Culture of ethics Human rights (fair compensation and labor laws) Anti-retaliation We believe everyone who works for AAR or a third-party business To maintain an environment where everyone feels comfortable and compliance partner should be treated fairly and respectfully. We follow all laws raising concerns or posing questions, AAR does not and will not related to working hours, working conditions and compensation. tolerate retaliation for making a report in good faith. When questions Our compliance culture is reflective of our purpose and our values. or issues arise that are not covered by the Code, anyone can turn ® AAR has a zero-tolerance policy regarding trafficking in persons and to the resources listed in the “Speaking UP” section of the Code At the heart of Doing It Right is a commitment to conducting forced labor. Employees are expected to monitor for indications business ethically. to report a concern or pose a question. There is no retaliation for of forced labor or human trafficking, whether by AAR or any third- speaking up. Our Code of Conduct and related policies party business partner we work with, and report any suspicious activity immediately. Conflicts of interest Our Code of Conduct comprises more than just policies and As part of our commitment to act with integrity, we avoid conflicts procedures. The purpose of the Code of Conduct is to promote the of interest or situations where we might have to choose between highest ethical standards in our business practices and procedures. All employees are trained annually on the doing what is best for AAR and what is best for us personally or for AAR takes violations of our Code of Conduct and the law very principles of Supporting Human Rights: a member of our immediate family. Based on AAR’s long history of seriously. Unethical or illegal actions detract from our workplace’s Modern Slavery Act. working with the government and other companies in our industry, ethical culture. Anyone who is found to have violated our Code of we take all reasonable measures to avoid organizational conflicts Conduct or the law will be subject to discipline, up to and including of interest. termination of employment. In FY 2019, AAR created a Chief Compliance Officer position to Anti-discrimination oversee and implement enhancements to our compliance program. We view fairness as paramount when it comes to hiring, firing, These enhancements focused on anti-bribery and anti-corruption promoting or including someone in professional development policies and procedures, third-party due diligence, risk assessments activities. AAR does not make employment-related decisions ® and similar measures designed to promote our Doing It Right based on an individual’s legally protected personal characteristics. corporate purpose. These commonly include race, religion, color, age, gender, sexual orientation, disability, gender identity, veteran status and national origin. We require all new hires to complete Code of Anti-harassment Conduct training, and training is also an annual requirement for all employees. Our commitment to inclusivity means that we want everyone to feel respected and safe in the workplace. As such, harassment and bullying have no place at AAR. We do not tolerate behavior that creates an intimidating, hostile or offensive work environment. 36