Table of contents 3 Code of Conduct Table of contents 2 Letter from John M. Holmes 4 We own it: an introduction to our C ode 4 What is our Code? 4 Who must f ollow our Code? 5 Why do w e f ollow the Code? 6 Asking questions and reporting concerns 6 Speaking up 6 Upholding our commitment to non-retaliation 7 Doing it right in the workplace 7 Work as one. Be inclusive. 7 Anti-harassment 8 Quality first. Safety always. 9 Fair compensation and labor laws 9 Protecting employee personal information 10 Doing it right for our customers 10 Putting quality first 10 Competing fairly 12 Exchanging gifts and entertainment 13 Saying no to bribery and corruption 14 Following international trade laws 15 Selecting third-party business partners 15 Steering clear of money laundering 16 Doing it right for our government customers 16 Doing procurement right 16 Complying with the contract 17 Avoiding improper payments and competing fairly 18 Partnering with the right contractors 18 Complying and cooperating with government audits and investigations 19 Doing it right for our company 19 Protecting AAR’s assets 19 Safeguarding confidential information 21 Avoiding conflicts of interest 21 Keeping accurate books and records 22 Avoiding insider trading 23 Speaking about our company 24 Doing it right for our communities 24 Being good corporate citizens 25 Waivers