OUR CODE OF CONDUCT

One Air New Zealand Doing what’s right

LAST UPDATED: JANUARY 2020 A message from Greg

We are a proud and iconic New Zealand business sharing the best of our country with the world. Every one of us plays a role in shaping the Air New Zealand experience for our customers each day.

Our Code of Conduct reflects the way we do things around here and serves as a guide to how we should behave and the daily decisions we make. Part of this means thinking, acting and working as One Air New Zealand so we’re consistent right across the airline. Let’s all take pride in working for this uniquely Kiwi organisation and together commit to doing what’s right. Be honest, act with integrity, transparency and mutual respect. Please take the time to understand our Code of Conduct, apply the principles to the work you do every day and speak up if you have concerns about any behaviour you feel is in breach of this Code. Ngā mihi,

Greg Foran Chief Executive Officer

BACK TO CONTENTS Contents

A Message From Greg 0

About our Code of Conduct 1 What is it? 2 The Code Applies to All of us 2 Comply with the Law 2 Refer to the Code and Ask Questions 3 Make a Commitment 3 Speak Up 4

Our Business Principles 7

Operate Safely, Responsibly and Reliably 11 Safety 12 Avoiding Alcohol and Other Drugs 14 Crisis, Emergency and Business Disruption Management 15 Airline Security 17 Environment Sustainability 18 Sponsorship, Grants and Donations 18

Act with Integrity, Honesty and Transparency 21 Be Free of Conflicts of Interest 22 Using our Digital Communication Systems 24 Exchanging Gifts and Entertainment 25 Using Business Resources 28 Travelling for Business 29 Speaking on Behalf of Air New Zealand 31 Using Social Media 32

Protect our People, Property and Information 35 Financial Integrity 36 Committing to Contracts and Expenditure 37 Accurate and Complete Information, Records, Reporting and Accounting 38 Protecting Privacy and Confidentiality 39 Information Security 40 Protecting and Respecting our Property 44

Treat People Fairly and with Respect 47 Diversity and Inclusion 48 Merit-based Recruitment and Selection 49 Preventing Bullying and Harassment 50 Ethical Business Practices of Suppliers 51

Comply with the Law 53 Anti-money Laundering 54 Ensuring Continuous Disclosure 55 Eliminating Bribery, Corruption and Improper Payments 56 Avoiding Insider Trading 57 Competing Fairly 58

Administration of the Code 60

Living our Code 61

© Air New Zealand 2016 AIR NEW ZEALAND CODE OF CONDUCT ABOUT OUR CODE OF CONDUCT

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 1 ABOUT OUR CODE OF CONDUCT

What is it? The Code applies to all of us Refer to the Code Make a commitment As Air New Zealanders, we are all expected to live our The Code of Conduct (‘Code’) sets out what we expect The Code applies to all Air New Zealanders globally – and ask questions Leadership Behaviours and ‘do what’s right’ in our daily from every person working for and with Air New Zealand, including our executives, employees, contract workers or work and actions: regardless of location, and confirms our commitments agents who provide services on our behalf, subsidiaries, Please read the Code and refer to it often. It’s your • Act safely, ethically and responsibly – taking pride to our people, our business partners and stakeholders. and directors. guidebook for doing what’s right. To supplement the general guidance of the Code, Air New Zealand has in your actions and decisions. The Code brings together all of our policy principles, We expect our suppliers and business partners to uphold more specific policies and standards that apply • Comply with the principles in this Code and fulfill and provides a working guide for employees to do the right equally high standards, and abide by our Supplier Code globally, geographically or to certain divisions, your legal and regulatory obligations. thing when making decisions in our daily activities. of Conduct. functions or departments. • Hold your colleagues accountable for It is absolutely essential that all Air New Zealanders read, Take the time to understand the policies that are referred behaving ethically and following this Code understand and live by this Code. to throughout the Code and how they apply to you in your and legal requirements. While the Code provides guidance on standards of integrity role. You are encouraged, and expected, to seek additional • Speak up if you see behaviours which are unsafe, and business conduct, it doesn’t attempt to address every Comply with the law help whenever you have questions or aren’t sure about unethical or in breach of our Code. situation that we might encounter. Refer to the Business the right course of action. Managers, Human Resources Principles to guide your behaviour and decisions, keeping Our Code reinforces our commitment to both the letter and and our Risk & Compliance team are available to help you in mind our Brand Values and Leadership Behaviours which spirit of our legal requirements and our policies, standards if you need them. Our leaders have additional responsibilities underpin all of our actions. and business principles. under the Code: The airline industry is highly regulated by local government • Enforce the Code consistently for all your employees. and the governments of other countries where we do • Where there is a conflict between our ethics and business. Without exception, Air New Zealand observes and business objectives, our ethics must always come first. complies with all applicable laws, rules and regulations. • Support appropriate business conduct and ethics However, our Code cannot cover all laws, regulations and compliance activities. other legal requirements in all countries we operate in. Always be familiar with the relevant laws and regulations • Make sure appropriate controls are in place in your that apply where you work. If there is a difference between team. a local legal requirement and our Code, apply the most • Never cover up or ignore any business conduct or stringent standard. If in any doubt, contact your manager ethical problem; address the matter immediately and or our Legal team. seek guidance if necessary. • Encourage your team members to ask questions and raise any conduct or ethical concerns by: – Encouraging them to speak up – Dealing with concerns when they are raised – Making sure that no one who speaks up is treated We need all Air New Zealanders unfairly as a result to read, understand and live by this Code.

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If you are faced with a difficult issue, Speak Up Q. I am concerned that my colleagues Q. What if I report something ask yourself: will find out if I raise a concern. suspicious that turns out not Will it be kept confidential? be a breach of compliance? Don’t ignore behaviour that is unacceptable, even small things, because we believe small actions can A. Yes, Air New Zealand will not A. As long as your report was made make a big difference. Is it legal and ethical? tolerate retaliation against anyone in good faith because of a genuine We encourage everyone to raise concerns about who raises, in good faith, a genuine concern, no action will be taken potentially unethical or illegal conduct, while assuring concern. We will keep what you against you. confidentiality and protection against retaliation or any tell us private throughout the Is it consistent with our investigation process, subject to our form of harassment. Our Just Culture policy and legal obligations. Your issue will be procedures support a fair and confidential process. Business Principles and kept confidential regardless of which Q. I have a concern about the actions of a colleague. If you see behaviour at work that you feel may breach this method you use to report it. Leadership Behaviours? How should I report this? Code or seems illegal or unethical – like bribery, theft or fraud, price fixing or a breach of data privacy – you must A. The most important thing is that report it, even if you only suspect it. Does it comply with Q. I am a contractor working with you report your concern. It doesn’t You must also report abuse of our systems, processes or Air New Zealand and I have a matter which route you choose. If policies. This could be bullying or harassment, potential our policies? concern to report. Can I use the you feel comfortable talking to your Speak Up reporting line? manager, do that. Your manager is conflicts of interest, or danger to the health and safety there to support you and can help of employees or customers. A. Yes, the Speak Up line is for you choose the correct course of Can I explain it to family, employees and contract workers, action. Alternatively, you can contact There are three ways to speak up: as well as suppliers and your HR Business Partner or use the Report it to your manager friends or colleagues? business partners. Speak Up line. We know it’s not always easy to raise your concerns. We value open and honest communications, so you’re encouraged to discuss any issues or potential issues Will I be comfortable if with your manager. it appears in the media? Report it to your Human Resources team If it’s not appropriate, or if you are not comfortable discussing the issue with your manager, you should discuss it with your HR Business Partner. Every business If the answer to any of these is NO, don’t do it. area has one or more HR Business Partners – ask your manager if you don’t know who yours is. If you are still unsure, seek help by talking to Report it confidentially using the Speak Up line your manager, HR Business Partner or the Risk You may want to report your concern to someone who is & Compliance team. independent from the situation. Search Speak Up on the intranet to find the phone numbers, or form to make a report online. The standard you walk past is Air New Zealand has a non-retaliation policy when a the standard you accept. genuine concern has been reported. This means that no Lt. Gen. David Morrison, Australian Army Chief action will be taken against you if you report concerns in good faith, even if proven not to result in a breach.

For safety-related incidents or issues, continue to use our safety reporting process as a first priority.

POLICIES COVERED: JUST CULTURE AND REPORTING POLICY RISK MANAGEMENT POLICY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 5 OUR BUSINESS PRINCIPLES

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 7 OUR BUSINESS PRINCIPLES

Our Business Principles are the foundation Our Business of how we do business everywhere we operate, and reflect the commitments we make to our people, our business partners and stakeholders. Principles These are at the heart of our Code of Conduct.

Operate safely, responsibly and reliably Act with integrity, honesty and transparency Protect our people, property and information Treat people fairly and with respect

• We will protect the health, wellbeing, safety and security • We will avoid any activity or contracts that may lead • We will base our investment decisions and business • We will treat people fairly, with dignity and will pursue of our customers, employees and the communities in to, or suggest, a conflict of interest between personal relationships on economic criteria from objective and equality of opportunity and inclusion for all employees which we operate. activities and Air New Zealand. complete due diligence information. through our employment policies and practices. • We will not tolerate anyone being affected by alcohol or • We will build trust through integrity, transparency, • We will not commit to expenditure without We value diversity of people and thought. other drugs in the workplace. honesty and objectivity in our business dealings appropriate authorisation. • We will recruit, select and develop our people on • We will operate our business with discipline and excellence and relationships. • We will only spend company money where there is merit – irrespective of age, race, colour, origin, gender, to ensure sustainability, resilience and effectiveness. • We will use business resources in the best interest a legitimate business need and where the cost is worth religious beliefs, disability, family or marital status, sexual orientation or other prohibited grounds. • We will protect and safeguard the natural environment, of Air New Zealand and not for personal gain. the benefit. minimising our use of finite resources and the release of • We will communicate honestly, responsibly and • We will take into account social, ethical and • We will not accept any form of discrimination, harmful emissions to the environment. transparently with all stakeholders within the bounds environmental considerations in our procurement harassment or bullying. • We will invest in society and communities ensuring of commercial confidentiality. and supply chain decisions. • We will perform at our best, demonstrating effective use of our resources and in line with our mission. • We will secure and safeguard our confidential and professionalism, living our values and operating with sensitive information from improper disclosure to acute customer focus at all times. We will proactively prevent harm to Air New Zealand, our stakeholders, address under-performance. employees or customers who have trusted us with • We will work in good faith, within the appropriate legal their information. framework, with trade unions and other bodies that our • We will protect and safeguard our brand, property, people collectively choose to represent them. intellectual property and financial assets. • We trust each other to deliver on our commitments and • We will respect people’s legal rights to privacy and the obligations, and value collaboration as the best means of confidentiality of personal information. working together to achieve superior outcomes. • We will empower our people to enhance their personal potential by offering satisfying and challenging work and career opportunities, investing in development and Comply with the Law personal growth. • We will reward and recognise our people for work which contributes to our mission to supercharge New Zealand’s • We will comply with all applicable domestic and success, and for demonstrating the right behaviours that international laws and regulations, appropriate standards reflect our values. and principles, including all competition, anti-trust and anti-money laundering laws. • We will respect people’s lives outside of work, balancing life activities, and valuing their contribution to society. • We will not tolerate any form of bribery, including improper offers of payments or gifts to or • We will not tolerate child labour and are committed to the from employees. elimination of all forms of forced and compulsory labour.

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 9 OPERATE SAFELY, RESPONSIBLY AND RELIABLY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 11 OPERATE SAFELY, RESPONSIBLY AND RELIABLY

Safety Q. Should I report an incident even if it We will protect the health, wellbeing, didn’t result in an accident or injury? safety and security of our customers, Safety at Air New Zealand is a top priority. A. Yes. Report any incident no matter employees and the communities in We are committed to achieving a Zero Harm work how small. Tell your manager environment and instilling a culture of safety and straightaway so we can take action to which we operate. prevent similar incidents happening continuous improvement. We expect everyone in the future. at Air New Zealand to behave in a safe and responsible manner at all times.

Q. If I report a safety issue, will I get in trouble if I’m the one who What this means for you: made the error? • You are responsible for your own safety and wellbeing, A. No, as long as it wasn’t done and the safety of your colleagues and our customers. recklessly or with malicious intent. • Only undertake work if you are medically fit for duty, We are all human and sometimes sufficiently rested and alert to carry it out. we genuinely make mistakes or errors. We encourage everyone to • Comply with applicable safety laws and follow the safety report any safety-related incident or procedures and requirements specific to your area. situation without fear of retaliation or • Never compromise on safety or knowingly create punishment. Being open and honest situations where the safety and wellbeing of any person about safety issues is important is put at risk. Intervene where you see unsafe practices to our Just Culture philosophy and helps us prevent any future or non-compliance with procedures. safety risks. • Prevention is critical – identify and report any hazards. • Report events immediately where safety and wellbeing have been compromised, including any near miss, Q. I see colleagues talking on their incident, accident, injury, illness, unsafe or mobile phones while driving all the unhealthy condition. time. Is this ok? • If injured, ensure you do all you can in your recovery and rehabilitation for a safe and timely return to work. A. No. Nobody should use a handheld • Always drive safely, responsibly and legally when mobile device while driving any vehicle used for work purposes, operating company vehicles or on company premises. including vehicles such as baggage Never use handheld mobile devices while driving. trolleys and forklifts. trolleys • Where your attention to safety is critical, limit using and forklifts. mobile devices in the workplace.

POLICIES COVERED: PEOPLE HEALTH SAFETY AND WELLBEING POLICY AIRLINE SAFETY POLICY ACCEPTABLE USE OF BUSINESS RESOURCES POLICY AND SUPPORTING STANDARDS

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We will not tolerate anyone We will operate our business being affected by alcohol or with discipline and excellence to other drugs in the workplace. ensure sustainability, resilience and effectiveness.

Q. What if I’m on call after hours and at Avoiding Alcohol weekends? Does this mean that I am Crisis, Emergency and unable to consume alcohol for that and Other Drugs period of time? Business Disruption Management Alcohol and other drugs must never affect A. Being on call to respond to work us in our work. Our safety, and that of our related situations is typically Crisis, emergency and business disruption colleagues and customers, depend on it. considered to be ‘on duty’ or an extension of your duties. Therefore, management is important to protect our people Therefore, you must maintain a zero blood if you are rostered or paid to be on and reduce any damage or loss. Effective alcohol level and be drug free while working. call, you must remain alcohol and crisis, emergency and business disruption This includes being free from the negative drug free. In cases where you are called on for work when you’re not planning ensures we’re committed to health and effects of legal drugs, such as prescription expecting it, safety must always safety, minimising damage and impact to the medication. Any possession, use, sale or come first – so let the caller know Company, and keeping our operations going distribution of illegal substances at work will if you’re not alcohol or drug free so they can find an alternative person. after any disaster. We must retain a high level of be treated very seriously. Air New Zealand preparedness to respond to any type of business provides support to those affected by interruption in any location where we might have problems with alcohol or other drugs. Q. I have been invited to a corporate function held after hours. Am I people, property or assets. allowed to have a drink there?

What this means for you: A. Any time you are representing What this means for you: • Never work, under any circumstances, while affected Air New Zealand at a function, keep in mind that your behaviour will Know your individual responsibilities and follow crisis, by alcohol or any other drug that impairs judgement, • reflect on the Company’s reputation. emergency and business disruptions procedures, performance or behaviour – be drug free and maintain Alcohol consumption in social including knowing local emergency contact details. a zero blood alcohol level. settings and at corporate functions • Assist in developing and implementing local crisis, • Never drive a vehicle used for business purposes during after hours is acceptable, provided emergency and business disruption plans for your work hours or on work duties if you aren’t drug and that all formal business has business area as requested. alcohol free. been completed, alcohol is used responsibly, and you are not on call • Continually assess risks and any financial, reputational • Don’t use, sell, distribute or be in possession of alcohol or or otherwise expected to return to and other non-financial threats that may impact your other drugs while working or while on our premises. work. If driving afterwards, ensure business area. • Discuss with the Medical team prescription medication or you are within legal limits. Test and practice your crisis, emergency and other legal drugs which may impair your ability to work. • business disruption procedures to improve response • Don’t store or consume alcohol on our premises unless it’s Q. What about drinking while preparedness. authorised (e.g. sponsored and supervised functions on I’m on Duty Travel? Debrief following an event to ensure lessons are learned our premises). • and actioned. • Report in confidence any concerns you have about your A. Any time you are travelling for work, use good judgement. Ensure that own use, or a colleague’s use, of alcohol or other drugs to any consumption of alcohol before, our Medical team for support and advice. during or after travelling will enable • You may be required to undergo alcohol and other drug you to comply with the policy when testing for safety sensitive roles and where there is cause. you are next expected to work. Familiarise yourself with local drug and alcohol laws, cultures and customs when travelling for

POLICIES COVERED: business purposes. POLICIES COVERED: ALCOHOL AND OTHER DRUGS POLICY CRISIS, EMERGENCY AND BUSINESS RESILIENCE POLICY

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Q. I’ve seen people ‘tailgate’ me through the security doors without swiping their card. What should I do in these situations?

A. Tailgating through security access doors is not permitted – you must swipe through. Next time this occurs, Airline Security politely ask the tailgater to swipe their own card, and ensure you’re not followed through the security door. Global security remains volatile and we must take our safety and security seriously. We are all responsible for having a high level of security Q. I’ve noticed visitors walking around awareness and consistently applying appropriate the office unescorted without a security ID or visitors badge on. Is security measures to protect our customers, that ok? employees, assets, premises and property in our care. A. No. People must be authorised to be taken into secure areas – i.e. any area that requires a password or swipe entry. All visitors must register What this means for you: at reception, wear a security badge • Always wear your security ID in secure areas so it is visible to enter a secure work area and be to others – make sure it’s current, accurate and valid for the escorted by an Air New Zealander at all times. If you see someone without area in which you work (restricted vs non restricted). a visible ID, first phone Security to • Immediately report to our Security team any actual or report the breach, then approach perceived security risks, weaknesses, threats, or unusual the person and politely question who or suspicious activity or behaviour. they are here to see, and escort them to the main reception area to wait for • Vigilantly adhere to safety and security protocol, standards their contact. and practices at all times, and follow requirements specific to your area. • Never bring unauthorised individuals into secure areas Q. Part of my uniform went missing without the appropriate security checks and authorisation. from my hotel room on my last Tour Always escort your visitors while they are on the premises of Duty. Is that a big deal? – never leave them alone in secure areas. Yes. Uniforms should be treated as an • Report any loss of property straight away, including A. item of security. You must report any security ID cards, Air New Zealand uniforms or branded theft or loss of a company uniform to work wear, to local police and our Security team. police and our Security team. There • Store equipment and other property securely to prevent is a very real possibility that lost or unauthorised use or theft. stolen uniform items could be used to do harm by posing as an employee to • Read travel advisories and security tips before travelling get into secure areas. overseas for business.

Refer to the Information Security section for protecting and securing data and information. Q. Should I report a small incident, even if it didn’t result in major security breach? A. Yes, report it to the Security team. Without knowledge of security incidents or events - including potential threats - we are not able to fully assess risk. What you might think is an isolated incident may in

POLICIES COVERED: fact be one piece of a larger puzzle. SECURITY POLICY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 17 OPERATE SAFELY, RESPONSIBLY AND RELIABLY

Q. I serve on the board of directors Q. My team wants to raise money of a non-profit organisation that for a local charity. Are there any supports environmental initiatives. restrictions on who to donate to? Can I guarantee the board that We will invest in society Air New Zealand will donate to A. No, there are no restrictions on giving and communities ensuring the organisation? personal donations. These should be done in your own time and with your effective use of our resources A. No. You must make clear that your own resources. participation on its board is in and in line with our mission. your individual capacity and that it is unlikely that you will be able to secure any donation from Air New Zealand. If the organisation has historically received donations or has a formal relationship with Environment Sponsorship, Grants us, approval for the directorship is required in advance of you Sustainability and Donations accepting a board position.

We are committed to preserving and protecting As New Zealand’s national carrier, we are New Zealand’s natural environment for the committed to using our resources to enrich future. We take responsibility for operating in an our communities, protect the environment environmentally sustainable way, minimising and promote New Zealand. We support Air New Zealand’s impact on the environment legitimate and worthy causes aligned to our and improving our energy performance. purpose, mission and values, including those based on humanitarian needs. Through proper governance of grants, sponsorships What this means for you: and donations, we protect Air New Zealand’s • Comply with applicable environmental laws reputation with all stakeholders. and regulations. • Report any non-compliance with environmental laws and regulations to your Property and What this means for you: Facilities Manager. • Ensure all sponsorships or donations are • Do your bit to reduce, recycle, reuse and be energy appropriately authorised. efficient in your work environment. • Ensure that your participation in personal fundraising • Support using and procuring sustainable energy- activity is not construed by the public as being endorsed efficient design, products and services to help by, or on behalf of Air New Zealand. improve our energy performance. • Never request sponsorships or use company money to • Educate, support and encourage others (including make charitable donations to close deals, seek favours suppliers and customers) to take responsibility for from decision makers, support illegal activity or for efficient energy practices in their workplaces personal gain. and communities. • Raise questions about any potential conflict of interest • Support company environmental or appearance issues that may arise from charitable sustainability initiatives. donations or sponsorships. • Never use company money to make donations to political parties, campaigns or candidates. We will protect and safeguard the natural environment, minimising our use of finite resources and the release of harmful emissions to the environment.

We’re proud to partner with the Department of

POLICIES COVERED: POLICIES COVERED: Conservation bringing some of New Zealand’s SUSTAINABILITY POLICY SPONSORSHIPS AND DONATIONS POLICY rarest birds back to their natural homes.

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 19 ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 21 ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY

Q. I work part-time in my family’s Q. A close friend is applying for a job at business. Do I need to disclose Air New Zealand. Is this ok? an interest? A. Absolutely. We encourage you to A. Yes, even if the business is not recommend Air New Zealand as a related to Air New Zealand, you great place to work. However, you must disclose it, as it may become need to ensure that you are not a conflict if it affects your health, involved in the recruitment process job performance or the quality of and that the job your close friend is your work. applying for does not report to you Be Free of Conflicts (either directly or indirectly). of Interest

We must all be free from actual, perceived What this means for you: Here are some examples of when you might face a conflict of interest. or potential conflicts of interest. A conflict • Act in Air New Zealand’s best interest and make of interest can happen if an employee’s objective decisions. Friends, relatives and co-worker relationships Outside activities or investments personal, social, financial or political activities • Discuss conflict of interest concerns with your Business relationships with relatives, spouses, partners/ You may have a personal interest in one of Air New interfere (or could be seen to interfere) with manager, disclose all conflicts and report them on significant others or close friends can lead to a conflict Zealand’s existing or potential competitors, suppliers their judgement in work-related decisions. the Conflicts of Interest Register. of interest. We don’t prohibit family members or friends or customers, which might affect or compromise our Whenever possible, conflicts of interest • Remove yourself from business decisions or processes from being employed by the Company, or close personal business, or your ability to perform your job. These should be avoided. If they arise, always where you have a personal interest. relationships between co-workers. However, a relative or situations can create an actual or perceived conflict close personal friend cannot have any business dealings of interest if they involve you: disclose them immediately. Even the • Never get involved in hiring, supervising, managing, with you, anyone who reports to you (direct report), or promoting, rewarding, or advancing any relative, close • Having a second job appearance of a conflict of interest can anyone working in your business unit (indirect report). friend or partner. be harmful and needs to be addressed. Similarly, intimate relationships of any duration between co- • Serving as a director or consultant, or providing • Never affect or influence the terms and conditions workers can, depending on the work roles, create an actual professional services of a contract for service, or for employment, of any or apparent conflict of interest. • Having material financial interests in a competitor, employee, contractor or supplier who is a relative, Q. Do conflicts of interest include supplier or customer, or close friend or partner. If you are faced with the possibility of a business or personal people I have close personal relationship conflict of interest, you should disclose it to • Taking part in civic or public duties. relationships with as well as • Avoid working or consulting for, or providing your manager, so the potential conflict can be managed. actual relatives? professional services to, anyone external that you As a general rule, you may work, or consult, for other deal with as part of your job for Air New Zealand. We must all exercise care when providing travel services organisations while employed at Air New Zealand as A. Yes. Any close relationship, no to relatives, friends or co-workers. Providing preferential long as you inform your manager and gain appropriate • Never use business resources for personal political matter how current, that may create treatment to them is not allowed – this includes approvals from the Legal team before accepting the activity, make political donations in Air New Zealand’s an actual or perceived conflict unauthorised deviations from established rules for pricing, work. Outside activities should not interfere or conflict name, or give the impression that the Company of interest is included. We can’t issuing, exchanging or refunding tickets, inappropriate with your job responsibilities – for example, scheduled endorses any candidate, campaign or political issue. list every activity or relationship. upgrades, improperly withholding seats from inventory hours, overtime when required, or job performance. However, a conflict of interest • Never provide sensitive or confidential information to or blocking space and ignoring boarding priorities. This includes selling goods or services for personal includes any activity that could a competitor or third party, including friends or profit during work time or using your employment interfere with your objectivity to relatives – see the Competition Law section. at Air New Zealand as an endorsement for Air New Zealand. See our Subsidiary Directorships Policy and Industry personal business. Associations Policy for information on the invitations We will avoid any activity or Knowingly maintaining substantial financial interests Q. My colleague’s son just joined our for directorships within the Air New Zealand Group or or investments in a competitor, customer or supplier team. Is this allowed? for Group representation on industry association contracts that may lead to, or without disclosing them is not allowed. boards/committees. suggest, a conflict of interest A. Unless local policy prohibits it, relatives can work in the same between personal activities team, department or business unit. Political or civic involvement The only rule is that no relative and Air New Zealand. If you are involved in civic or political activities, it must can ever be in a position to either hire, supervise, affect the terms be on your own time, and with your own resources. You and conditions of employment should never use Air New Zealand resources such as time, or influence the management of property, material, cash, equipment or branding for political another relative. donations or activities. POLICIES COVERED: CONFLICT OF INTEREST POLICY SUBSIDIARY DIRECTORSHIPS POLICY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 23 ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY

Exchanging Gifts and Entertainment We support reasonable and proportionate giving We will build trust through and receiving of gifts and entertainment as part of a normal business relationship or cultural practice. integrity, transparency, They’re permitted as long as they’re ethical, honesty and objectivity in related to Air New Zealand business, infrequent, Using our Digital Q. I use a range of internet and social our business dealings media sites for my job. Why are low in value, legal and customary in a business and relationships. Communication Systems some sites blocked? relationship. We prohibit the giving or receiving of significant gifts or significant benefits (including For many of us, the use of the Company’s intranet, A. We encourage the use of the internet for research, training and hospitality, discounts and other benefits not internet, phone and email systems is critical to our collaborating in the context of your available to all employees). jobs. Air New Zealand invests in strengthening our job. Some sites are not appropriate Q. I’ve been sent a high value gift by We need to ensure we are never influenced, digital workforce and provides access to a range for the workplace, don’t have a supplier and don’t want to cause appropriate levels of security or are or seen to be influenced, by gifts or entertainment offence by returning it. What should of IT resources to connect and collaborate as one used predominately for personal or other inducements during a tender process I do? Air New Zealand. These systems and resources, use. In these cases, the sites have or when signing a new deal. These actions can such as Wi-Fi, are intended to be used for business been blocked. If you run into issues, A. Notify your manager and seek contact the IT Service Desk for create conflicts of interest, or raise questions guidance from the Legal team. Ideally, purposes. As a user of these resources, you have information and assistance. about our judgement. you should politely refuse and return access to valuable information, sensitive data the gift. If this is not possible, then the and internal and external networks that must be item should be donated to charity. protected and used responsibly. Q. I recently noticed that a colleague in my department spends a lot of What this means for you: work time on the internet and social • Seek approval and record gifts, hospitality and entertainment Q. I work at checkin. A regular customer networking sites, despite a backlog on the Gifts Register if valued at NZ$250 or more. offered me a tip as thanks for taking What this means for you: of incomplete projects. Is this ok? • Avoid giving or accepting anything of inappropriate value. care of a reconnection on his last • Use digital communication systems and other IT trip. He then asked me to upgrade resources in a responsible, ethical and legal manner. • Avoid giving or accepting any gifts or entertainment during him to business class outside of A. No. Personal use of company a tender process that would be perceived as preferential appropriate guidelines. What should Don’t use them for any illegal, unethical, or objectionable resources (including Internet and treatment or providing an unfair advantage. I have done in this situation? activities such as gambling, pornography or other email) should be limited and never inappropriate subject matter. interfere with job responsibilities. • Think about the context of the gifts, entertainment or A. The best course of action is to His or her use of social networking • Don’t use company computers and equipment for outside hospitality – imagine how it might look to someone outside of thank the customer for their sites is likely to be excessive and businesses, personal gain or personal activities. Air New Zealand. thoughtfulness and politely decline could even lead to damaging accepting the tip, ensuring that you • You are personally accountable and liable for all activities computer viruses. You should • Never accept any cash or cash equivalent, even as a tip for operate within established rules associated with your user accounts and company report the issue to your manager. great service. regarding upgrades. equipment. • Never give or accept gifts from competitors or public officials. • Incidental personal use of IT resources (email, internet, • Never ask for gifts, entertainment or any other inducements. social media) at work is acceptable as long as it: • Discuss any concerns with your manager. Q. A colleague in my team manages the – doesn’t affect your, or others’ job performance or relationship with a wholesale travel productivity, and agency on behalf of Air New Zealand. ‘Gifts and entertainment’ include anything of value offered to or Last week, I heard the agency offered – doesn’t interfere with operations or system received by you or a member of your family. ‘Gifts’ include cash my colleague a significant discount performance (e.g. sending large personal files) or and non-cash items. ‘Entertainment’ is where you accompany for personal travel that isn’t available consume significant time or resources, and a third party to an event. Entertainment should be treated as a to other employees. Is this allowed? – doesn’t create risk to Air New Zealand as a result of gift if the party who made the offer does not plan on attending. your personal use, and ‘Inducements’ are gifts, entertainment, services or benefits for the purpose of securing business or favourable terms outside A. No. By offering this discount to your doesn’t violate other company policies. – of the normal process. colleague, which is not available to all employees at Air New Zealand, the Review the Bribery and Improper Payments section for agency created a conflict of interest additional guidance on inducements. between official company business and your colleague’s personal gain. POLICIES COVERED: POLICIES COVERED: ACCEPTABLE USE OF BUSINESS RESOURCES POLICY GIFTS AND ENTERTAINMENT POLICY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 25 We need all Air New Zealanders to read, understand and live by this Code.

BACK TO CONTENTS ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY We will use business resources in the best interest of Air New Zealand and not for personal gain.

Q. I’ve seen colleagues checking out Using Business Resources flight details and seat assignments Travelling for Business of celebrities who fly on Air New Resources are provided to you to perform Zealand. Is this allowed? At times, employees need to travel for work. As an the requirements of your job. We must all use airline, we must balance the needs of commercial business resources responsibly and only for A. Definitely not. Unless these customers with our business travel requirements. individuals are directly booking or business purposes. All business resources have altering a customer’s travel plans, When planning your trip, use your judgement to an economic value, so use them effectively. employees are not allowed to access find the right balance between business need, confidential information out of environmental impact, financial cost and your personal interest. We should always Common business resources include: protect the identity, privacy and health and safety. Q. My travel costs into the office • IT resources and computer equipment safety of our customers. are expensive. Can I claim some including access to electronic information, of it back? What this means for you: networks, software, internet, systems and Q. I sometimes use my company A. No. Normal travel to and from equipment such as desktops, laptops, phones, laptop to respond to personal • Only travel on business when there is a genuine need, work can’t be claimed as a travel and mobile devices emails, do my personal online where travel is authorised and pre-approved. Manager expense – this cost is considered banking and for other personal approval is required for domestic or intra-regional your responsibility and not a activities at home? Is this ok? • Business-related travel business travel; international travel requires additional business expense. • Budgets, expenditure and company credit cards GM approval (or Chief approval for GMs). A. Our preference is that you use • Office furniture, equipment and supplies business resources for business- • Use the defined procedures to book travel (e.g. through Q. I travel regularly for business. related work. In principle, business Tandem Travel for International travel and your local Can I access the Koru Lounges • Branded material and official company images resources provided to you for work travel arranger for domestic or regional travel) – never when I’m travelling so I can work and content are not intended to be a replacement book your own business travel, including flights, more productively? for personal resources, however accommodation and rental cars. • Company-provided vehicles and car parks. incidental and occasional use of IT A. Access to our Koru Club Lounges is resources is acceptable where the • Use preferred suppliers to help minimise the for members only. If you personally cost and risk to Air New Zealand cost of travel. have a membership, then you can is negligible. We ask that you use • Only claim business expenses that are necessary use the Koru Lounge whenever What this means for you: you travel (we offer a discount to common sense and good judgement. and reasonable for your business travel. Use a employees who purchase Koru Club • Use business resources and assets for company company credit card for travel-related expenses memberships). Some roles require business – this includes money, equipment, materials, whenever possible. business travel so regularly that the information and time. Q. Can I use my company credit card to pay for personal items, especially • Ensure you are medically fit for your planned travel and Company purchases a Koru Club • Only use resources that you are authorised to use and if I’m short on cash? I would pay it review safety protocols and security advisories for your membership on their behalf. In these complete all necessary authorisations. back to the Company, of course. destination – discuss any concerns with our Safety and cases, where there is capacity, staff may access the Lounge. • Only access or use authorised resources or information Security teams. where there is a legitimate business need and not for • Personal travel is not be taken in conjunction with A. No. Never use a company credit card, personal interest or gain. business-related travel. or any company funds, to pay for Q. I’m travelling overseas for business • Use resources responsibly and cost effectively. personal items. • To reduce risk, executives, management groups or and would like to add on some annual leave at my cost. Is this allowed? • Don’t engage in personal activities during work hours other key individuals should avoid travelling together. that interfere with you fulfilling your job responsibilities. • Maintain professionalism at all times – you are an Q. I have access to company tickets to A. No. Annual leave cannot be taken ambassador for the airline. • Take all reasonable and necessary steps to protect a sporting event that are being used together with business travel. company resources and assets, including the for marketing promotions. Can I give Air New Zealand honours any provision in employment However, there are times when it is prevention of theft. them to a friend who works at a hotel agreements regarding duty travel, where it differs to policy. acceptable to add, for example, a weekend to a planned business trip. • Use business resources in line with our confidentiality in exchange for a free hotel room for my personal use? Because of the potential conflict of and privacy guidelines. interest, you must openly disclose A. No. The tickets are considered your intent, gain approval from your Chief, and ensure that there is no POLICIES COVERED: company property and cannot be ACCEPTABLE USE OF BUSINESS RESOURCES POLICY AND SUPPLEMENTARY used for personal gain. POLICIES COVERED: financial impact to Air New Zealand. STANDARDS DUTY TRAVEL AND TRAVEL-RELATED EXPENSES POLICY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 29 ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY

We will communicate honestly, responsibly and with transparency with all stakeholders within the bounds of commercial confidentiality.

Q. A local reporter has contacted me through a mutual friend to ask me Speaking on Behalf about this year’s Annual Report. Can I comment? of Air New Zealand

A. No. Only authorised spokespeople As a publicly-listed company, we are bound for Air New Zealand can provide by strict rules to ensure that publicly released comment to the media. You should information is appropriately disclosed and put the reporter in touch with our Corporate Communications team accurately reflects the Company’s position. on the 24 hour media line: (+64) No one should make comments on behalf of 021 747 320. Leaks of company Air New Zealand unless they are an authorised or confidential information to the media will be treated very seriously. spokesperson or have prior approval from Corporate Communications. This includes when contributing to professional journals or presenting Q. I’ve been invited to speak at a at industry association conferences. professional conference in my area of expertise. Do I need permission to speak on behalf of Air New Zealand? What this means for you:

A. Yes. You need to gain approval • Only make comments on behalf of Air New Zealand if you from your GM before speaking are authorised to do so. This includes passing on to third at conferences. If you plan on parties information intended for internal use only. using Air New Zealand material, • Direct any media enquiries or requests to the Corporate Corporate Communications Communications team. must review your content to protect against disclosing • Never disclose commercial or strategic information confidential, sensitive or about the Company, our employees or our proprietary information customers without permission, even after you leave Air New Zealand. • Return any unsolicited confidential information you receive to the sender or ensure it’s deleted. • Gain approval from your GM and have your content reviewed by our Corporate Communications team before contributing to professional journals or speaking engagements.

POLICIES COVERED: MEDIA COMMUNICATIONS POLICY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 31 ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY

Q. Am I allowed to say where I work on my social network profile?

A. Yes. You can disclose on your ‘About’ page or bio that you are an Air New Zealander, which part of the What this means for you: organisation you represent and what Using Social Media your responsibilities are. You may • You are personally responsible and liable for anything want to include a link to the We recognise the importance and benefit of you post online, whether speaking personally or in an Air New Zealand website. official capacity for Air New Zealand. communicating through social media. We want to empower all our employees to be good • Separate your personal social media sites and accounts from work-related ones. Avoid using Air New Zealand Q. I have an issue with my manager ambassadors for our brand, but be mindful of sites to distribute personal communications, and never and said so recently in my Facebook page. Was this wrong? what you post online as it could have unintended use official company images on personal social media. consequences. • Clearly show when posts or comments are your own A. Yes. You should discuss any issues or views, and not that of Air New Zealand’s, when you talk concerns you have about your job or Follow these general guidelines when using about work related matters. work environment with your manager social media – both inside and outside of using the normal processes, rather • Don’t disclose information about others, misuse than posting to social media sites. the Company: personal data or post photos without their knowledge and permission. Think before you post – Remember • Be mindful of copyrights, trademarks and intellectual Q. On my last tour of duty, I took this that whatever you share may be public property rights of others. Never post copyrighted great photo with a celebrity who was for an indefinite period of time (even material without the appropriate permissions (including flying with us. Can I post it on social if you attempt to delete it), and will be published music, movies or video content). media?

associated with you, your profile, and • Honour any confidentiality and non-disclosure A. No. Even though taking and posting Air New Zealand. requirements, even on personal sites. ‘selfies’ have become the norm, we • Never post information about legal matters, including must protect our customer’s privacy Be truthful, accurate, and respectful – corporate transactions or investigations. and safety as a priority. Avoid asking customers for autographs, photos, or Don’t make statements that are false, • For security reasons, never post details (including videos any favour that encroaches on their misleading or unsubstantiated. Respect or photos) of any secure or restricted area, such as personal privacy. And never take other people’s views, even if you disagree aircraft hangars or maintenance areas, runways, airline or post photos of our passengers, or make comments about them and always be polite and courteous. passenger areas, interiors of aircrafts cabins, cockpits, under carriage, landing gear and baggage holding areas. on social media, unless it is with permission and authorised by Use good judgement and common Corporate Communications. sense – Don’t post items that could reflect negatively on Air New Zealand, You are personally responsible or are legally protected (e.g. confidential Q. I saw a negative post on social and liable for anything you media about Air New Zealand. or private in nature). Avoid topics that Should I respond? could be inflammatory, or inappropriate, post online, whether speaking including personal work-related concerns personally or in an official A. No. As a general rule, avoid the temptation to respond directly to or issues. capacity for Air New Zealand. negative posts about the Company on social media unless you respond Do no harm – Don’t post material with approved messaging from considered to be illegal, abusive, Corporate Communications. Keep in mind that we have dedicated discriminatory, defamatory or offensive. teams tasked with responding to customer enquiries or complaints. When in doubt, contact Corporate Communications. POLICIES COVERED: SOCIAL MEDIA POLICY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 33 PROTECT OUR PEOPLE, PROPERTYAND INFORMATION

BACK TO CONTENTS PROTECT OUR PEOPLE, PROPERTY AND INFORMATION

Financial Integrity Q. I think my manager is claiming for Committing to Contracts Q. Where do I find out the details of my expenses that aren’t really business- Delegated Financial Authority? related. What should I do? We expect all Air New Zealanders to be good and Expenditure A. Refer to the Delegated Financial stewards of company funds and spend responsibly. A. You should speak to your HR Air New Zealand is committed to sustainable Authority Policy on Korunet. Our financial and accounting controls ensure we manager about your concerns. Alternatively, use the Speak Up procurement and supply chain decision-making. apply sound financial principles in our business reporting line if you feel it’s By managing our supply chain decisions centrally, Q. Can I put a preferred supplier transactions. Clear policies and strict guidelines are more appropriate. we will minimise our impact on the physical contract in place by myself? used in our financial planning, budgeting, monitoring environment, deliver optimal financial outcomes, and evaluation. We are all responsible for following A. No. All supplier contracts and and enhance our competitive advantage. We have our policies and legal, financial and accounting We will only spend company agreements are managed centrally. defined processes for interacting with suppliers, Contact Procurement for more regulations. Our managers have an extra duty to money where there is a negotiating supply contracts and making information. ensure that their teams manage expenditure within legitimate business need purchasing decisions. Legally binding contracts, budget and spend company money carefully. with agreed terms and conditions, are required (See Committing to Contracts and Expenditure and where the cost is worth Q. Why does Procurement need to before we can commit our resources. Without for more information). the benefit. We will base approve suppliers before we can these agreements, we are open to financial, order from them? When assessing value for money, consider: quality, our investment decisions commercial, tax and legal risk. service, reliability, sustainability, compliance with A. We have a set of criteria used for and business relationships The Delegated Financial Authority (DFA) our finance and procurement policies and any terms approving suppliers that takes into shows what level of authority you need before consideration cost, environmental and conditions. Make sound investment decisions on economic criteria from committing Air New Zealand to a contract or factors and purchasing power. capable of being validated and based on objective objective and complete due This helps us meet our sustainability expense. Everyone is expected to understand and economic criteria. goals, mitigate risk of conflicting diligence information. how the DFA rules apply to their role. supplier commitments, provide more cost-effective procurement and ensure the quality of goods What this means for you: and services. What this means for you: • Understand the financial management responsibilities, policies and processes relevant to your role. • Only commit to a contract or incur expenses where you are authorised and within your delegated limits. We will not commit to • Understand when you can and when you can’t commit • Use defined processes and approved suppliers when company funds. expenditure without sourcing and purchasing goods and services. • Strive to find the best value when spending company money. • Obtain DFA approval for every purchase, requisition or appropriate authorisation. • Only spend company funds on legitimate business needs. order you make. We will take into account • Keep expenditure within budget. • Ask Purchasing if you’re in doubt before ordering a social, ethical and • Ensure your decisions are sound, and based on product or service. objective information. environmental considerations • Run transparent tendering processes for suppliers in our procurement and and business relationships. supply chain decisions. • Report suspected misuse of company property or funds.

POLICIES COVERED: POLICIES COVERED: PROCUREMENT POLICY FINANCE AND ACCOUNTING POLICIES DELEGATED FINANCIAL AUTHORITY POLICY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 37 PROTECT OUR PEOPLE, PROPERTY AND INFORMATION We will respect people’s right to privacy and the confidentiality of their personal information and will only retain personal information that we need to operate effectively or to comply with the law.

What this means for you: What this means for you: Accurate and Complete • Record and report company information honestly, Protecting Privacy • Recognise when you are accessing or using personal Information, Records, accurately and objectively, with reasonable detail and and Confidentiality information and treat it as confidential. supporting documentation for all transactions. • Limit sharing, or access, to authorised people only, Reporting and Accounting • Make no false or misleading entries on (or Privacy is about how we collect, use, process who have a clear business need for that information. inappropriately alter) company books, records or and share personal information and how we • Keep personal information no longer than necessary Honest, complete and accurate recording and expense claims for any reason. respect the rights of our customers, employees to accomplish the legitimate purposes (legal, regulatory reporting of information is critical to protecting • Comply with the Company’s system of internal controls. or legitimate business need). and business partners with regards to their our credibility, reputation and meeting our legal • Be alert for unauthorised payments or invoices – information. The right to privacy is a human right. • Be aware of local privacy laws, especially when obligations. We are committed to ensuring our ensure that no undisclosed or unrecorded or ‘off transferring personal information outside of its country records are complete and accurately reflect the books’ amount, fund or asset is established or Personal Information is any piece of information of origin. transactions and events. This includes all forms maintained (see the Anti-money Laundering section that relates to an individual where the person can • Be objective when making written comments about for more information). of media (paper or electronic) and information, be identified, either directly or indirectly. Personal people, as all personal information may be disclosed. including financial, health, safety, personal or • Cooperate fully with Internal Audit, Group Finance information belongs to the individual and they Personal information, including your opinions, should and external auditors and provide them with accurate be relevant, appropriate, accurate and justifiable. regulatory. We will properly manage the life cycle have the right to know what information we hold information and unrestricted access to necessary • Take extra care when using electronic communications – of our records, and only retain them for the period about them, how we are using it, and that we are resources. ensure any sharing of personal information is done in handling it appropriately. of time necessary to meet our legal requirements • Report any concerns or irregularities in accounting, a secure and protected way. and business needs. auditing or internal controls. Privacy is also about regulatory compliance. As • If you believe personal information has been accidentally We ensure our financial statements are reviewed • Understand and follow our data retention standards for an international airline, we need to comply with or intentionally viewed, shared, altered, stolen or used in by independent auditors, and that we are creating, retaining and destroying company information. established personal information protection an unauthorised way contact [email protected]. completely open and transparent in our dealings Failure to keep accurate and complete records, falsifying guidelines, specifications and legislation Refer to the Privacy Policy for additional guidance on the with them as well as with our Internal Audit team. information or creating misleading information could everywhere we fly. handling of personal information and a description of constitute fraud, with civil and criminal liability for protected information. Air New Zealand and individuals involved.

Q. My manager asked me to record Q. I have just received by accident Q. I found a report on the photocopier unconfirmed sales in the quarterly an email with a file containing the that contains a lot of confidential report to meet our targets. But the salaries of several employees. records. I don’t think it’s right to sale will not be completed until Can I share it with other people leave this kind of information after the quarter ends. Should I do at work? lying around for all to see. What what they ask? should I do? A. No. You and your friends at work A. No. You must always record costs have no business reason to have A. You should return the report in and revenues in the correct time this information. Delete the email confidence to the owner if you know period. Reporting a sale that and inform the sender of the mistake. who it belongs to. Otherwise, put is not yet complete would be a Disclosing confidential and private it in a secure bin for destruction. misrepresentation and may amount information to other employees is Report your discovery and actions to fraud. Discuss it with your a breach of the Code. to your Privacy Officer. This breach manager, or use the Speak Up line needs to be recorded in the Privacy to report your concerns. Breaches Register. Whoever left POLICIES COVERED: POLICIES COVERED: the papers in the copier will be FINANCE & ACCOUNTING POLICIES PRIVACY POLICY reminded of their duty to protect RECORD RETENTION AND DESTRUCTION POLICY INFORMATION SECURITY POLICY employee and customer data. AUDIT INDEPENDENCE POLICY CONFIDENTIALITY POLICY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 39 PROTECT OUR PEOPLE, PROPERTY AND INFORMATION

What this means for you: • Protect your password Information Security Q. My manager told me when I travel • Classify information that you use for work – Don’t share your password with anyone or write with my laptop I should carry Information is one of our most valuable assets it down. it on the plane with me. Is this necessary? and we must safeguard our proprietary and – Never let other people access the internet using your internet account. confidential information at all times. We are A. Yes. When travelling with a responsible for determining whether the Air New Zealand Public – Don’t let your computer ‘remember’ your passwords. company laptop, you must carry it on the plane with you. This protects information is sensitive, who owns it and the Air New Zealand Information we share with • Protect information and data at all times the laptop and the confidential Public the public (which requires appropriate level of protection it requires. – Look after laptops, mobile devices and storage information contained on it from approval from our External Our security controls manage access to our devices when you are not in the office – never leave theft, loss, misuse or damage. Communications team). information and networks to prevent improper your laptop unattended, or in the car visible to others. disclosure. We limit access to the information – Store classified information correctly and dispose of it to those who have a legitimate business need, securely when it’s no longer needed. Q. I’ve given my password to our team administrator so they can process – Avoid leaving sensitive and confidential documents in following defined procedures. purchasing requisitions on my meeting rooms, on your desk (lock away if necessary), behalf. Is this ok? Air New Zealand Internal or on printers (use ‘secure printing’).

Air New Zealand Day-to-day information that – Never save sensitive or confidential information on A. No. Never share your password Internal we share with colleagues and unauthorised systems or storage devices. with anyone. And don’t allow others authorised third parties. – Lock your computer screen if you leave your computer to approve the use of company unattended and switch off your computer at the end funds or assets on your behalf, especially if they don’t have the of the day. correct level of authority themselves. – Report incidents, breaches or lost laptops or mobile Your nominee must go through a Air New Zealand Sensitive devices immediately to the IT Service Desk. formal application and approval Personal, confidential or process to gain their own designated • Think before you click Air New Zealand commercially sensitive authority (for transparency and audit Sensitive information that will only be – Be careful when opening attachments from tracking purposes). shared on a ‘need-to-know’ unknown addresses. basis to those authorised. – Only use authorised software and hardware. – Don’t click links which may take you to unsafe websites. Air New Zealand Restricted Air New Zealand We will secure and safeguard Restricted Critical information that could affect our Share Price. our confidential and sensitive information from improper disclosure to prevent harm to Air New Zealand, our stakeholders, customers or employees who have trusted us with their information. POLICIES COVERED: INFORMATION SECURITY POLICY INFORMATION CLASSIFICATION POLICY CONFIDENTIALITY POLICY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 41 PROTECT OUR PEOPLE, PROPERTY AND INFORMATION Our Code represents our commitment to do the right thing.

BACK TO CONTENTS PROTECT OUR PEOPLE, PROPERTY AND INFORMATION

We will protect and safeguard Q. A former employee of Air New Zealand asked me for copies of our brand, property, intellectual materials we worked on together. Also, I discovered they already have property and financial assets. a lot of printed and digital Air New Zealand material and data. What should I do?

A. Never give anyone outside the Company confidential information or What this means for you: IP. They have breached our Code by Protecting and taking information with them when • Comply with our Brand Guidelines. they left the Company, and there Respecting our Property • Never allow any third party to use our brand or could be further issues if they use or trademarks without first discussing it with Legal. reveal it to others. The obligation to We are all encouraged to be creative and secure confidential Air New Zealand • Protect all confidential, proprietary or other IP innovative. Our brand, designs, patents, information applies not only during information regardless of the method used (e.g. but after employment. Discuss the trademarks, copyrights, trade secrets and printed material, electronic files, email, and verbal situation with your manager and know-how — our intellectual property (‘IP’) — conversations), even after you leave Air New Zealand. report it to Security and Legal. They are valuable assets that we must safeguard. • Retain confidential or proprietary information or other IP will decide what action is needed to We must comply with applicable laws and in accordance with our Data Retention Policy, and only protect our information in this case. regulations that help us protect our intellectual share it with those who are authorised and have a business need for the information. property from theft or misuse — and in doing so, ensure it’s available to us for future • Use Confidentiality Agreements before disclosing confidential information to outside parties. innovation. We all have a duty to protect Air New Zealand’s confidential information. • Avoid disclosing any details of new products, designs, patents, trademarks or other confidential or IP in Other confidential business information public places, or with friends and family, or anyone not authorised to access it. that also comes under Intellectual Property includes: • Report any suspected misuse or theft of logos, trademarks or other Air New Zealand IP to Legal. • Sales, marketing and other • Report any activities that infringe on the IP of others. company databases • Gain appropriate permissions before using the • Marketing strategies and plans IP of others. • Report any lost or stolen confidential information or • Research and technical data other property immediately to Legal and Security. • Business ideas, processes, proposals Violations of IP laws can be costly. Discuss with your or strategies manager or Legal any questions or concerns about how • New product and/or package design to safeguard it. and development Q. I’m not sure whether a design idea • Software bought or developed by I’ve had might be worth something. Can I discuss it with our customers the Company to get their views? • Information used in trading activities including pricing, marketing and A. Initially, you should only discuss your idea with your team. Any customer strategies. idea, design, or new technique developed by you while working We must also respect the intellectual property for the Company is considered the rights of others. Never knowingly violate intellectual property of Air New another company’s intellectual property and Zealand and must be protected. If you want further guidance, always obtain the necessary licenses and discuss it with Legal. Air New Zealand is the official airline of Middle- permissions before copying, using POLICIES COVERED: CONFIDENTIALITY POLICY earth and marketing activity around the Hobbit has or distributing it. INVENTIONS, IDEAS AND DESIGNS POLICY benefited New Zealand’s tourism and economy.

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 45 TREAT PEOPLE FAIRLY AND WITH RESPECT

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 47 TREAT PEOPLE FAIRLY AND WITH RESPECT

Q. Who is responsible for delivering Q. I have a vacancy in my team that Diversity and Inclusion our commitment to having an Merit-based isn’t suitable for a single parent, as inclusive and diverse workforce? it involves a lot of travel. This is not We strive to create a working environment where Talent Acquisition about prejudice but practicality. Do I still have to interview single parent everyone feels respected and valued, and that A. We must all take responsibility for Our people are critical to our business. We are candidates out of courtesy? reflects the diversity and characteristics of treating people with professional committed to attracting, developing and advancing the communities in which we operate and the courtesy, dignity and respect. This means valuing them as the best people through a fair and merit-based A. You are obligated to interview customers we serve. We recognise and celebrate all candidates whose qualifications individuals as well as complying process, and ensuring the process is free from bias the importance of diversity in our workplace. We with specific laws and regulations meet the requirements of the and discrimination. We will screen all employees job – not on the basis of personal will not tolerate any form of discrimination, and where we operate. All employees are responsible for supporting and contractors before they are hired or engaged opinion. Making assumptions like we respect individuals and their human rights. this violates our principles and may our commitment to creating an to help protect our people, assets, intellectual We should all challenge discriminatory behaviour environment where everyone feels even be against the law. If we don’t property and products. We will ensure those we interview qualified candidates, when we see it. We want everyone to feel valued and respected. hire have the qualifications and the experience we may miss the opportunity empowered to raise any concerns. to appoint the best person for required for their roles. We adhere to all employment the job. At Air New Zealand, regulations regarding staff, contractors and other equal opportunity means equal complementary workforce (outsourced opportunity for everyone. What this means for you: workers, agents). • Act fairly and show respect towards others in all your dealings. Q. A colleague is recruiting a new team member. I’m concerned they • Actively seek, value and draw on the differing knowledge, What this means for you: may be discriminating against perspectives, experience and styles present in our global certain candidates. Should I • Complete full and proper pre-employment and community. challenge them? pre-engagement screenings as defined in • Be aware of cultural sensitivities when working with our procedures. others (employees or customers). A. You are right to raise your concern • Base your decisions about recruitment, selection, as we will not tolerate any form of • Understand your responsibilities under the law development and advancement of employees on discrimination. Urge your colleague regarding equal opportunity. merit – their qualifications, demonstrated skills, to discuss the selection criteria • Challenge discriminatory behaviour. and achievements. with HR. If there is no change then you should raise the issues with • Raise any concerns with your manager. • Comply with all applicable labour and employment laws. your manager. • Be inclusive in the language you use when • Seek advice if you have a concern – whether it concerns communicating. you, your direct reports or others. • Report any incidents that are inconsistent with • Report any breaches of law or this Code when you our commitment to equal opportunity, inclusion become aware of them, and cooperate with and diversity. We will treat people fairly, with company investigations. We will recruit, select dignity and will pursue equality • Never allow race, colour, religion, gender, age, country and develop our people of origin, sexual orientation, gender identity, marriage of opportunity and inclusion status, disability or any other characteristic protected on merit – irrespective of for all employees through by any applicable law to influence your judgement when age, race, colour, origin, it comes to the recruitment, selection, development or our employment policies and advancement of others. gender, religious beliefs or practices. We value diversity of • Expect others you work with (contractors, agents, joint sexual preference or other ventures) to act in a way that is consistent with our fair people and thought. treatment and equal opportunity standards. protected characteristic.

POLICIES COVERED: POLICIES COVERED: EQUALITY, DIVERSITY AND INCLUSION POLICY EQUALITY DIVERSITY AND INCLUSION POLICY

BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 49 TREAT PEOPLE FAIRLY AND WITH RESPECT

We will not accept any We will not tolerate child form of discrimination, labour and are committed to harassment or bullying. the elimination of all forms of forced and compulsory labour.

Q. I can see that one of my colleagues Preventing Bullying is being picked on constantly by Ethical Business other team members. I want to raise and Harassment this but I’m concerned it might be Practices of Suppliers my turn next. What should I do? We are all responsible for ensuring that We engage with suppliers who share our harassment and bullying doesn’t happen at commitment to sound, sustainable business Air New Zealand. Harassment and bullying can A. You should always challenge principles, and who operate in a safe and inappropriate or unacceptable take many forms and have serious repercussions. behaviour. Speak to your manager ethical manner. Harassment includes language or conduct that or HR. If you don’t feel comfortable We are committed to doing business may be derogatory, intimidating or offensive doing this, then use the Speak Up reporting line. with suppliers who, as a minimum: to others. Bullying and intimidating behaviour is repeated inappropriate behaviour that • Supply products that are manufactured in safe undermines someone’s right to respect at work. Q. My manager mimics and makes and healthy conditions jokes about a regular customer • Operate in an ethical manner We may initiate disciplinary or legal action that speaks with an unusual accent. against people who harass or bully others. I think the jokes and comments • Use voluntary workers (not indentured, forced are disrespectful and sets a bad or bonded labour of any kind), that are paid a This includes suppliers, customers and other example for the team. What should I visitors to our premises. do about it? proper wage under human conditions, are not discriminated against, exploited or subject to A. This behaviour is unacceptable. You any kind of abuse, and work in conditions which could talk to your manager about are humane What this means for you: your concerns, highlighting that this behaviour is inappropriate and • Do not use child labour. • Never be derogatory or abusive to or about others. not aligned with our commitments • Never behave in a way that is unwelcome, intimidating or to supporting diversity and We will enforce the completion, and review, of inclusion. You could also raise your offensive, including threats, bullying, inappropriate jokes inspection reports annually to ensure continued or actions of a sexual nature. concerns with your local Bullying & Harassment Contact Person, an HR compliance with these requirements. • Discourage others from engaging in this behaviour. Business Partner or report it through • Make sure your communications abide by our the Speak Up reporting line. Code no matter how informal you are being. What this means for you: • Take all harassment and bullying complaints seriously. Managers should immediately address behaviour or Q. I feel uncomfortable when my • Do your due diligence before engaging a supplier or conduct that may be offensive. manager asks me out for drinks or business partner on ethical conduct requirements. makes remarks of a sexual nature • Challenge any unethical behaviour or business practice • Report, and encourage others to report, incidents of when no one else is around. What when you see it. harassment, bullying or retaliation. should I do? • Don’t retaliate against anyone who makes a good-faith • Report any suspected issues of unethical business complaint of harassment or bullying, or who cooperates A. If you are not comfortable raising practices by suppliers to Legal or the Speak Up the issue with your boss, talk to a in an investigation of a complaint. reporting line immediately. Bullying & Harassment Contact Person or to HR. They will protect your confidentiality as far as possible while taking steps to stop the offensive behaviour. You could also use the Speak Up reporting line POLICIES COVERED: to report your concerns. POLICIES COVERED: WORKPLACE BULLYING AND HARASSMENT POLICY SUPPLIER CODE OF CONDUCT

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Anti-money Laundering Ensuring Continuous What this means for you: • If you become aware of an issue that may be considered Organised crime and terrorism are global Disclosure ‘material information’, immediately discuss it with a member of the Disclosure Committee. problems, with serious social, economic and Air New Zealand is committed to the timely political impacts for every country in the world, • Keep the material information confidential until adequate disclosure of all material information to its public disclosure is made. including New Zealand. Money laundering is the shareholders to promote investor confidence, and • If in doubt whether it is ‘material information’, don’t use of transactions by criminals, terrorists, or to meet our obligations as a listed company on the communicate it and contact Legal for guidance. others to conceal the illegal source of their funds. New Zealand and Australian Stock Exchanges under • Our Disclosure Committee manages the Company’s We are committed to the highest standards of their Listing Rules. Material information means any disclosure obligations and implements reporting anti-money laundering compliance to prevent information that a reasonable person would expect, processes, controls and guidelines for the release use of our products and services for money of information. if it were available to the general market, to have a laundering purposes or for financing of terrorism. material effect on Air New Zealand’s share price. Harsh penalties exist for breaches of the Listing Rules We will take all necessary steps to ensure that and other applicable laws which may result in personal exposure to regulatory penalties, company liability and trades in our shares take place in an efficient and What this means for you: disciplinary action. informed market. • Look for any suspicious transactions using cash payments or monetary instruments. ‘Material information’ normally includes • Detect, manage and mitigate the risk of money items such as: laundering and the financing of terrorism using defined • Revenue and earnings performance of processes in your area. We will comply with all Air New Zealand or its subsidiaries • Follow all procedures, policies and controls used to applicable domestic and detect and report money laundering or illegal • Shareholder issues, and company control financing activity. international laws and or ownership • Complete comprehensive customer due diligence to regulations, appropriate • Major projects involving commitment of verify their identity. standards and principles, significant capital expenditure • Report any suspicious activity to Legal immediately. • Actual or potential new routes, products, including all competition, acquisitions or major service changes anti-trust and anti-money • Actual or potential alliance negotiations laundering laws. and announcements • Any commercial agreements with other airlines or businesses • Bilateral and multilateral international air service agreements or related issues • Government, agency, or regional and local authority lobbying • Legal proceedings, industrial relations, negotiations and disputes • Safety, security and health – and incidents involving these

• Any other matter that is likely to impact the POLICIES COVERED: Company’s reputation. CONTINUOUS DISCLOSURE POLICY

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We will not tolerate any form of bribery, including improper offers of payments or gifts to or from employees.

Eliminating Bribery, Q. I am travelling overseas later this Q. A supplier told me about a new month and need to get a work visa Avoiding Insider Trading product in confidence. We can’t use Corruption and quickly. The person processing my the product at Air New Zealand, request at the embassy has said In most countries, it is illegal for people to profit but I think it has real potential and Improper Payments that they can speed up the process from insider trading. This involves trading the shares will go up fast. Can I buy if I pay a small fee in cash. Is this shares in the supplier’s company? ok? securities or manipulating share prices based The law prohibits bribery in every kind of on ‘inside information’ – information that is not A. No. You can’t buy shares in the commercial setting. We are committed to meeting A. No. This sounds like a facilitation publicly available that we may have as a result of supplier’s business until the the highest ethical standards in the way we do payment, which is a form of bribery working for Air New Zealand, and that is ‘material’ information you have is publicly and is illegal. If this payment is a available. Currently you have ‘inside business. Facilitation payments, or kickbacks, are standard or official fee – such as part or could have an impact on the value of those information’ which was given to examples of bribery and are illegal. Local ways of a publically available fast-track shares or securities if it was made public. These you in confidence and has not been of working are not an exception to these rules. service – then it is ok to proceed. rules apply regardless of how you acquire the publicly disclosed. However, even then you should Giving or receiving gifts or entertainment might consult Legal for advice first, as you inside information, whether you are aware of the also be bribery in certain circumstances, as many may be putting yourself and Air New sensitivity of the information, and continue even countries have stringent rules that prohibit giving Zealand at risk of legal action. after you stop working for Air New Zealand. Q. My friend is thinking about selling anything of value to public officials to influence some Air New Zealand shares in the next few days. I know we are due to their actions. Be aware that even charitable make an announcement that will donations can be seen as bribes if payments Q. A public health & safety inspector What this means for you: have a positive impact on our share has arrived at our base. As an are made to facilitate a process or secure a price. Is it ok if I drop hints to my act of good will, may I give them • Protect inside information from accidental disclosure. friend to wait to sell? commercial advantage. some Air New Zealand branded • Never spread false information or engage in activities to merchandise? manipulate the price of publicly listed securities. A. No. You should never leak information about Air New A. No. Never give anything of value to • While having ‘inside information’, you are prohibited from Zealand’s business which is not What this means for you: a government official without prior directly or indirectly: publicly available. Nor should you approval from Legal. Something that • Be cautious when giving or receiving gifts or – trading securities of Air New Zealand use inside information to influence is considered a normal business entertainment, especially when a public official is the investment decisions of others. courtesy in the commercial – trading securities of any other publicly involved (refer to the Gifts and Entertainment section marketplace can, in the government traded company for more information). marketplace, be construed as an – leaking, tipping off or otherwise passing inside Ensure that all gifts and entertainment are permitted attempt to improperly influence. • information to third parties. by local law. Giving anything of value, even small gifts, meals or other gratuities could • If you have questions or concerns about insider trading, Refuse to pay facilitation or other improper payments. • be perceived as a bribe intended to contact Legal for more guidance. • Never make, offer to make or authorise payment to a influence the inspector’s review of third party knowing that the payment will be offered the facility. Securities include shares, options, debt, bonds, notes and or given to secure an improper advantage, obtain or other investments whose value is determined by the price of retain business. these shares. Insider trading can result in severe penalties including criminal liability, fines, and imprisonment.

POLICIES COVERED: ANTI-BRIBERY & CORRUPTION POLICY POLICIES COVERED: GIFTS AND ENTERTAINMENT POLICY SECURITIES TRADING POLICY

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What this means for you: Q. I attended a sales meeting with Q. I will be attending an industry Competing Fairly other airlines, during the sales association meeting next month • Never exchange sensitive information with competitors. meeting I was asked what Air New and many of our competitors are We make independent business decisions that • Take care when dealing with competitors not to Zealand’s travel agency commission also planning to attend. Would it be are in our best commercial interests, compete participate in any arrangement that could be construed rates are likely to be for next year. okay for me to ask our competitors fairly, and comply with all applicable competition as anti-competitive collusion. Can I share this information? about their new routes or products? laws around the world. We believe in free • Never enter into anti-competitive agreements with A. No. This information is A. No. While industry association competition and strive to outdo our competitors competitors, such as price fixing, bid rigging, market allocation and agreements to restrict supply to commercially sensitive and meetings and conferences do serve through honest and fair business practices. another competitor. therefore cannot be shared an important role in promoting In our relationships with customers, suppliers with our competitors. If you did information sharing, setting industry • Never discuss costs, pricing or competitive bids with and competitors, we never pursue any unfair share this information, and other standards and discussing new competitors or agree on who will win a competitive bid. carriers independently matched developments, they also raise advantages or misrepresent facts about our • Unless you obtain prior approval from Legal, don’t: our commission rates, your serious competition law concerns. business. In addition, we avoid making false or conversation could be viewed As an attendee on behalf of the – engage in benchmarking or other information misleading statements about our competitors. or perceived as an attempt to Company, you should avoid any exchanges or activities with competitors – eliminate fair and open competition, discussion of routes, current We collect competitor information in legally use publicly available information instead which would violate competition or future pricing or statistical and other antitrust laws. appropriate and ethical ways. – begin any negotiations on mergers, acquisitions, information, or attempts to stabilise the industry or encourage price joint ventures or similar transactions, especially if uniformity. If you have any concerns, competitors are involved Q. During a recent sales visit, a contact Legal. – negotiate in joint activities with competitors to customer gave me a copy of my influence government action. competitor’s marketing strategy. • Never use trade associations or professional societies Should I have accepted the information? for contacts or communications with competitors that violate the law or company policy, such as discussions A. No. You must respect the about price or other sensitive information. intellectual property of others and • Never encourage customers, suppliers or former avoid any inappropriate or illegal employees of competitors to provide information that means of gathering information they should keep confidential. about competitors or customers. If you gain possession of Competition law violations can result in substantial fines competitor information that is for both Air New Zealand and those who violate it. marked confidential, or is believed to be confidential, consult with Legal immediately.

POLICIES COVERED: COMPETITION LAW POLICY

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Living Abiding by our Code our Code

Because our Code covers so much detail and Agreement to abide by the Code Consequences of non-compliance different situations, keeping everything in mind may seem daunting. But in any situation you’re All Air New Zealanders must acknowledge that they’ve Our Code represents our commitment to do the right read, understood and agree to abide by the Code. We thing, including respecting the rights of others. As an not sure of, just remember these three key things are required to do this when we are hired and to renew Air New Zealander, you agree to uphold this commitment. and you’ll be well on your way to living our Code this commitment annually. If you don’t, you could put yourself, your colleagues and Air New Zealand at risk. of Business Conduct and Ethics. Please note that the Code is not a contract of employment, and Air New Zealand may interpret, Our Just Culture philosophy of addressing risk focuses modify or rescind some or all of the Code provisions, as on open reporting, process improvement and prevention Know our Principles Decide what’s RIGHT Speak Up well as related policies and standards, at any time. measures, rather than on blame or punitive action. However, reckless behaviour is a failure to follow this Code and is misconduct, which could result in disciplinary Make sure you understand our Ask yourself: Whatever your concern, don’t wait action and even dismissal. Breaches of law may also result Business Principles, legal and until it becomes a serious problem. in civil or criminal penalties. • Is this aligned with our Business company requirements that apply to You can always: Principles and ethical behaviour? your job – and always follow them. • Are you acting with integrity? • Talk it through with your manager • Who is this good for? • Get in touch with your HR Business Partner or the • Who could be harmed? Risk & Compliance team • What is the truth? • Or use the Speak Up line to • Is this the right thing to do? raise a concern

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