17 Code of Conduct Doing it right for our government customers Avoiding improper payments and competing fairly When we work with government officials, we must be sure to know and follow the rules and regulations they are subject to regarding gifts and entertainment. We must also be aware of lobbying and political contribution restrictions and follow all related rules closely. How we own it • In general, do not give or offer any gift—regardless of value—to a government official. • Never offer anything to a government official in exchange for any official action, as this would be considered a bribe. • Never improperly influence or attempt to improperly influence a government official regarding a government contract. • Do not use government funds to pay lobbyists or AAR directors, officers, employees, attorneys or anyone else acting on our behalf to engage in lobbying activities. Avoiding organizational conflicts of interest Due to AAR’s long history of working with the government and other companies in our industry, the Company may sometimes face an organizational conflict of interest because of AAR’s past work experience or because of its relationships with other persons, such as consultants, teaming partners or subcontractors. In an organizational conflict of interest, the Company is unable (or could potentially be unable) to act impartially, or it may receive an unfair advantage regarding a new business opportunity with the government. We must avoid even the appearance of an organizational conflict of interest. If you learn of a potential organizational conflict of interest, report it to your manager and an attorney in the Law Department immediately. Hiring former government employees We work closely with government officials as we bid and work on government contracts. At all times, we want to avoid the appearance that we could be trying to influence the procurement process unfairly. Accordingly, we must be careful to comply with applicable laws when hiring former government employees or even discussing employment opportunities with them. How we own it • Never discuss employment or consulting opportunities with a government official who is involved in certain competitive procurements on which AAR is bidding. • Speak to a Human Resources representative and an attorney in the Law Department before discussing employment opportunities with anyone who works—or used to work—for the government. What Is a Government Official? A government official is any of the following: • Any employee of any branch of the government • Police officers • Members of the military • Employees of government-owned or -controlled enterprises • Private citizens acting in an official government capacity • Political party officials and political candidates • Employees of public international organizations like the UN and the Red Cross This list is not exhaustive. Because this term is so broad, it is not always easy to know who is or is not a government official. Speak to an attorney in the Law Department if you have questions.