13 Code of Conduct Doing it right for our customers Saying no to bribery and corruption When we work on AAR’s behalf, we must always demonstrate AAR’s commitment to doing business honestly. In all our work, we must comply with all applicable laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and any local anti-corruption laws. AAR has zero tolerance for any form of bribery or corruption. That means we never offer, give or accept, directly or indirectly, any bribes, kickbacks or other corrupt payments, regardless of whether we are working with commercial entities or government officials, including employees at state-owned or -controlled airlines. How we own it • Never offer or accept any sort of bribe. This can be anything of value given with the intention of gaining an improper advantage, such as securing a contract or receiving a license or a permit. Value can include cash payments, promises or offers of employment, use of AAR facilities, lavish gifts or entertainment, payments for unreasonable travel expenses or political or charitable contributions. • Do not offer or accept kickbacks, which are payments paid (or due to be paid) after the completion of a business deal. • Take special care when working with government officials outside the U.S. Under the FCPA, it is illegal to offer government officials anything of value that could corruptly influence their decision making. • Do not make facilitating payments, which are small cash payments to perform or expedite a routine non-discretionary government action, such as processing visas or obtaining utility services. • Always keep in mind that these rules also apply to third-party business partners, including agents and representatives, who act on AAR’s behalf. • Report any questions or concerns regarding bribery or corruption to an attorney in the Law Department. See the Global Anti-Corruption policy for more information. Bianca is setting up a new AAR office, and she needs to have the utility service turned on. She contacts the clerk at the local utility company, and he tells her that it will take at least three weeks to get utility service—unless she can make a small additional cash payment to him to expedite the process. She wants to get the office open as soon as possible, so she decides to make the payment out of her own pocket. Is Bianca Doing It Right? No, she is not. Regardless of whether Bianca uses AAR funds or her own money, this is still a facilitating payment, which is not allowed at AAR. We want to do business the right way, so we never offer or make any corrupt payment, no matter how small. Susan is meeting with a prospective state-owned commercial airline customer in Asia. During the meeting, the customer suggests that AAR hire his daughter as an intern prior to submitting its bid. Susan agrees to do so. Is Susan Doing It Right? No, she is not. The FCPA prohibits promising something of value to a foreign government official to gain an improper advantage. Employees of state-owned commercial airlines are considered government officials, and hiring the customer’s daughter could be perceived as an improper attempt to give something of value to the customer in order to secure the contract. Susan should refuse the request and immediately report this situation to the Law Department.