Summary
Details
- Global
Mandatory obligations include:
compliance with Azul’s supplier conduct expectations.
compliance with supplier approval requirements.
prohibition of slave labour and child labour by suppliers and business partners.
third-party due diligence cooperation.
compliance with applicable laws and regulations.
conduct compatible with Azul’s values and rules.
integrity and anti-corruption expectations.
Functionally mandatory obligations include:
fuel and emissions data for fuel suppliers.
SAF documentation for SAF suppliers.
environmental data for high-impact suppliers.
maintenance and efficiency data for MRO providers.
waste and packaging data for catering and onboard suppliers.
cargo and logistics data for relevant partners.
documentation supporting ESG reporting.
evidence supporting ProBioQAV and CORSIA readiness where applicable.
The strongest obligations apply to:
fuel suppliers.
SAF providers.
aircraft and engine suppliers.
MRO providers.
airport service providers.
catering suppliers.
waste contractors.
cargo and logistics partners.
high-risk third parties.
technology suppliers affecting operational efficiency.
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What’s Required
Azul’s supplier climate framework should be interpreted as an aviation-specific procurement governance system rather than a manufacturing-style supplier decarbonisation programme. The airline does not appear to publish a detailed supplier science-based target programme equivalent to those used by major industrial groups, but it does maintain supplier conduct rules, supplier approval policies, ESG reporting, environmental governance documents and aviation climate disclosures that create practical obligations for suppliers.
The framework is built around:
Código de Ética e Conduta.
Código de Conduta para Fornecedores.
Supplier Approval Policy.
Environmental Policy.
Biodiversity Policy.
ESG reporting and sustainability reports.
Brazilian aviation climate regulation, including ProBioQAV.
CORSIA exposure for international aviation.
fuel efficiency and operational emissions management.
supplier due diligence and third-party integrity controls.
catering, cargo, airport, MRO and waste supply-chain controls.
Azul’s investor relations governance page lists a Supplier Approval Policy dated 29 May 2023, an Environmental Policy dated 12 August 2024 and a Biodiversity Policy dated 21 August 2024, showing that supplier management and environmental governance are formal policy areas within the company’s public governance structure.
1. Supplier conduct and third-party governance as baseline compliance
Azul’s Código de Ética e Conduta states that the company discloses its values and conduct rules to suppliers, which must act compatibly with those values and with the rules described in the Code of Conduct for Suppliers and Business Partners and in third-party due diligence policies and procedures. It also states that no supplier or business partner may use slave labour or child labour.
This creates the baseline supplier compliance architecture.
Suppliers and business partners are expected to support:
ethical conduct.
legal compliance.
anti-corruption standards.
human rights protections.
prohibition of slave labour.
prohibition of child labour.
third-party due diligence.
compatibility with Azul’s values and conduct rules.
cooperation with supplier approval and compliance procedures.
Although these requirements are not exclusively climate-related, they are important because supplier climate governance depends on the same procurement enforcement infrastructure: onboarding, approval, due diligence, monitoring, escalation and potential exclusion.
2. Supplier approval as procurement enforcement
The existence of a Supplier Approval Policy indicates that Azul uses supplier qualification as a formal control point. In aviation, supplier approval is especially important because suppliers affect safety, operational continuity, regulatory compliance, fuel use, waste management, passenger experience and emissions performance.
Supplier approval may involve:
registration and qualification.
documentation review.
compliance screening.
integrity checks.
environmental and operational capability checks.
category-specific technical assessment.
contract controls.
monitoring and re-evaluation.
corrective action where deficiencies are identified.
For climate and environmental governance, supplier approval becomes the gate through which Azul can impose practical requirements on high-impact suppliers, especially fuel, ground operations, maintenance, catering, airport services and waste management.
3. Climate, emissions and fuel-chain governance
Azul’s most material climate exposure is aviation fuel combustion. Supplier climate governance, therefore, depends heavily on fuel suppliers, future SAF suppliers, fleet suppliers, flight operations systems, MRO providers and airport service providers.
Relevant supplier obligations may include:
fuel quality and delivery documentation.
fuel volume data.
emissions calculation support.
SAF certification, where applicable.
SAF lifecycle carbon data.
chain-of-custody records.
feedstock sustainability evidence.
operational fuel efficiency data.
aircraft and engine performance data.
maintenance records affecting fuel burn.
route and flight planning technology support.
Brazil’s 2024 State Action Plan on CO₂ emissions reduction from civil aviation identifies SAF as a key pathway and discusses both domestic aviation and CORSIA for international flights. Azul’s 2024 sustainability reporting materials also reference Federal Law No. 14.993/2024 and Brazil’s National Sustainable Aviation Fuel Program, ProBioQAV, which requires airline operators to reduce CO₂ emissions by at least 1% starting in 2027.
This is highly relevant for supplier governance. Fuel and SAF suppliers will need to provide compliant, traceable and emissions-reducing fuels that support Azul’s regulatory and voluntary climate obligations.
4. Sustainable Aviation Fuel and ProBioQAV implications
The emergence of ProBioQAV changes supplier expectations for Brazilian airlines. As SAF requirements become operational, Azul’s procurement exposure will increasingly depend on fuel suppliers capable of delivering eligible low-carbon aviation fuel with reliable documentation.
SAF suppliers may need to provide:
proof of SAF eligibility.
lifecycle emissions reduction data.
feedstock origin data.
sustainability certification.
blending records.
fuel quality documentation.
delivery records.
carbon intensity values.
chain-of-custody documentation.
audit-ready records for emissions claims.
evidence compatible with domestic requirements and CORSIA, where applicable.
This converts fuel procurement into a quasi-regulatory system. Fuel suppliers are no longer assessed only on price, availability and reliability. They also become compliance partners in Brazilian aviation decarbonisation.
5. CORSIA and international emissions reporting
Azul’s international operations may expose the airline to CORSIA-related requirements, depending on route coverage and regulatory application. Brazil’s aviation climate planning explicitly discusses CORSIA for international flights.
Suppliers that affect emissions data may need to support:
fuel uplift documentation.
SAF eligibility documentation.
operational emissions data.
aircraft efficiency information.
carbon accounting inputs.
audit evidence for emissions reporting.
verification-ready documentation.
This is where formal aviation climate regulation becomes private supplier governance. Azul must obtain reliable operational and fuel data, and suppliers become part of the reporting infrastructure.
6. Fleet, aircraft, engine and MRO supplier requirements
Azul’s environmental performance is strongly influenced by fleet composition, aircraft efficiency, engine performance and maintenance quality. Aircraft and engine suppliers, lessors and MRO providers affect fuel burn, emissions intensity, noise, reliability and operational efficiency.
Relevant suppliers include:
aircraft manufacturers.
engine manufacturers.
lessors.
component suppliers.
MRO providers.
aircraft parts suppliers.
avionics providers..
flight-planning and operations technology suppliers.
Supplier requirements may include:
aircraft fuel-efficiency data.
engine performance evidence.
maintenance documentation.
parts traceability.
component reliability data.
retrofit and upgrade information.
operational efficiency metrics.
noise and emissions performance data.
For airlines, MRO is climate-relevant because maintenance quality directly affects fuel performance. Poor maintenance, parts delays or reliability failures can increase fuel burn, cancellations, repositioning flights and operational inefficiencies.
7. Catering, onboard products, packaging and waste suppliers
Azul’s supplier framework also covers high-volume service categories such as catering, onboard products, packaging, airport services, cleaning, uniforms, textiles and waste contractors. These areas do not dominate climate impact in the same way as jet fuel, but they influence waste, plastics, food systems, passenger-facing sustainability and airport operations.
Suppliers may need to provide:
waste management records.
food waste reduction plans.
packaging composition data.
recyclable or reusable material options.
sustainable sourcing evidence.
chemical safety documentation.
cleaning product information.
water and wastewater controls.
waste contractor traceability.
documentation supporting environmental claims.
Azul’s environmental and biodiversity policies, listed in its public governance policy library, provide the internal basis for applying environmental expectations to these operational supply chains.
8. Cargo, logistics and airport service controls
Azul’s operations include passenger transport, cargo and airport service dependencies. These suppliers affect fuel use, ground emissions, packaging, waste, logistics efficiency, hazardous goods handling and regulatory compliance.
Relevant supplier groups include:
Azul Cargo Express partners.
airport ground handlers.
ground service equipment providers.
logistics contractors.
warehouse operators.
cold-chain providers.
cargo packaging suppliers.
hazardous goods service providers.
airport waste contractors.
Supplier expectations may include:
transport emissions data.
ground equipment fuel or electricity data.
packaging reduction.
route optimization.
cold-chain energy management.
hazardous goods documentation.
cargo handling compliance.
waste and recycling data.
subcontractor compliance controls.
Cargo and logistics suppliers are important because they extend Azul’s environmental footprint beyond aircraft operations into warehousing, ground transport, packaging and distribution.
9. Data systems and governance architecture
Azul’s supplier framework requires operational data that can support ESG reporting, supplier approval, climate regulation, aviation safety and environmental performance management.
Suppliers may need systems covering:
supplier registration and approval data.
emissions and fuel data.
SAF certification and chain-of-custody records.
waste and recycling data.
packaging material information.
energy and water data.
environmental compliance records.
maintenance and operational performance data.
third-party due diligence documentation.
audit and corrective action records.
anti-corruption and integrity compliance evidence.
The key compliance issue is evidence quality. In aviation, climate and environmental data must be reliable enough to support sustainability reporting, regulatory requirements, procurement decisions and public claims.
10. Supplier segmentation and upstream cascade
Azul’s supplier obligations are likely segmented by risk and operational relevance.
High-impact suppliers include:
jet fuel suppliers.
future SAF suppliers.
aircraft and engine suppliers.
MRO providers.
airport ground service providers.
catering suppliers.
cargo and logistics partners.
waste contractors.
technology vendors supporting flight efficiency.
suppliers subject to third-party due diligence.
Lower-impact suppliers may face baseline conduct and procurement requirements, while high-impact suppliers face stronger expectations for technical documentation, environmental data, fuel-chain evidence and operational performance.
Upstream cascade requirements are most relevant for:
SAF feedstocks.
catering ingredients.
packaging materials.
aircraft parts.
maintenance inputs.
chemicals and cleaning materials.
uniforms and textiles.
cargo subcontractors.
This means Azul’s supplier governance can extend beyond direct suppliers where upstream information is needed to prove compliance, sustainability or operational integrity.
Important Deadlines
Key timelines include:
29 May 2023: Azul Supplier Approval Policy listed in the company’s governance policy library.
12 August 2024: Azul Environmental Policy listed in the company’s governance policy library.
21 August 2024: Azul Biodiversity Policy listed in the company’s governance policy library.
2024: Federal Law No. 14.993/2024 established Brazil’s National Sustainable Aviation Fuel Program, ProBioQAV, referenced in Azul’s sustainability reporting materials.
2027: ProBioQAV requires airline operators to begin reducing CO₂ emissions by at least 1%.
Annual: ESG and sustainability reporting cycles.
Ongoing: supplier approval, supplier conduct and third-party due diligence.
Ongoing: aviation fuel efficiency, SAF readiness and CORSIA-related data governance for international aviation.
Current Status
The framework is active and evolving. Azul has formal governance policies covering supplier approval, environmental policy and biodiversity policy, and its investor relations ESG page shows continued ESG updates through 2026.
The framework is strongest in:
supplier approval and conduct.
third-party due diligence.
aviation fuel and SAF readiness.
environmental policy governance.
biodiversity policy governance.
sustainability reporting.
operational efficiency.
Brazilian aviation climate compliance.
It is less transparent than some global airlines on mandatory supplier-level climate targets or CDP supply-chain engagement. However, the framework remains commercially material because fuel, SAF, MRO, catering, cargo, airport services and operational suppliers directly influence Azul’s emissions, waste, regulatory readiness and sustainability reporting.
Penalties for Non-Compliance
Enforcement is procurement-driven.
Potential consequences include:
failed supplier approval.
failure to pass due diligence.
corrective action requirements.
contract review.
reduced sourcing opportunities.
exclusion from future tenders.
suspension or replacement of the supplier relationship.
reputational exposure.
regulatory risk where supplier data affects aviation compliance.
loss of eligibility for strategic sustainability or SAF-related supply opportunities.
The strongest enforcement mechanism is supplier eligibility. A supplier that cannot meet conduct, approval, environmental or documentation expectations becomes a procurement risk for Azul.
Examples of Known Violations
This analysis does not identify specific public violations by named Azul suppliers. Realistic failure modes include:
failure to comply with supplier conduct requirements.
use of prohibited labour practices by a supplier or business partner.
failure to pass supplier approval.
weak third-party due diligence documentation.
incomplete fuel or emissions data.
unsupported SAF claims.
missing SAF chain-of-custody evidence.
poor waste or catering documentation.
weak maintenance records affecting fuel efficiency.
inaccurate packaging or recycling data.
weak cargo subcontractor controls.
insufficient environmental compliance evidence.
failure to support regulatory reporting under SAF or aviation emissions rules.
These failures can trigger procurement escalation, reputational risk and possible loss of commercial access.
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