For Atlas Air Worldwide, being a trusted partner means upholding an unwavering commitment to the highest level of legal and ethical conduct, honesty and integrity. We are committed to accountability and transparency in all our operations throughout the world.
Under our Employee Handbook and Code of Conduct, we require all employees to act responsibly in full compliance with all applicable laws and standards and to maintain the highest level of ethical conduct in their dealings with customers, suppliers and other stakeholders. The Code of Conduct includes more than 25 employee “rules of conduct” related to use of company resources and data, confidentiality, anti-harassment and anti-discrimination policies, regulatory compliance, workplace safety, avoiding conflicts of interest, and other topics to ensure a high degree of ethical conduct across our organization. Employees of any operating entity of Atlas Air Worldwide receive a copy and acknowledge receipt of the Code of Conduct when they are hired.
We periodically review and conduct a comprehensive update of our Employee Handbook and Code of Conduct – most recently in 2018 – to maintain compliance with applicable laws and to ensure we are conforming to the most current best practices. Through our last review process, we called upon legal counsel in the U.S. and in the countries outside the U.S. where we have the largest populations to ensure we are mindful of current issues and any new legal concerns. In January 2019, we distributed the revised and updated Employee Handbook and Code of Conduct, which incorporates the additional global input and enhances policies and procedures in fast-changing areas such as social media, intellectual property, cybersecurity and leave policies.
We also maintain our Code of Ethics Applicable to the Chief Executive Officer, Senior Financial Officers and Members of the Board of Directors. This code addresses officers’ and directors’ responsibilities for honest and ethical conduct, avoidance of conflicts of interest, and compliance with all governmental laws, rules and regulations. Ultimate responsibility for overseeing this Code and related party transactions rests with our Board’s Audit Committee.
We are committed to maintaining a strong control environment and we have made effective controls an integral part of our routine business practices. Our commitment to ethics and integrity and related checks and balances allow us to address potential issues before they could become larger problems.
Our Compliance Hotline allows anyone, both inside and outside the company, to anonymously report conduct that they are concerned about. The Compliance Hotline can be reached at 1-877-540-5060 or online at aaww.alertline.com, and is available seven days a week, 24 hours a day. To ensure anonymity, the Compliance Hotline is serviced exclusively by an independent, outside vendor. All matters are promptly and thoroughly investigated, and internal legal resources are mobilized to address or escalate the issue as needed and appropriate.