COVID-19: A MESSAGE FROM ATLAS AIR WORLDWIDE

 

Governance

Compliance

Compliance Header
Compliance Header

Governance

Compliance

Atlas Air Worldwide’s business is built on safety, security and compliance. We regard legal and regulatory compliance and cooperation with regulatory authorities as a core responsibility. This provides opportunities for us to lead in the development and application of best practices and compliance with emerging rules and policies even before they become mandatory.

Leading with Best Practices for Compliance

Given our position in the global air cargo industry, Atlas is subject to a complex web of U.S. and international legal frameworks, regulatory requirements and industry standards. First and foremost, we comply with all laws and regulations applicable to us. We believe our compliance programs and willingness to partner with regulatory bodies help us to raise the state of the art for compliance in our industry.

We seek to go beyond straightforward compliance to develop proactive best-practice relationships with key regulatory bodies, including U.S. agencies such as the Federal Aviation Administration (FAA), Department of Defense and Department of Homeland Security, local and regional authorities, and international bodies such as the International Civil Aviation Organization (ICAO).

Here are a few examples of how we are leading with best practices for compliance:

  • Aviation safety: Atlas maintains an industry best-practice safety program meeting all applicable FAA, ICAO and International Air Transport Association (IATA) standards. Atlas was among the aviation industry leaders participating in FAA’s Safety Management System (SMS) before it was required. Read more in the Safety & Security section of this report.
  • Anti-corruption: Our anti-corruption policy exists to ensure compliance with the U.S. Foreign Corrupt Practices Act of 1977, as amended, the UK Bribery Act of 2010 and other similar statutes around the globe. We supplement this policy with mandatory training provided to our employees, vendor due diligence and related policies and procedures.
  • Greenhouse gas emissions reductions and reporting: Atlas has been reporting emissions under the European Union Emissions Trading Scheme since 2010 and is setting the groundwork to participate in CORSIA, the global carbon emissions program governing international flying starting on January 1, 2021.
  • Office of Foreign Assets Control: OFAC, which is part of the U.S. Department of the Treasury, administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign countries and regimes. In recent years, we have bolstered our efforts to protect against even inadvertent violation of OFAC requirements and guidelines.
  • U.S. government contracts: As a U.S. government contractor with a significant role in international trade, we partner with various federal agencies on compliance and best practices related to areas such as preventing human trafficking and endangered species trafficking.
Compliance Hotline is Available to All

Atlas maintains a toll-free Compliance Hotline to accept reports and complaints related to potential violations of Company policy. The Compliance Hotline may also be used to report concerns or complaints about the Company’s accounting, internal controls or auditing matters, as well as instances of suspected fraudulent conduct. The hotline can be reached at 1-877-540-5060 or online at aaww.alertline.com and is available to employees and other callers on an anonymous basis. To ensure anonymity, the hotline is serviced exclusively by an independent, outside vendor. The hotline is available seven days a week, 24 hours a day and can be contacted from anywhere in the world.

Corporate Compliance Policy

Our Corporate Compliance Policy governs our compliance programs and our commitment to prevent and detect any violations of the law or company policy. This policy is applicable to directors, officers, other employees and agents of the Company and its subsidiaries. It is designed to promote:

  • Compliance with all applicable laws, rules and regulations in the many jurisdictions in which we operate;
  • Honest and ethical conduct, including appropriately addressing actual or apparent conflicts of interest in professional and personal relationships;
  • Prompt internal reporting to an appropriate supervisor and/or the Legal Department of potential and actual violations of the Company’s compliance policies; and
  • Accountability for adherence to the Company’s compliance policies.

In addition to the overall policy, Atlas has specific policies in place to address our myriad compliance responsibilities. We update these policies as regulations change and we review all policies regularly to ensure that we are keeping pace with the evolution of best practices. We provide new-hire and recurrent compliance training to our employees that supports their ability to act responsibly and in full compliance with all legal and company requirements.