Code of Business Conduct

  1. Why this Code?

    First thing about ethics – we don’t break the law!

    But ethics is also about how we behave towards each other and the outside world.

    At AirAsia, we obey all applicable laws and regulations, both in letter and in spirit. We treat all stakeholders – our shareholders, guests, suppliers, employees and the community around us – with respect.

    We believe all our employees, directors, agents and representatives must share and pursue the same beliefs. We can’t be part of AirAsia if we are not prepared to follow the same standards, or if we breach any of these conditions. We have specific policies with more details in the respective areas. Please check them up.

    What’s important then? These are important:

    • That we do our business fairly, impartially, ethically, and with the utmost regard to safety.
    • That we obey all applicable laws and regulations.
    • That integrity be the basis of all our relationships whether with guests, suppliers, communities and with each other.
    • That we respect the environment and are aware of, and minimise our impact on it.
    • That we don’t do anything that may raise questions about AirAsia’s honesty, impartiality, reputation or ability to conduct its business.
    • And that we don’t get other parties to carry out any tasks prohibited under AirAsia’s policies and practices and Terms & Conditions of employment.
  2. What is important to us?
    1. Creating a positive working environment

      We create a, diverse, positive, respectful and fun working environment for people of all backgrounds. We promote and recognise our people based on talent and performance. We work hard and create a common vision and sense of purpose amongst all fellow employees of AirAsia.

      We commit to giving equal employment opportunities by creating an environment free from any discrimination, whether due to colour, religion, race, gender, sexual orientation, nationality, marital status, ancestry, socio-economic status or physical disabilities. We won’t accept bullying, harassment or any other behaviour that can be seen as degrading and threatening. We’ll focus on what brings people together rather than on what keeps them apart.

  3. The environment inside and outside
    1. Health, safety, nature and the environment

      Given the nature of our business, we create an extremely high level of safety, satisfaction and good health for our guests, ourselves, and everyone around us. We minimise environmental damage by developing, promoting and using environmentally-friendly technology and practices.

    2. Keeping a drug-free, violence-free workplace

      No drugs or any drug-related activities are allowed in AirAsia. Keep our work-place drug-free! No violence either – we sort out issues and disagreement in a civil manner using proper channels and with respect for all others around us.

  4. How we work
    1. How we ensure safety in our operations and in everything we do

      We write clear and comprehensive safety policies and procedures, and we adhere to them strictly. We continually look for opportunities to improve, keep a lookout for possible safety failings and violations, and report all such instances through the established channels. We will not do anything that will compromise safety in AirAsia.

    2. How we use AirAsia’s assets, properties, time, information and other resources

      We make proper and efficient use of these by following procedures and guidelines to prevent wastage, loss, and theft, unsafe or unauthorised use. We won’t create unnecessary added costs and disruptions to AirAsia’s business or cause any obstructions or interference to our actual or potential ability to do business.

      AirAsia’s property and assets, e.g. aircraft, buildings and equipment, and IT resources – must be managed and safeguarded well. We will refrain from utilising AirAsia property and assets for personal use. We follow all security requirements on access to and use of AirAsia’s aircraft, facilities and assets.

      When traveling, we minimise traveling expenses by following all requirements and guidelines. We use common sense and reasonable judgement to ensure AirAsia’s goals are met with minimum costs.

      When using AirAsia’s communication systems, we keep personal use short and only when necessary. We will make best use of technology that allows us maximum benefits for minimum costs. We won’t use them to do anything illegal, immoral, questionable or embarrassing to AirAsia; or use them in support of any political activities or outside third parties, unless approved.

      As technology changes rapidly, something totally new and unexpected may emerge and become widespread in use (such as some aspects of social media or new devices or new ways of using technology). Sometimes, policies and guidelines may not be able to keep up. In such cases, if you need guidance about what to do, remember the core of our Code of Conduct – break no laws, break no part of this Code, keep the interest of the company utmost, treat others as you want to be treated and use your best judgement and get advice from your bosses or the right people if in doubt.

    3. How we exercise expertise and authority

      We have policies and rules on who can make what decisions. We may only represent AirAsia to other parties if we have the authority to do so – and when we do, we keep within that authority at all times.

    4. How we relate with guests, suppliers, competitors and public authorities

      We treat our guests with respect and understanding, and protect their personal information unless they agree for their personal information to be shared. We treat suppliers impartially and justly. Selection of suppliers must follow established guidelines and rules.

      We meet public authorities in an appropriate and open manner. Information meant for the public about the company shall only be supplied by the person responsible for or approved to make such communications.

    5. How we compete

      We compete based on superior value propositions – by offering products and services at great prices and quality, and through superior execution of our business models and strategies. We treat our competitors honestly and professionally. We compete fairly and openly at all levels, and we compete hard!

    6. How we handle issues of corruption and bribery

      We don’t offer or accept illegal or inappropriate gifts or money or other things of value to get business or personal advantage to ourselves or others. And we don’t use middlemen to do what we know either is a corrupt practice, or something that could be interpreted as one.

      We don’t offer or accept illegal or inappropriate gifts or money or other things of value to get business or gain advantage for the company, ourselves or others. And we don’t use middlemen to do what we know either is a corrupt practice, or something that could be interpreted as one. We are strictly prohibited from offering to pay, paying, promising to pay, or authorising the payment of money or anything of value to anyone in order to influence any act or decision or to secure any other improper advantage in order to obtain or retain business.

    7. How we deal with gifts and business courtesies

      We are careful in offering or accepting gifts and business ‘courtesies’. If we think such a gift is meant to influence business decisions, we won’t take it.

    8. Money laundering is illegal and dangerous

      Money laundering is when people use legal means to convert illegal money into legal money. We must prevent money laundering in AirAsia. It is illegal, dangerous and could have a very serious impact on AirAsia, its directors and officers as well as negative repercussions far beyond AirAsia. We must also prevent AirAsia from being used by others for this purpose.

    9. How we relate our own private interests and actions to AirAsia’s

      When we are working with AirAsia, we won’t hold another position or work for others during AirAsia working hours without the written approval from the Company.

      So long as a person is in the employment of AirAsia and the employee is aware that AirAsia is entering into a transaction with a person or entity whom the employee has an interest in, the employee shall immediately declare his/her interest and shall not participate in any deliberations or negotiations on the said transaction.

    10. How we handle duty, positions and ownership of external businesses

      Whatever we do outside of work must not affect our working relationship with AirAsia, or conflict with AirAsia’s business interests. Examples of such work that may affect our working relationship with AirAsia are board duties, consultancy for or ownership of guests’, suppliers’, joint-venture partners’ or competitors’ businesses. It also includes duties and position of a scope or nature that can affect our employment relationship with AirAsia. And this also applies to other jobs or attachments that may give an appearance of conflict of interest.

    11. What about political activity?

      Political activities are okay – but only if done outside of AirAsia, and in our own time and not in the capacity of an AirAsia staff. AirAsia does not give support to political parties, either through direct financial support or paid working time. And you shall not let your involvement in such political activities create issues or embarrassment to AirAsia.

    12. Harassment and intimidation are unacceptable and wrong

      Harassment and intimidation (such as verbal and physical abuse, racist or sexist remarks, unwelcome sexual advances or inappropriate sexual contact, sexually-oriented gestures, pictures, jokes, remarks) are ugly and wrong and often make the workplace a very unpleasant place to be in. Basically any conduct that is unwelcome or unreciprocated by the other person could be deemed as harassment and intimidation. We won’t be part of it, and will not tolerate it.

  5. Conflict of interest
    1. Loyalty, impartiality and conflict of interest

      We have the right to lead a private life but when at work, we’ll be open and loyal to AirAsia. We won’t do anything that conflicts with or appears to conflict with AirAsia’s interests, or be directly or indirectly involved in any activity which may interfere with our objectivity in carrying out our AirAsia duties.

      Conflict of interest could involve any parties that have a relationship with AirAsia or could have such a relationship (such as guests, suppliers, contractors, present or prospective employees, competitors or outside business interest). We won’t be influenced by personal and family interests at all.

      We’ll use our judgement to decide on what is, or could be, a conflict of interest. We are smart enough and wise enough to do that. In our course of work, we frequently have to exercise judgement on even more difficult matters.

      Basic rules – prompt and full disclosures of everything, AND ASK FOR HELP IF NOT SURE!

  6. Confidentiality and disclosure of information
    1. Maintain confidentiality

      Our job in AirAsia gives us access to a lot of information about our guests, our operations and our business. All such information shall be treated as confidential unless they have become publicly known. We will use the information only for the purposes of carrying out our work, and for no other purpose. Unless authorised – we won’t reveal trade secrets, customer information and secrets or confidential operations, processes, finances to any unauthorised party.

      We won’t use or try to use any of the information in a way likely to hurt or cause loss, directly or indirectly to AirAsia, or its shareholders. We won’t share sensitive AirAsia information with others, not even with our family members. And we’ll be careful not to accidentally reveal such information, such as discussing the matters in public, or over the phone and computer.

      This requirement extends even after we have left AirAsia, as long as the information is deemed sensitive and confidential, unless the information has become publicly known. This duty of confidentiality is required both by law and by our employment contract.

    2. Privacy and protection of employees, information and data

      If we have access to such data or information, or even if we accidentally come across it – we won’t share it with anybody, whether inside or outside of AirAsia, unless we have been given authorisation to do so, such as via written approval from the Company, or through requirements by rule, laws, court order.

      We’ll be careful and follow all laws and regulations, when processing information that might be sensitive, whether the information is about employees or guests or others. We only process data limited to what we need for operational purposes, efficient customer care, relevant commercial activities and proper administration of human resources.

    3. Intellectual property

      AirAsia’s intellectual property – patents, trademarks, know-how, methods, concepts, and ideas – must be protected and administered in the best interest of AirAsia. We also respect the intellectual properties of others. Unless required by law or public authority, we won’t share any of these with unauthorised parties.

    4. Information that may affect our stock price

      Parts of the AirAsia Group may be publicly listed, subject to strict rules on handling information that may affect our share price. We must prevent access by unauthorised persons or disclosure to them – about any information regarding AirAsia that can affect the share price, before the information has been received by the stock exchange and made available through the stock exchange’s information system, or before the information ceases to be sensitive.

      We won’t trade any inside information for financial gain. If we are in doubt as to whether we have sensitive information or how we should act, we’ll seek advice from the legal and compliance function.

      If we have or received information about AirAsia that may affect the share price, we won’t trade in the financial instrument/share before the information has been made public or ceases to be sensitive. We won’t provide such information to anyone, directly or indirectly, except those who have a legitimate need for the information in order to perform their duties on behalf of AirAsia.

      In this context, the deciding factor is how a normal investor would have reacted to this information if it had been included in that investor’s decision making.

    5. Information, communication and contact with the media

      If it is our job and we are authorised to do so – we must make sure whatever information about AirAsia we make publicly available is reliable, correct and keeps to high professional and ethical standards. We won’t answer questions from, or make comments to, the media (even if it’s our personal opinion, or it’s “off the record”, or even just to clarify some points).

      We’ll let the right people e.g. Corporate Communications, Group CEO, Country CEO or CFO handle it. Divert all questions to them. On their part, they have a special responsibility to do this within established guidelines and satisfy the regulations and practices applicable to publicly listed companies.

    6. Disclosure of information

      AirAsia’s reporting shall in all material respects, comply with applicable laws and regulations; and be full, fair, accurate, timely and easily understood.

      If we are involved in AirAsia’s disclosure process we must be familiar and comply with AirAsia’s disclosure controls and procedures and internal controls over financial reporting, to the extent relevant to our responsibility, so that AirAsia’s public reports and documents filed with the relevant authorities and other public communications comply in all material respects with applicable laws and regulations.

      We must also prevent access to such information and/or unauthorised disclosure before it has been received by the stock exchange and released by them (or before the information ceases to become sensitive).

  7. Good practices and controls
    1. Accounting systems and processes

      AirAsia’s accounting shall ensure that all transactions are correctly reported in accordance with applicable national laws and good accounting practices. The annual accounts and interim accounts shall be in accordance with the law, International Financial Reporting Standards (IFRS) and Generally Accepted Accounting Principles (GAAP).

    2. Internal control

      We have good internal controls to ensure that we meet our goals and strategies. These controls must be efficient and carry acceptable levels of risks. Assets, tangible or otherwise, are safeguarded and used productively. We have an obligation to ensure financial information is correct and timely and is in compliance with laws, regulations and guidelines.

  8. Duty and declaration
    1. Reporting

      Apart from asking (our bosses, the Legal Department or People Department) when we are not sure, we also have a duty to report to them, to Internal Audit or to the Regional Fraud and Investigation team; or we can write an email to – anything that we see as a breach against this code. Not reporting it when we should is by itself a breach of this code. Our report will be treated confidentially, and there won’t be any repercussions against us if our report is made in good faith.

    2. Violation statement

      This code sets out minimum acceptable standards. But it obviously can’t cover each and every instance or example. We must use our good judgement at all times. Action may be taken against us if we breach this code.

      This code complements our existing Terms & Conditions of service, as well as all Policies & Procedures. This Code, or parts of it, may be changed from time to meet AirAsia’s needs or address changing conditions.