National Air Cargo - Ethics

OUR MISSION: To provide our customers with a competitive advantage through on time delivery.

National Air Cargo is committed to conducting operations with the highest standards of business conduct and ethics. A strong and proactive culture of ethics is critical to the Company's future success and continuing growth. For ethics and integrity to be the foundation of our culture, all of us, every employee, must be committed. Performing with integrity is every employee's responsibility and there is no room for compromise. Our values apply to every employee of National Air Cargo.

- Christopher J. Alf, CEO & President

OUR VALUES

• Uncompromising Integrity
• Passion for Excellence
• Full Spectrum Customer Focus
• Continuous Improvement
• Responsibility

INTRODUCTION

The National Air Cargo Code of Business Ethics identifies for us as a Company, and for all those with whom we do business, the values and principles that guide our business relationships. We are committed to the principles of honesty, integrity, and responsibility in everything we do. Our Code of Business Ethics applies to all officers, employees, and representatives of National Air Cargo. Ethical decision-making depends on understanding and commitment to our company values and principles combined with good personal judgment.

COMMITMENT TO QUALITY

At our Company, we strive to do the job right, on time and always to the contractual expectations of the customer. While striving to get it right, we must also report any discrepancy, deviation, mistake or failure, with regard for the highest ethical standards and personal integrity. Never falsify documents or conceal problems. Always receive proper approvals before deviating from any requirement.

RESPECT FOR PEOPLE AND NONDISCRIMINATION

We are committed to providing a work environment that is free from discrimination or harassment of any type. We will not tolerate discrimination based on race, religion, gender, age, marital status, national origin, sexual orientation, citizenship status, or disability. The use of discriminatory slurs; unwelcome, unsolicited sexual advances or harassment; or any other remarks, jokes or conduct that creates or fosters an offensive or hostile work environment. We prohibit discrimination concerning recruitment, hiring, compensation, benefits, training, termination, promotions, or any other condition of employment or career development. Employees at all levels of the organization must act with respect and civility toward coworkers, customers and others.

PROTECTION AND PROPER USE OF COMPANY ASSETS

Effective use of company resources is critical to our bottom line, and the resources should be used principally for business purposes that advance our company's strategic objectives. Occasionally, however, limited personal use is permitted when it does not compromise company interests. National Air Cargo employees must use these resources wisely, demonstrate efficiency, and guard against waste. Time spent on personal affairs should be limited to a reasonable duration and frequency – always incidental to the workday and never charged to the company or customer. Personal use must not interfere with or adversely affect job performance or that of any other person or organizational requirements. Company assets must never be used in a disruptive or offensive manner to others (e.g., involving sexually explicit materials or materials that are discriminatory, hateful, or threatening).

Employees should be mindful of the fact that National Air Cargo retains the right to access, review, monitor and disclose any information transmitted, received or stored using Company electronic equipment, with or without an employee's or third party's knowledge, consent or approval and in accordance with applicable law, and employees should have no expectation of privacy in connection with this equipment.

FINANCIAL RECORDS

National Air Cargo employees have the responsibility to be careful, accurate, and complete when making or reporting financial entries or transactions. We must disclose problems and discrepancies promptly, never falsify or alter financial records and shall not sign documents without the proper authority. National Air Cargo employees must never make or approve payments on behalf of the Company if they will be used or might be used for something other than the stated approved business purpose.

TIMEKEEPING

National Air Cargo employees must accurately and honestly record time spent each day on each job on which they work. Falsifying time records is fraudulent, and may be looked upon as a criminal offense. Employees are responsible for the accuracy of their individual time records. Signing of one's timecard certifies that it is true and accurate.

ENVIRONMENTAL AND WORKPLACE SAFETY

We must comply with all applicable environmental laws. National Air Cargo must conduct its business in an environmentally responsible manner that minimizes any environmental impact. All employees must take appropriate actions in using, generating, handling and disposing hazardous materials and report all concerns to their supervisor or other appropriate person. Honor and keep our commitment to maintain a drug-free work environment.

CONFLICTS OF INTEREST

A conflict of interest occurs when an individual's personal interest may interfere in any way with the performance of his or her duties or the best interests of the Company. Employees must be free from influences that conflict with the best interests of the Company or might deprive the Company of their undivided loyalty in business dealings. Even the appearance of a conflict of interest where none actually exists can be damaging and should be avoided.

PROPRIETARY DATA

One of National Air Cargo's most important assets is its information. Employees who have received or have access to proprietary information should take care to keep this company information private. Because we interact with other companies and organizations, we may be aware of competition-sensitive data from customers before that information has been made available to the public. You must treat this information in the same manner as you are required to treat National Air Cargo proprietary information. There may even be times when you must treat as private the fact that we have an interest in, or are involved with, another company. We cannot accept unauthorized competitive proprietary data.

National Air Cargo employees should also be careful not to inadvertently disclose proprietary information. Materials that contain proprietary information, such as memos, notebooks, computer disks and laptop computers, should be stored securely.

COMPETITIVE SENSITIVE DATA

National Air Cargo employees, consultants, or representatives may not solicit, obtain, or utilize source selection information relating to a Government procurement. In addition to materials so marked by the Government, source selection information includes bid prices submitted in response to a solicitation; source selection plans; technical evaluation plans; technical evaluation of competing proposals; cost or price evaluations of competing proposals; competitive range determinations; ranking of competitors; reports and evaluations of source selection boards; and Government agency planning, programming, and budgeting system information.

Similarly, National Air Cargo employees, consultants, or representatives may not solicit, receive, or utilize any other company's proprietary material other than as authorized by that company.

LEGAL COMPLIANCE

National Air Cargo is committed to obeying all laws and regulations applicable to its business. Violation of domestic or foreign laws, rules and regulations may subject an individual, as well as our Company, to civil and/or criminal penalties. You should be aware that conduct and records, including emails, are subject to internal and external audits, and to discovery by third parties in the event of a Government investigation or civil litigation.

INTERNATIONAL

We must comply with the applicable laws in all countries in which we travel, operate and otherwise do business, including laws prohibiting bribery, corruption or the conduct of business with specified individuals, companies or countries. The fact that in some countries certain laws are not enforced or violation of those laws are not subject to public criticism will not be accepted as a reason for noncompliance. In addition, we expect employees to comply with U.S. laws, rules and regulations governing the conduct of business by its citizens and its corporations doing business outside the U.S.

These U.S. laws, rules and regulations, which extend to all our activities outside the U.S., include the Foreign Corrupt Practices Act, International Traffic in Arms Regulations (ITAR) and other Export Control Laws. Attention to potential violations related to technical data on computers and laptops or in presentations and technical support documentation is vital.

DEALING WITH U.S. GOVERNMENT PERSONNEL

Employment Discussions or Hiring

Any contacts relating to employment must be coordinated with a Human Resources representative. Employees may not have direct employment conversations with Government personnel without specific permission. Once a former government employee is hired by the Company, that employee may be subject to certain restrictions.

Meals and Business Courtesies

Business entertainment and gifts are meant to create good will and sound working relationships and not to gain improper advantage with customers or facilitate approvals from Government officials. The U.S. Government has very detailed rules related to the value of permissible meals, gifts, or entertainment for government employees. A meal can never exceed $20 per meal or a total of $50 per year, per government employee.

Unless express permission is received, entertainment and gifts cannot be offered, provided or accepted by any employee unless consistent with customary business practices and not of greater than nominal or token value. Our customers, suppliers and the public at large should know that the judgment of our employees is not for sale. Employees with procurement responsibility can never accept anything of value from a vendor or supplier.

OUR COMMITMENT

National Air Cargo employees aware of a suspected or actual violation of Code standards by others, have a responsibility to report it. Whether they choose to speak to a supervisor or others, they can do so without fear of any form of retaliation. We will take prompt disciplinary action against any employee who retaliates against another employee, up to and including termination of employment.

National Air Cargo employees are encouraged to seek advice or express concerns about ethical misconduct to whomever they are most comfortable. They are advised to seek guidance when they are uncertain about a situation and raise issues that may be a violation of National Air Cargo policies, regulations, or laws.

The following resources are available:

• Talk to a supervisor or other member of management
• Talk to your ethics point of contact or our company ethics officer
• Contact the National Air Cargo EthicsPoint, utilizing our toll free dialing instructions. (EthicsPoint - International Dialing Instructions)
  • A confidential resource for employees to raise concerns or ask questions. Employees may call this toll-free number to raise concerns, report misconduct, or ask questions.
  • Anonymous toll-free telephone number
  • Use the anonymous online portal at www.ethicspoint.com or via National Air Cargo's company Intranet
  • Send an email to ethics@nationalaircargo.com
• Contact U.S. Department of Defense Hotline For Reporting Fraud, Waste, and Abuse: 800-424-9098 or 877-363-3348 (from OCONUS)