Retaliation will not be tolerated. The Business Ethics & Compliance Office. Our commitment to each other and to safety. We provide a respectful workplace.
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657 KB – 29 Pages
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Building the greatest airline in the world requires a strong commitment to our customers, shareholders, business partners, and, of course, each other. That commitment is founded on a value system we all share, one based on integrity, honesty, and the absolute dedication that every decision we make is a responsible and ethical one. We know that you embrace these values and continue to make smart, sound decisions every day. To help guide our actions, we have updated our Standards of Business Conduct. Some of the subjects covered are familiar, but you will also ˜nd guidance on new areas and changes in others. Consider these Standards part of our moral compass. They set clear expectations for each of us and tell the world how we conduct business. Please read the new Standards carefully and ask questions if there is something you don™t understand. If you™re ever unsure how to handle an issue, reach out to your manager, People business partner, or our Chief Ethics & Compliance O˚cer, Doug Cotton, for guidance. You can also ask questions or report potential violations con˜dentially at 877-422-3844 (toll free) or by visiting aa.ethicspoint.com . Our Standards of Business Conduct require us to comply with the law. But they also ask for more: that we all work together to ensure American Airlines is a company that we and all of our stakeholders can count on to do the right thing. Thank you for your commitment. Dear colleagues, Doug Parker Doug Parker Chairman and CEOA message from Doug
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Our Standards Why we have the Standards What the Standards mean for you Retaliation will not be tolerated The Business Ethics & Compliance O˚ce Our commitment to each other and to safety We provide a respectful workplace We comply with our training obligations We protect the health and safety of our colleagues and customers Our commitment to our company We don™t reveal or trade on inside information We follow our media policy We are responsible and respectful on social media We protect our con˜dential information We maintain accurate books and records We are careful with gifts and hospitality We have strict gift rules for government o˚cials We avoid outside con˛icts Our commitment to fair competition We compete fairly We seek business openly and honestly We don™t pay bribes to government o˚cials Our commitment to our business partners and others We respect intellectual property We respect the con˜dential information of others We avoid con˛icts, and apparent con˛icts, with business partners We deal fairly with the government We follow political contribution laws We follow the lobbying laws Our commitment to our communities We take our privacy obligations seriously We respect human rights We safeguard the environment Other resources to help you Index 1112344557788891011131515171819 191920202021222223232526Table of Contents
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Our Standards Why we have the Standards Our Standards provide you with some information and tools you need to follow the law, seek advice when needed, and report possible misconduct. The Standards provide guidance about key business issues and o˝er real-life answers for situations you may face. While our Standards provide some detailed guidance, they cannot address every situation you might face. We rely on you to exhibit the values we share when conducting our business, always act with honesty and integrity, exercise good judgment in making decisions, and seek help when you have questions or concerns about the right course of action. Remember, the best resource about what™s right or wrong is your own conscience. The Standards apply to all team members The Standards apply to all team members and o˚cers of American Airlines Group Inc. and its wholly owned subsidiaries, including American Airlines, Envoy Air, Piedmont Airlines, and PSA Airlines. As an employee, you agree to uphold this commitment. The Standards also apply to our agents, consultants, contractors, providers, and suppliers when they are representing or acting for us. What our Standards mean for you You have a responsibility to yourself, your colleagues, our customers, and our company to conduct business legally and ethically in accordance with our values and our Standards. In addition, we each have an obligation to ensure that our company is following the law and making ethical decisions. So be alert to activities going on around you. And if you learn of or suspect illegal or unethical conduct, or if you ˜nd yourself in a situation that just doesn™t feel right, speak up. Why we have the Standards The Standards apply to all team members What the Standards mean for you Retaliation will not be tolerated Our Standards provide guidance Why do we need the Standards of Business Conduct? Doesn™t everyone just need to do the right thing? The Standards provide guidance and rules to conduct our internal and external activities. It is important to know that some rules are absolute. Illegal acts can cost us millions of dollars in ˜nes, and penalties for companies and individuals convicted of crimes can be severe. To protect our reputation and our future, we all need to understand the rules.1
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Our Standards Waivers are extremely limited Waivers from complying with the requirements in these Standards are granted only in extraordinary circumstances, and only the Board of Directors can grant waivers for executive o˚cers or amend the Standards. Contact the Business Ethics & Compliance O˚ce if you have a question about a waiver. Violations of the Standards An employee who is believed to have violated the Standards will be given an opportunity to present his or her version of the events before corrective action is taken. The ˜nal determination of disciplinary action, which may include the termination of employment, will be based upon the facts and circumstances of each situation.Team members who violate the law or the Standards may also expose themselves to substantial civil damages, criminal ˜nes, and prison terms. We may also face substantial ˜nes and penalties and may incur damage to our reputation and standing in the community. If your conduct as a representative of our company does not comply with the law or with the Standards, there can be serious consequences for both you and American. Retaliation will not be tolerated Anyone who, in good faith, seeks advice, raises a concern, asks a question, reports actual or suspected misconduct, or participates in an investigation is following the StandardsŠand is doing the right thing. We take claims of retaliation seriously. If you or someone you know is the victim of retaliation, report it immediately. We investigate all allegations of retaliation. Team members who have retaliated against someone who reported or raised a good faith concern about misconduct will be subject to serious disciplinary action, up to and including termination. International operationsYou must comply with all relevant local laws. If American™s policies are stricter than local laws, comply with our policies. The EthicsPoint Helpline 877-422-3844 aa.ethicspoint.com Calls to the helpline are answered by trained intake specialists at EthicsPoint, an independent third party. You may ask questions or make reports online. Reports to the helpline can be anonymous. The company reviews and investigates (if necessary) all reports. We strive to maintain con˜dentiality to the extent possible. If you choose to remain anonymous, you will be assigned a PIN number so that you can check back to provide more information and so that we can follow up with you if we need more information. To learn more, visit aa.ethicspoint.com .2
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Our Standards Ask questions and voice your concerns Promptly bring any questions or concerns about potential violations of our Standards or other issues to your supervisor or manager, the Business Ethics & Compliance O˚ce , the appropriate resource listed on page 25 , or the EthicsPoint helpline .It may seem easier to keep silent or look the other way, but taking no action can result in serious consequences. Remember, we cannot honor our company™s bedrock commitment to integrity if we ignore concerns about suspected illegal or unethical actions. The Business Ethics & Compliance O˚ce Doug Cotton, Managing Director & Associate General Counsel, is also our Chief Ethics & Compliance O˚cer and is responsible for our Business Ethics and Compliance Program. Doug oversees the team members who work in the Business Ethics & Compliance O˚ce and coordinates with the other attorneys in the Legal Department who support the Ethics O˚ce. Contact the Ethics O˚ce or the EthicsPoint helpline if you have questions about the program or need educational materials or training.3
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Our commitment to each other and to safety We comply with our training obligations For the safety of our colleagues and our customers, make sure you know and comply with the training requirements for your job. We also must maintain accurate and complete training records. Any failure to train, or any discrepancy in our training records, may violate the law and result in severe penalties for the individual who committed the violation as well as for American Airlines. Key points to remember You™re responsible for completing your required training within the speci˜ed time. Make sure everyone on your team receives the training needed to do his or her job properly. Falsifying training records will result in disciplinary action and may be a criminal violation.We protect the health and safety of our colleagues and customers We strive to be a leader in safety and rely on your sound judgment and experience to run a safe operation. Success requires not only attention to detail, but also compliance with our policies and the consistent execution of safe work practices on the job. You can help contribute to a safe workplace. Perform your job with the highest regard for safetyŠfor both customers and colleaguesŠ and report any activity that might compromise safety or violate applicable laws, regulations, or our policies. Managers must address concerns If you are a manager and a colleague approaches you about a health or safety concern or a situation that might pose an imminent danger, you must address the problem immediately. Listen carefully, ask questions where appropriate, and then, if necessary, investigate and visit the location. Use resources such as our safety policies and procedures on Jetnet and experts in the Safety, Regulatory Compliance and Environmental departments to help you assess the issue and correct the problem as soon as reasonably possible. When applicable, be sure to provide constructive feedback to your colleague who brought the issue forward. 5
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Our commitment to each other and to safety Key points to remember A company that violates federal safety laws can receive sti˝ ˜nes. Team members who willfully violate safety laws can be subject to criminal sanctions, including sti˝ ˜nes and imprisonment. Safety is everyone™s responsibility. Each o˚cer is accountable for the safety performance of his or her department. Each department is responsible for ensuring that policies, procedures, and training are followed to prevent accidents and injuries. 6Health and safety A colleague often works more than four feet o˚ the ground without wearing required fall protection equipment. What should I do? Everyone is responsible for safety. You should encourage him to use the proper safety equipment. If he does not, tell a manager or supervisor. Manager responsibilities A colleague who reports to me told me about a potential safety hazard on the ramp. It doesn™t appear to be serious. Do I need to take any action? Yes. Every safety issue should be immediately addressed. You have a responsibility to listen to your colleague™s concern and work to address it locally with the assistance of Corporate Safety as needed.
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Our commitment to our companyWe don™t reveal or trade on inside information You may not trade (or tip others to trade) securities of American or other companies based on material nonpublicŠor insideŠinformation. Material nonpublic information is any information that a reasonable investor would consider important in making a decision to evaluate, purchase, hold, or sell securities and which the company has not publicly disclosed. Examples of material information include ˜nancial results or forecasts, adverse changes in liquidity, major new products or services, signi˜cant capital expenditures, major contract awards or cancellations, merger or acquisition proposals, signi˜cant developments in litigation, and organizational changes, such as layo˝s. If you have material nonpublic information, you may not beat the market by trading before, simultaneously with, or shortly after the o˚cial release of the information. Information should not be considered publicly disclosed until a reasonable time after it has been made public (for example, by a press release). Be aware that insider trading is illegal and can result in disciplinary action and civil and criminal penalties. Key points to remember Team members who violate insider trading laws are subject to criminal sanctions, including heavy ˜nes and imprisonment. Read and follow our Insider Trading Policy . Know what kind of information is material nonpublic information, and do your part to protect it. If you are unsure whether information is material, or has been released to the public, don™t trade on it until you have consulted with the Ethics O˚ce. We don™t reveal or trade on inside information We follow our media policy We protect con˜dential information We maintain accurate books and records We are careful with gifts and hospitality We avoid con˛icts of interest Inside information My neighbor, a stockbroker, keeps asking me if we are going to speed up our aircraft deliveries. I think she might be trying to get con˜dential information. I really want to just say, fiYeah, we are working on that now, but I can™t tell you anything more than that.fl Is it okay to say that? No. Telling people outside work our con˜dential information is never okay, even if it isn™t the entire story or is done casually. Disclosing information too soon At the end of every quarter, a friend who works at a hedge fund asks me what I think our quarterly earnings are going to be. Can I tell my friend before the press release? No. You can™t tell him, or other colleagues who don™t need to know this information to do their jobs. This is con˜dential information, and the SEC takes leaks of ˜nancial information very seriously. Even if no one trades on leaked con˜dential information, disclosure still violates our policy and may violate the law. 7
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Our commitment to our companyWe follow our media policy To protect our reputation and our company, and to make sure that any information communicated is accurate, only American™s Corporate Communications team (and those preapproved by that department) is authorized to speak directly to the media about our company. If the media contacts you, direct them to Corporate Communications. Key points to remember Don™t speak directly to the media about our company unless you have been preapproved to do so by Corporate Communications. If the media contacts you, direct them to Corporate Communications. We are responsible and respectful on social media Team members are responsible for the content of their postings and publications on social media. What you post or publish on networking sites or other websites must not be attributed to or appear to be endorsed by or to originate from American Airlines. Only o˚cially designated American Airlines spokespersons are authorized to speak on behalf of the company. If you choose to list your work a˚liation on a social network, please remember that your communications may re˛ect on our company and your colleagues. We protect our con˜dential information Con˜dential information includes all information that the company has not publicly disclosed. This includes things like product information; nonpublic ˜nancial information; business strategies; contract terms; employment and personnel information; information about our relationships with customers, suppliers, or government agencies; and any other information that gives us a competitive advantage. We safeguard our con˜dential information because it™s one of our most valuable assets. We never use con˜dential information for our personal bene˜t, and we never disclose it to others (including family members and friends) or anyone else at work who doesn™t have a need to know it. Remember that the responsibility for protecting con˜dential information continues even after your employment ends. Our con˜dential information A colleague was working on a plan for training crew members before she left. Can she tell her new employer about our new plan? No. When your colleague was hired, she agreed that she would not use con˜dential information for her own bene˜t or disclose it to others. That obligation is a permanent one that continues even after her employment with us ended.8
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