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At AirPlus International we bear responsibility for our customers, shareholders, communities, and each other by adhering to the highest ethical standards, which is reflected in the Code of Conduct that applies to AirPlus.

AirPlus encourages all employees and external Whistleblowers to report any suspected misconduct and compliance violations involving AirPlus’ business and provides protective measures to enable individuals to make a disclosure of such conduct or violation without fear of reprisal.

Staff members are encouraged to speak up through a variety of available channels, which are provided in our Intranet together with comprehensive information on how to raise concerns and suspicions.

Additionally, if you, as an external party, have reasonable grounds to suspect that our employees or individuals acting on behalf of AirPlus are committing compliance violations such as:

• Bribery, corruption
• Money laundering, financing terrorism and violation of embargoes and sanctions rules
• Competition/ cartel offences
• Corrupt activities and property offences
• Compromising or violating human rights, or environmental damage
• Violation of data protection regulations and IT-standards
• Violation of other laws
• Ethical misconduct

please use our below whistleblowing channels. Your information can help to identify risks at an early stage and avert sanctions and damage to our reputation.

You are not obliged to identify yourself when making a report. All information received will be treated confidentially and sensitively, in adherence to the provisions of the Regulation (EU) 2016/679 (General Data Protection Regulation) and applicable national data protection laws.

AirPlus protects the identity of the Whistleblowers as well as persons who are the subject of a report and other persons mentioned in a report to the full extent of applicable laws. If you have provided a contact option (for example, by setting up an anonymous postbox in the electronic whistleblowing system), you will receive a confirmation of receipt. Follow-up questions which may arise in course of the investigation of a report will be addressed via the same channel. You will then be informed of the progress in the processing of your report and of the outcome of the investigation.

Electronic Whistleblowing System

With the help of our electronic whistleblowing system, you can easily, safely and if you wish anonymously report an incident. The system enables you to send encrypted and secure messages to the Compliance Office.

Access to the system

External reporting channels of the authorities

Whistleblowers can also directly contact the external reporting channels . However, it should be noted that the investigation of the report and the implementation of the requirements of the applicable local laws in this case is the sole responsibility of the external reporting office. AirPlus cannot assume any responsibility or guarantee any protective measures in this respect.

List of external reporting channels