1. Trust and Credibility

The success of our business is dependent on the trust and confidence we earn from our employees, customers and shareholders. We gain credibility by adhering to our commitments, displaying honesty and integrity and reaching company goals solely through honorable conduct.When considering any action, it is wise to ask:

When considering any action, it is wise to ask:

Will this build trust and credibility for JAL?

• Will it help create a working environment in which JAL can succeed over the long term?

• Is the commitment I am making one I can follow through with? 

2. Respect for the Individual

JAL is committed to creating such an environment where people are treated with dignity and respect because it brings out the full potential in each of us, which, in turn, contributes directly to our business success not letting anyone’s talents go to waste.

JAL is an equal employment/affirmative action employer and is committed to providing a workplace that is free of discrimination of all types from abusive, offensive or harassing behavior.

Any employee who feels harassed or discriminated against should report the incident to his or her manager or to Human Resources.

3. A Culture of Open and Honest Communication

At JAL everyone is comfortable to speak his or her mind, particularly with respect to ethical concerns.

Managers have a responsibility to create an open and supportive environment where employees feel comfortable raising such questions.

We all benefit tremendously when employees exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right times.

JAL will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, the company will take appropriate action.

We will not tolerate retaliation against employees who raise genuine ethics concerns in good faith.

4. Set Tone at the Top

Management has the added responsibility for demonstrating, through their actions, the importance of this Code.

In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Again, ultimately, our actions are what matters.

To make our Code work, managers must be responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate steps to deal with such issues.

Managers should not consider employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication.

At JAL, the ethics dialogue to become a natural part of daily work.

5. Uphold the Law

JAL’s commitment to integrity begins with complying with laws, rules and regulations where we do business.

Further, each of us must have an understanding of the company policies, laws, rules and regulations that apply to our specific roles.

If we are unsure of whether a contemplated action is permitted by law or JAL policy, we should seek the advice from the resource expert.

We are responsible for preventing violations of law and for speaking up if we see possible violations.

6. Competition

JAL is dedicated to ethical, fair and vigorous competition.

We will market JAL services based on their merit, superior quality, applicability and competitive pricing.

We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors.

We will not offer or solicit improper payments or gratuities in connection with the purchase of products or services for JAL or the sales of its services, nor will we engage or assist in unlawful boycotts of particular customers.

7. Proprietary Information

It is important that we respect the propriety rights of others.

JAL will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information.

We will not engage in the unauthorized use, copying, distribution or alteration of software or other intellectual property.

 8. Selective Disclosure

We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any JAL material, non- public information, its securities, business operations, plans, financial condition, results of operations or any development plan.

We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material, not for public information.

9. Health and Safety

JAL is dedicated to maintaining a healthy environment.

A safety manual has been designed to educate employees and business partners alike on safety in the workplace.

10. Conflicts of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs.

At times, we may be faced with situations where the business actions we take on behalf of JAL may conflict with our own personal or family interests because of the course of action that is best for us personally may not also be the best course of action for JAL.

We owe a duty to JAL to advance its legitimate interests when the opportunity to do so arises. We must never use JAL property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with JAL

Some of the conflict of interest:

• Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier or contractor, regardless of the nature of the employment, while you are employed with JAL
• Hiring or supervising family members or closely related persons.
• Serving as a board member for an outside commercial company or organization.
• Owning or having a substantial interest in a competitor, supplier or contractor.
• Having a personal interest, financial interest or potential gain in any JAL transaction.
• Placing company business with a firm owned or controlled by a JAL employee or his or her family.
• Accepting gifts, discounts, favors or services from a customer/potential customer, competitor or supplier

11. Gifts, Gratuities and Business Courtesies

JAL is committed to competing solely on a merit of our services.

We should avoid any actions that create a perception that favorable treatment of outside entities by JAL was sought, received or given in exchange for personal business courtesies.

Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom JAL does or may do business.

We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or polices of JAL or customers, or would cause embarrassment or reflect negatively on JAL’s reputation.

 12. Accepting Business Courtesies

Most business courtesies offered to us in the course of our employment are offered because of our positions at JAL.

We should not feel any entitlement to accept and keep a business courtesy.

Although we may not use our position at JAL to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies that promote successful working relationships and good will with the firms that JAL maintains or may establish a business relationship with.

Employees who award contracts or who can influence the allocation of business, who create specifications that result in the placement of business or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect the company’s reputation for impartiality and fair dealing.

The prudent course is to refuse a courtesy from a supplier when JAL is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain JAL business.

 13. Gifts

Employees may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of the marketplace, including:

• Flowers, fruit baskets and other modest presents that commemorate a special occasion.
• Gifts of nominal value, such as calendars, pens, mugs, caps and t-shirts (or other novelty, advertising or promotional items).

Generally, employees may not accept compensation, honoraria or money of any amount from entities with whom JAL does or may do business.

Tangible gifts that have a market value greater than SR 100 may not be accepted unless approval is obtained from management.

14. Accurate Public Disclosures

We will make certain that all disclosures made in financial reports and public documents are full, fair, accurate, timely and understandable.

This obligation applies to all employees, including all financial executives, with any responsibility for the preparation for such reports, including drafting, reviewing and signing or certifying the information contained therein.

No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records.

Employees should inform Top Management and the HR department if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.

15. Corporate Recordkeeping

We create, retain and dispose of our company records as part of our normal course of business in compliance with all JAL policies and guidelines, as well as all regulatory and legal requirements.

All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with JAL’s and other applicable accounting principles.

We must not improperly influence, manipulate or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of JAL books, records, processes or internal controls.

16. Accountability

Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if we are uncertain about company policy.

If we are concerned whether the standards are being met or are aware of violations of the Code, we must contact the HR department.

JAL takes seriously the standards set forth in the Code, and violations are cause for disciplinary action up to and including termination of employment.

17. Confidential and Proprietary Information

Integral to JAL’s business success is our protection of confidential company information, as well as nonpublic information entrusted to us by employees, customers, and other business partners.

Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses or nonpublic information about other companies, including current or potential supplier and vendors.

We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization.

18. Use of Company Resources

Company resources, including time, material, equipment, and information, are provided for company business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause a disruption to the workplace.

Employees and those who represent JAL are trusted to behave responsibly and use good judgment to conserve company resources.

Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.

In order to protect the interests of the JAL network and our fellow employees, JAL reserves the right to monitor or review all data and information contained on an employee’s company-issued computer or electronic device, the use of the Internet or JAL’s intranet.

We will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.