Ethics hotline Global anti-corruption policy We encourage good-faith concerns to be reported to the employee’s AAR has zero tolerance for any form of bribery or corruption. It is our Compliance Champion Network manager, Law Department, Human Resources, or through the policy to comply with all applicable laws, including the U.S. Foreign Our Compliance Champion Network is a group of AAR AAR ethics hotline. The hotline is operated by an independent Corrupt Practices Act (FCPA), the UK Bribery Act, and any local anti- employees embedded in our facilities and business units third party, EthicsPoint, and is available 24 hours a day, 7 days a corruption laws. We do not offer, give or accept, directly or indirectly, around the globe to serve as an extension of AAR’s Global week via telephone calls and web reports. Anyone may contact any bribes, kickbacks or other corrupt payments, regardless of Compliance Program. Key responsibilities include: EthicsPoint with confidential complaints, information, suggestions whether we are working with commercial entities or government or recommendations. EthicsPoint permits individuals to identify officials, including employees at state-owned or -controlled airlines. • Promote AAR’s Compliance Program and AAR’s themselves or remain anonymous at their election; however, Doing It Right® values to their colleagues in their business individuals are encouraged to provide contact information to more unit and region. easily investigate the report. We conduct separate anti-corruption training for • Act as a local resource to allow employees to voice new hires and for employees annually. We also concerns and ask questions about compliance issues. The Audit Committee of the Board receives reports concerning our • Triage issues to the appropriate subject matter experts ethics hotline activity and any investigations of non-compliance with require training of certain third parties. our Code of Conduct by any AAR officers. within the organization. • Document and report issues raised for tracking and www.aar.ethicspoint.com reporting as appropriate to management and Board. +1-855-822-9536 Compliance Champions are selected by the CEO and company leadership based on a number of qualities: • High performers • Friendly and approachable • Trustworthy and honest • Respected by fellow employees and leadership • Expert communicators, including a strong ability to listen and respond • Solid judgment • Ability to issue-spot 37

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