts, official complaints, or claims for damages.

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4. Speak Out Policy

Version: 2025 – Dated: 20 October 2025

1. Purpose of the Policy

The purpose of this Speak Out Policy is to outline how employees within Skyports, as well as the company’s business partners and third parties, can report any concerns regarding suspected non-compliance. This policy will explain the different formal methods available for raising a concern, noting that concerns can also be raised informally, e.g. to a line manager. If communicating with a relevant line manager does not resolve the issue, or if you feel uncomfortable in doing so, the channels mentioned in this policy can be used.

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The main goal of this policy is to offer guidance, assurance, and protection to anyone who reports a violation. Skyports strictly prohibits any retaliation against those who report concerns in good faith.

2. Scope of application

This Policy can be used by all Skyports shareholders, management, employees (permanent and temporary) and associated third parties (collectively, “Stakeholders”). We will try to ensure that the principles in this policy also apply to our partnerships and joint ventures that we do not fully control.

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Everyone in our company must follow this policy, no matter their role or position. This policy covers all concerns and complaints raised by anyone at Skyports, as well as our business partners and third parties. It also applies to anyone who is not part of Skyports’ work but knows of or suspects non-compliance at Skyports as a result of their relationship with us.

3. About speaking out

At Skyports, “Speak Out” refers to the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:

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• criminal activity;
• failure to comply with any legal or professional obligation or regulatory requirements;
• danger to health and safety;
• damage to the environment;
• bribery and corruption;
• financial fraud or mismanagement;
• human rights and modern slavery violations;
• breach of competition legislation or anti-competitive practices and concerns;
• breach of our internal policies and procedures, including our Code of Conduct;
• conduct likely to damage our reputation or financial wellbeing;
• unauthorised disclosure of confidential information;
• negligence;
• the deliberate concealment of any of the above.

A Reporter is a person who raises a genuine concern relating to any of the above. If you have any concerns related to suspected wrongdoing or danger affecting any of our activities (a “speak-out concern”) you should report it under this policy.

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This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases, you should use other appropriate policies such as the Grievance Policy. In case of doubt regarding the scope of this Policy, advice should be sought from the Head of People.

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UK whistleblowing law is set out in the Employment Rights Act 1996 (as amended by the Public Interest Disclosure Act 1998). It provides the right for a worker to take a case to a tribunal if they have been victimised at work or they have lost their job because they have ‘blown the whistle’.

4. Skyports’ internal policies for speaking out

Skyports is committed to acting as a responsible business and employer, providing training to employees at all levels of the organisation in relation to whistleblowing law, the organisation’s policy and the organisation’s procedures for speaking out.

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On joining Skyports, employees will be provided with all company policies, and upon receipt, will be asked to confirm that they have read and understood these. Each employee’s line manager will be responsible for ensuring that this process is carried out, and will act as the first point of contact for any questions that employees may have in this regard.

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The management of complaints or concerns raised through adherence to this policy will always be guided by the following principles and guarantees:

• No Retaliation: Skyports prohibits retaliation, discrimination, or sanctions against anyone who reports issues in good faith or refuses to participate in illegal / non-compliant activities.
• Confidentiality: Information from complaints must remain confidential. Only essential details should be shared on a need-to-know basis. If others join the investigation, they must also maintain confidentiality.
• Objectivity & Impartiality: Investigators must remain objective and impartial and must consider all of the available facts.
• Adequacy & Sufficiency: Skyports will provide necessary resources for investigations and ensure decisions are justified and traceable.
• Proportionality: Sanctions should match the severity of the findings and be fair, with due process allowing individuals to defend themselves.
• Presumption of Innocence: Implicated employees are considered innocent until they are proven to be otherwise.
• Regulatory Compliance: Investigations must respect legal rights and ethical standards, allowing accused individuals to defend themselves.
• Whistleblower Protection: Reporters’ identities are protected, and Skyports does not tolerate retaliation. This protection extends to respondents and relevant parties, like family members.
• Investigation of Violations: Any breach will be investigated, and appropriate sanctions will be applied. Temporary measures may be taken during investigations.
• Good Faith Requirement: Protection is provided if reporters act in good faith and believe their information/concern is true.

5. Skyports’ internal procedures for speaking out

Skyports is committed to cultivating a culture of openness and accountability and creating a transparent and safe working environment where employees always feel able to speak out.

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Skyports is committed to treating all disclosures consistently and fairly, and to taking all reasonable steps to maintain the confidentiality of the Reporter where this is requested (unless required by law to break that confidentiality). Any so-called ‘gagging clauses’ in settlement agreements do not prevent workers from making disclosures in the public interest.

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Any report/disclosures raised, through the formal channels raised in this policy, will be referred immediately either to the Head of Health and Safety for concerns or incidents relating to health and safety or the Head of People for other matters. Cases will be fully investigated with appropriate corrective action taken. The Reporter does not need to provide evidence for the employer to look into the concerns raised.

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Reporters can expect to receive regular feedback on how their disclosure is being handled, any investigative measures that are being taken and any actions that are being taken where applicable.

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Anonymous Reporters will not ordinarily be able to receive feedback, and any action taken to look into a disclosure could be limited. Anonymous Reporters may seek feedback through a telephone appointment or by using an anonymised email address.

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Once Skyports is satisfied that a disclosure has been acted upon appropriately and that the issue has been resolved, this will be promptly communicated with the Reporter.

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Skyports is committed to ensuring that any victimisation of a Reporter is not acceptable, and any instances of victimisation will be taken seriously and managed appropriately.

6. How to speak out

When to raise a concern

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Employees should report suspected wrongdoing as soon as possible, but in the knowledge that their concerns will be taken seriously and investigated as appropriate, that their confidentiality will be respected and that they will not be discriminated against for what they report, even if it turns out to be mistaken (provided the report was made in good faith).

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How to raise a concern and with whom

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We hope that in many cases employees will be able to raise any concerns with their manager. However, concerns can also be raised through the reporting channel:

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https://whistleblowersoftware.com/secure/Speak-Out-Skyports

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Please refer to the user manual for practical guidance on how to use the reporting channel.

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This reporting channel will be managed and overseen by the Head of People.

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What information is needed when raising a concern

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Reporters are encouraged to provide as much detailed information as possible about any potential violations. It is also helpful to include or clearly reference any evidence or documents that support the complaint. This helps us address the issue quickly and efficiently. It’s important to provide evidence that has been obtained legally and does not infringe on the rights of those involved in the complaint or any third parties.

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Once a concern is raised

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Skyports management will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. This colleague or union representative must respect the confidentiality of your disclosure and any subsequent investigation.

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We will take down a written summary of your concern and provide you with a copy after the meeting. We will also aim to give you an indication of how we propose to deal with the matter.

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In some cases, we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing.

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We will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.

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If we conclude that a Reporter has made false allegations maliciously, the Reporter will be subject to disciplinary action.

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Confidentiality

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We hope that you will feel able to voice Speak Out concerns openly under this policy. However, if you want to raise your concern confidentially, we will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you. The Speak Out channel should provide you with the option to raise a concern anonymously.

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We do not encourage staff to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether allegations are credible if the Reporter is anonymous. Reporters who are concerned about possible reprisals if their identity is revealed should come forward to the Head of People or a more appropriate individual and adequate measures can then be taken to protect confidentiality.

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External disclosures

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The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. It will very rarely, if ever, be appropriate to alert the media. We strongly encourage you to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Protect, operates a confidential helpline. They also have a list of prescribed regulators for reporting certain types of concern.

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Speak Out concerns usually relate to the conduct of our staff, but they may sometimes relate to the actions of a third party, such as a customer, or service provider. In some circumstances the law will protect you if you raise the matter with the third party directly. However, we encourage you to report such concerns internally first. You should contact a manager or the Speak Out channel in these cases.

7. Protection of the parties involved in a concern

Skyports will protect and support both the Reporter and any relevant parties involved in a complaint from any harm they might face for reporting possible violations.

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Scope of protection

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Protection covers all forms of retaliation or harmful actions against Reporters and relevant parties. This includes any direct or indirect actions or threats that could cause harm, whether professionally or personally.

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Protection and support measures

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Protection involves taking steps to prevent harm and maintain the confidentiality of the Reporter and relevant parties. This can include psychological, financial, legal, or reputational support. Support also means reassuring these individuals about the importance of reporting violations and helping with their well-being. The Leadership Team ensures these measures are in place. If harmful conduct is identified, appropriate actions will be taken to stop it.

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Protection measures for the respondent

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Skyports will also provide protection for the respondent. This includes keeping their identity confidential and protecting them from reputational damage during the investigation. The respondent has the right to defend themselves, present evidence, and access the case file to understand the allegations and data protection rights. If no evidence of violations is found, further remedial actions will be taken.

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Activation of protection

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Protection and support for Reporters, relevant parties, and respondents begin as soon as a complaint is received and continue throughout and after the investigation process.

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Concerns raised in bad faith

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Protection and support from Skyports are available only if the Reporter submits their complaint in good faith.

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The Reporter should have reasonable grounds to believe that the information they are reporting is true, based on the circumstances and information they have. Good faith means having a reasonable belief that the reported information about possible violations was true when it was reported.

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Anyone who intentionally provides false or misleading information will not receive protection. Additionally, our company will review each case to decide on appropriate disciplinary actions for our Stakeholders or commercial actions against business partners and third parties who file complaints in bad faith.

8. Protection of personal data

Skyports handles data from the Speak Out process according to current data protection laws, ensuring privacy, security, and data preservation. This applies to all personal data related to complaints. Data processing aims to manage and resolve inquiries or complaints, assess allegations, investigate violations, and take necessary actions. Data is collected from Reporters, relevant parties, or authorised third parties, ensuring confidentiality and security.

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All Skyports Stakeholders must provide accurate and lawful information, especially through the Speak Out Channel, and are responsible for any intentionally misleading statements. Communication channels with the Leadership Team are secure, adhering to data protection regulations. Reporters can raise concerns anonymously without personal data collection.

Access to personal data is limited to specific roles, including data processors, and the Data Protection Officer.

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Preservation of Information

‍

Skyports manages and retains complaint-related data per data protection regulations. Information is kept by the Head of People and deleted, blocked, or anonymised after legal deadlines. Complaints are recorded confidentially and retained only as long as legally required. Data is kept for up to twelve months unless an investigation is initiated. If not investigated, data is anonymised. If data is false, it is deleted unless needed for legal proceedings.

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Additional Information

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Individuals can obtain more details about data processing from the Data Protection Officer.

9. Further advice for those thinking of speaking out

Further information and advice for those thinking of speaking out, can be found at the following locations online:

• https://www.acas.org.uk/archive/whistleblowing
• https://webarchive.nationalarchives.gov.uk/20210103184947/https://www.gov.uk/government/publications/blowing-the-whistle-list-of-prescribed-people-and-bodies–2
• https://www.gov.uk/whistleblowing
• https://protect-advice.org.uk/pida/

10. Entry into force and review

This policy takes effect upon its approval by the Skyports CEO. The Head of People is responsible for reviewing the policy, every 2 years, to ensure it remains aligned with current business practices and regulatory expectations. Any ongoing updates will be submitted for consideration and approval to the Skyports Leadership Team, who will escalate major updates to the Skyports CEO for approval as appropriate.

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Annex 1

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Definitions

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Business Partners: Any legal or natural person, except Skyports Stakeholders, with whom Skyports maintains or plans to establish some type of business relationship. By way of example, but not limited to, external advisors, joint ventures or individuals or legal entities contracted by Skyports for the delivery of goods or provision of services are included.

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Communication: A statement that records a question about the scope, interpretation, or compliance with the regulations applicable to Skyports. Depending on its content, a communication may consist of an Inquiry or a Concern.

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Concern: Communication regarding a possible Violation (active or omissive behaviour) of the regulations applicable to Skyports, understood as the set of ethical commitments and compliance voluntarily assumed by Skyports, as well as the legislation in force that is always applicable.

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Reporter: An individual or entity that raises a concern, including.

– Stakeholders

– Business partners

– Third parties and other individuals such as, for example, labour union representatives

– Any person or entity within the above contexts.

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Harmful Conduct: Any act or omission, whether attempted, threatened, or actual, direct, or indirect, intentional, or negligent, that may result in harm or disadvantage to the Reporter or other Relevant Interested Parties, both in the workplace and in the personal sphere, solely because of their status in relation to the Reporter because they have made a public disclosure.

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Inquiry: Communication by which any Skyports Stakeholder requests a clarification, response or opinion on the scope, interpretation, or compliance with the regulations applicable to the Skyports.

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Skyports: Skyports Limited

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Stakeholders: Members of Skyports management, employees and personnel (permanent or temporary).

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Relevant Interested Parties: A party that can affect, be affected by, or perceive itself to be affected by the Concern. This includes the following:

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– Witnesses, or other people involved in the Concern.

– Investigators.

– family members, union representatives, and other people supporting the Whistleblower.

– Those from which the information that motivated the filing of a Concern is obtained.

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Respondent: Natural or legal person(s) linked to the reported violations, as perpetrators, participants or even accessories. They may be identified in the Concern or within the subject of the Inquiry.

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Retaliation: Any action or omission, whether attempted, threatened, or actual, direct, or indirect, that may result in harm or disadvantage to the Reporter or other Relevant Interested Parties, in the work or professional sphere, solely because of their status in connection with the Complaint or because they have made a public disclosure.

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Third Party: Natural or legal person or body independent from Skyports.

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Violation: Behaviour, active or omissive, that involves the violation of applicable laws and/or regulations applicable to Skyports, including, among others and when relevant, any violation of regulations and/or serious or very serious criminal, administrative or labour violations relating to occupational health and safety at work, established in the UK legal system, occurring within Skyports. A violation, depending on its seriousness, may range from a mere formal violation of a requirement included in an internal rule, to the commission of acts constituting a crime potentially attributable to Skyports.

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Annex 2

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Examples of possible retaliation and harmful conduct

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The following are some behaviours that may be considered as Retaliation or Harmful Conduct:

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– Dismissal, suspension, removal, or equivalent measures.

– Early termination or cancellation of contracts for goods or services.

– Non-renewal or early termination of a temporary employment contract.

– Change of job position or duties, change of work location, reduction in salary or change in working hours or other working conditions.

– Demotion or denial of promotion.

– Imposition of any disciplinary measure, reprimand, or other sanction, including monetary sanctions.

– Denial of services.

– Denial of training.

– Damage, including to your reputation, especially on social media, or economic loss, including loss of business and revenue.

– Any type of act, intentional or reckless, that causes harm, physical or psychological.

– Medical or psychiatric referrals.

– Negative performance evaluation or adverse references regarding your employment.

– Coercion, intimidation, harassment, ostracism, or isolation.

– Discrimination, unfavourable or unfair treatment.

– Blacklisting from a project, which may imply that in the future the person will not find employment in that sector.

– Disclosure of the Reporter’s identity.

– Financial loss.

– Cancellation of a licence or permit.

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Annex 3

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Examples of protections and support measures

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If Whistleblowers and other Relevant Interested Parties may be subject to any Retaliation or Harmful Conduct, the protective measures may be invoked to:

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– Reinstate the Whistleblower Relevant Interested Party in the same or equivalent position, with equal salary, responsibilities, job position and reputation.

– Enable equitable access to promotion, training, opportunities, benefits, and rights.

– Restore the Whistleblower Relevant Interested Party to the previous commercial position in relation to Skyports, if applicable.

– Withdraw litigation.

– Apologise for any damage suffered.

– Grant compensation for damages.

5. Employee code of conduct

Version: 2025 – Dated: 20 October 2025

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‍Message from the CEO

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At Skyports, our mission to transform global mobility through advanced air infrastructure is built on a foundation of trust, innovation, and responsibility. As we pioneer new frontiers in aviation and logistics, it’s essential that our actions reflect the highest standards of integrity and professionalism.

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Our Code of Conduct is a shared commitment to doing what’s right. It guides how we work with each other, our partners, and the communities we serve. Whether you’re in operations, commercial or support functions, your decisions shape our reputation and our future.

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I ask every member of the Skyports team to read, understand, and live by this Code. Speak up when something doesn’t feel right, support one another in making ethical choices, and never compromise on safety, fairness, or respect. Together, we can build a culture that not only drives innovation but earns trust—every day.

‍

Duncan Walker

Chief Executive Officer

Skyports Limited

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1. Purpose

At Skyports (“us”, “the Organisation”), we are committed to upholding the highest standards of integrity, honesty, transparency, and compliance in all aspects of our operations. We expect our representatives to act ethically, with professionalism and fairness, and in adherence to all applicable laws and regulations.

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The purpose of this Code of Conduct (“the Code of Conduct”, “the Code”) is to set the ethical principles that guide the actions of Skyports. It outlines the main standards that everyone working at the Organisation must follow. If local rules are stricter than this Code, they will take priority. However, we will not follow local customs if they go against the principles in this Code.

2. Scope

The Code applies to board members, management, and all employees connected to Skyports, regardless of their legal relationship.

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We also expect our suppliers, advisors, and business partners to follow equivalent ethical standards and principles. Skyports maintains a “Supplier Code of Conduct” setting out further information on the standards we expect in this area.

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Our values are integral to accomplishing our mission and include:

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Safety and Integrity: This is our priority. If something doesn’t look right, fix it.

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Think Big: We are tackling big problems which will make a huge difference. Don’t lose sight of the scale of what we can achieve, environmentally, economically and socially.

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Action over Talk: Make informed decisions quickly, then execute.

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Own it: success relies on owning problems. Don’t make them someone else’s.

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Be Candid, Honest and Respectful: Growth requires bold, candid communication. Get to the point.

3. How should I use the Code?

Skyports’ Code of Conduct should be used as a guide and resource for legal and ethical behaviour in the workplace, helping the Organisation live its values in practice. It is essential that we all follow the policies referred to in this Code as well as the Code’s principles, in addition to fulfilling our legal obligations. You are encouraged to familiarise yourself with the Code, focusing on areas which are relevant to your work and daily activities. If you feel that a working practice is not lawful, ethical or safe and/or it is in breach of this Code, please Speak Out.

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If you have any questions concerning this Code, please contact your Line Manager in the first instance or the Company Secretary.

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We all have a responsibility to follow the Code and each of us will be held accountable for our conduct. Failure to follow this Code or any of Skyports’ policies may lead to disciplinary action.

4. Principles of the Code of Conduct

Anti-Bribery and Corruption

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Skyports is dedicated to combating bribery. It is strictly forbidden to promise, offer or provide any payments, gifts, hospitality or favours with the intention of securing an undue business advantage for the company (either directly or through a third party).

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The following section sets out our approach to bribery and corruption in more detail and provides links to the relevant policies where applicable. For further information, please refer to our dedicated Anti-Bribery and Corruption Policy.

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Gifts and Entertainment

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The giving and receiving of gifts and hospitality may be allowed if it is legal, aligned with our relevant policies and of minimal financial value. However, Skyports forbids its employees from giving or accepting gifts or entertainment that could be perceived as a bribe and/or could lead to an improper business advantage.

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For more information, please refer to our Gifts and Hospitality Policy.

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Charitable Donations

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Skyports supports making charitable donations in the communities where we operate, but these require internal approval. Donations should not appear as disguised bribes. Whenever possible, donations should be in kind and meet a real need in the community, like providing sports equipment to a local school. Donations should be made directly to the charity, and a receipt should be obtained.

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Sponsorships

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Skyports may sponsor projects and activities that align with its social or institutional goals or to promote its activities. Sponsorships are acceptable if they do not create a conflict of interest and serve their intended purpose. All sponsorships should be transparent and made in good faith, following Skyports policies. Sponsorships must not be given to beneficiaries with a known history of bribery, corruption, fraud, or other illegal activities.

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Political Contributions and Activities

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Skyports does not make contributions, in cash or otherwise, to any political candidate, party, or organisation. This includes making political statements or supporting political parties and candidates. However, you are free to support political candidates or organisations personally, as long as you do so on your own time and with your own resources.

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Facilitation payments

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In some countries, small payments to foreign government officials for routine actions might be allowed, but they can be illegal under local laws and international laws like the UK Bribery Act, which applies to the operations of Skyports even outside the UK. These payments are often made to speed up processes like invoices or visas.

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Skyports does not allow facilitation payments, except in rare cases where the payment is necessary to prevent an immediate threat to an employee’s health, safety, or welfare. If you are unsure about a payment, seek advice. If you’re asked to make a payment that makes you uncomfortable or you suspect facilitation payments are being requested, report it to the Company Secretary, the Head of People or using the Speak Out Channel.

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Conflict of Interest

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A conflict of interest at Skyports occurs when personal interests improperly influence—or seem to influence—decisions, potentially harming the company’s best interests. This can happen when personal or others’ interests interfere with Skyports’ values or duties.

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Common examples include personal relationships affecting work objectivity, holding a second job that impacts Skyports responsibilities, or having financial interests in companies doing business with Skyports.

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Employees must avoid situations that could lead to conflicts of interest. If a potential conflict arises, employees should act in Skyports’ best interests, disclose the situation promptly, and avoid decision-making related to the conflict until it can be mitigated.

For more information, please refer to our Conflicts of Interest Policy.

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Respect for Health and Safety

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Skyports Group is committed to protecting the health, safety and well-being of its employees, contractors, visitors and anyone else who comes into contact with our operations worldwide.

We recognise that a positive health and safety culture not only safeguards people and property, and protects the business from reputational harm, but also enhances the performance of its employees.

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For more information, please refer to our Group Health & Safety Policy.

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Data Protection

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Employees must use the IT systems and resources provided by Skyports appropriately, following the Acceptable Use Policy and applicable guidelines and rules. They must strictly adhere to control measures for protecting personal data. Skyports provides the necessary resources for work activities, and all members should use these resources responsibly, efficiently, and appropriately, in line with the rules for using information systems.

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For more information, please refer to our Acceptable Use Policy.

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Skyports is committed to complying with data protection laws, specifically the EU General Data Protection Regulation (GDPR) and the Data Protection Act (DPA) 2018. These laws guide how we process personal data in the UK.

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Our data protection practices apply to all employees, partners and suppliers who handle our information, whether stored in our systems or managed by others on our behalf. This includes all formats of data, such as printed and digital information, documents, and recordings. We collect and use personal information about individuals, including suppliers, customers, and partners as part of our business operations. Therefore, we must treat this information lawfully and correctly, recognising its importance in maintaining trust.

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Skyports will comply with data protection laws, meet our data protection standards, protect the rights of individuals we interact with, and safeguard the organisation from data protection breaches.

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For more information, please refer to our Data Protection Policy.

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Unfair Competition

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We work in a competitive environment and compete actively to identify and capitalise on new business opportunities. However, in doing so, we also ensure that we comply with all applicable competition legislation and avoid behaviour that could be seen as anti-competitive, such as price fixing.

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Competition law ensures fair market competition for the benefit of consumers. It prohibits agreements between businesses that restrict competition and prevents dominant companies from exploiting their position. In the UK, this is governed by the Competition Act 1998 and the Enterprise Act 2002. In the EU, it falls under the Treaty on the Functioning of the European Union. In the US, antitrust laws like the Sherman Act and the Clayton Act apply.

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At Skyports, we are committed to maintaining high ethical standards and conducting our business with honesty and integrity, in line with all applicable laws, including competition laws. We do not tolerate any behaviour that breaches these laws or could be perceived as anti-competitive.

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For more information, please refer to our Competition Policy.

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Respect for Human Rights

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Skyports is committed to acting in accordance with internationally recognised human rights standards. In practice, our commitments can be summarised as:

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Equal Opportunities: We support the professional and personal growth of all employees, ensuring equal opportunities. Hiring and promotions are based on merit and ability.

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Non-Discrimination: We reject discrimination of any kind, including race, nationality, age, gender, sexual orientation, religion, or any personal or social conditions. Harassment and intimidation are not tolerated, and disciplinary actions will be taken if they occur.

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Union Freedom: We support and respect the right of employees to join unions and associate freely.

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No Child Labour: We do not use child labour and ensure our suppliers comply with International Labour Organisation (ILO) standards.

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No Forced Labour: We do not use forced labour and ensure all employees have a good work-life balance. We avoid working with suppliers or contractors who infringe these rights.

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Respect for Minority Rights: We respect the rights of minorities and disabled persons, in line with our corporate values and relevant international standards.

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Community Commitment: We are committed to respecting human rights in our communities, conserving natural resources, and supporting community health and well-being.

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For more information, please refer to our Human Rights Policy.

5. Body responsible for compliance functions

The body responsible for the Compliance function at Skyports is the Leadership Team. Details of the Leadership Team can be found on our website.

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The Leadership Team is responsible for:

• Promoting understanding of and adherence to the Skyports Code of Conduct;
• Establishing a compliance system, monitoring its operation and effectiveness, and regularly reviewing it to ensure it prevents improper conduct;
• Promoting ethical and responsible behaviour among all Skyports employees;
• Ensuring that compliance training programmes are developed and implemented.

All employees and departments within Skyports must cooperate with the Leadership Team as it carries out the responsibilities above, for example by completing all necessary compliance training in accordance with relevant deadlines.

6. Speak Out

If you become aware of, or suspect, a breach of this Code or our other policies, you must report it:

• to a line manager or any other manager;
• to any member of the Leadership Team;
• to the Company Secretary; or
• via our Speak Out Channel.

For more information, please refer to our Speak Out Policy and Speak Out Channel.

https://whistleblowersoftware.com/secure/Speak-Out-Skyports

7. Consequences of failing to comply with the Code

Compliance with this Code of Conduct and all other Skyports policies is mandatory. Breaking these rules can have serious consequences up to and including dismissal.

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If a breach of this Code of Conduct or our other policies is reported (see above), Skyports will respond immediately, taking appropriate action to investigate and resolve the issue. The response will match the severity of the breach, regardless of the employee’s position in the firm.

8. Entry into force and review

This Code of Conduct takes effect upon its approval by the Skyports CEO. The Company Secretary is responsible for reviewing the Code of Conduct, every 2 years, to ensure it remains aligned with current business practices and regulatory expectations. Any ongoing updates will be submitted for consideration and approval to the Skyports Leadership Team, who will escalate major updates to the Skyports CEO as appropriate.