21 Code of Conduct Doing it right for our company Avoiding conflicts of interest We each have a responsibility to act with integrity and do what is best for AAR. As part of that commitment, we must avoid conflicts of interest, or situations where we might have to choose between doing what is best for AAR and what is best for us personally or for a member of our immediate family, such as a spouse, child or anyone else who lives with us. How we own it • It is impossible to list every situation where a conflict of interest may arise, but here are a few guidelines to help you avoid the most common ones: • Do not compete with AAR. Do not take for yourself any business opportunity that you learn about through your work with AAR, or serve as a director, consultant or employee for any company that competes with AAR. • Think before accepting outside employment. Any outside employment should not embarrass AAR, require you to use Company confidential information or interfere with your ability to perform your work for AAR. Full-time employees must disclose any outside job that requires a significant time commitment—meaning more than 10 hours a week or 40 hours a month—before accepting the position. • Never directly supervise—or be supervised by—a member of your immediate family. • Exercise caution when making outside investments. You (or your immediate family) should not own more than one percent of the stock of a company that does business (or seeks to do business) with or competes with AAR. If you believe you may be involved in a conflict of interest—or a situation that could appear to be a conflict—disclose it to your manager, a Human Resources representative or an attorney in the Law Department right away. See the Related Person Transaction and Standards of Business Ethics and Conduct policies for more information. Keeping accurate books and records AAR uses its business records—such as expense reports, time records and invoices—to make important business decisions and create its financial disclosures. In order to ensure that these business decisions are sound, AAR’s records must be complete, accurate and truthful. How we own it • Be certain that any records you create are correct and complete. • Never provide false or misleading information in a record. • If you work on AAR’s financial disclosures, ensure they are full, fair, accurate and understandable. Follow all generally accepted accounting principles, as well as AAR’s policies, controls and procedures. • Retain records only as long as needed, destroying or deleting them appropriately when that period has ended. See the Records Management and Retention policy for more information. Mark works in AAR’s Marketing Department. In the evenings, he works as a server at a local restaurant. Sometimes Mark has to work the late shift, and he does not get home until 1 AM. He is usually tired at work the next day, and has even caught himself almost falling asleep a few times. Is he Doing It Right? No, he is not. This outside job is taking up a significant amount of time and interfering with Mark’s ability to effectively perform his work for AAR. He should speak to his manager about the situation.
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