CODE OF BUSINESS CONDUCT AND ETHICS. FRONTIER AIRLINES, INC. Adopted May 27, 2004

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1 1. Introduction CODE OF BUSINESS CONDUCT AND ETHICS FRONTIER AIRLINES, INC. Adopted May 27, 2004 The Board of Directors adopted this Code of Business Conduct ( Code ) to establish basic legal and ethical standards that all of us must operate under to maintain the public trust and confidence in Frontier Airlines. Frontier has developed an outstanding reputation in the aviation, business, and consumer markets by maintaining the highest standards of ethical behavior and integrity. Maintaining this reputation is very important to the Board of Directors and management. Our commitment to the highest level of ethical conduct should be reflected in all of our activities including our relationships with employees, customers, suppliers, competitors, our shareholders, the government, and the public. All employees, officers and directors are expected to exercise good judgment, conduct themselves according to the language and spirit of this Code, and comply with all applicable policies and procedures. The Code establishes guidelines for conduct in some of the general areas that pose ethical concerns, but cannot and does not cover every issue that may arise. The Frontier Employee Manual, Frontier s intranet site, and your applicable operations manuals, address specific issues and actions in more detail. This Code, together with our corporate policies and procedures, applicable laws and regulations, and most important, your common sense and good judgment, form the basis for implementing the following general principles. We will be honest, fair, and maintain the highest standards of business conduct in all Frontier business dealings. We will act honestly and ethically in the performance of our duties at Frontier. We will avoid actual or apparent conflicts of interest between personal and professional relationships. We will provide full, fair, accurate, timely and understandable disclosure in reports and documents we file with, or submit to, the SEC and in our other public communications. We will comply with the rules and regulations of federal, state and local governments and other private and public regulatory agencies affecting the conduct of our business and our financial reporting, conduct our business according to the highest standards of corporate citizenship, and expect the same from those with whom we do business. We will act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing our independent judgment to be subordinated.

2 We will share knowledge and maintain our skills relevant to carrying out our respective duties within Frontier. We will promote and sustain a work environment that fosters mutual respect, openness and individual integrity, and proactively promote ethical behavior in the work environment and community. We will maintain the confidentiality of Frontier information and the confidential information of our customers and vendors, except when we are authorized or legally obligated to disclose the information. We will provide a high quality, friendly, safe experience for our passengers. We will achieve responsible use of and control over our assets and resources. We will each promptly bring to the attention of the Chief Executive Officer any information concerning (a) significant deficiencies in the design or operation of internal controls which could adversely affect Frontier s ability to record, process, summarize and report financial data or (b) any fraud, whether or not material, that involves management or other employees who have a significant role in Frontier s financial reporting, disclosures or internal controls. Frontier requires that each employee, officer and director make a personal commitment to the highest ethical standards and the exercise of proper judgment in all aspects of Frontier s operations. Part of your job and ethical responsibility is to help enforce these standards. You should be alert to possible and actual violations and report them as described in Reporting Violations of the Code below. If you have any questions concerning the Code or if you are unsure about the appropriateness of an event or action, you may contact the Human Resources Department, the General Counsel s Office, or the hotline number included in Reporting Violations of the Code below. 2. Compliance with Laws, Rules and Regulations We are strongly committed to conducting our business affairs with honesty and integrity and in full compliance with all applicable laws, rules and regulations. Frontier's operations are subject to a variety laws, rules, and regulations of federal, state and local governments and other private and public regulatory agencies. No employee, officer or director will commit an illegal or unethical act in the conduct of Frontier business, or instruct others to do so, for any reason. This policy goes beyond mere compliance with the letter of the law. Employees, officers and directors also must comply with the spirit of the law. You must comply with all applicable laws, rules and regulations, as well as Frontier s policies and procedures. Part of this responsibility includes acquiring sufficient knowledge of the legal requirements relating to your duties to enable you to recognize 2

3 potential problems and to seek advice from the General Counsel s Office or the Aviation Safety and Security Department where appropriate. If you believe that any practice raises questions as to compliance with this Code or applicable law, rule or regulation or if you otherwise have questions regarding any law, rule or regulation, please contact the General Counsel s Office or the Nominating and Corporate Governance Committee of the Board of Directors (the Governance Committee ). 3. Disclosure and Company Records Frontier s policy is to provide full, fair, accurate, timely and understandable disclosure in its reports and documents filed with or submitted to the Securities and Exchange Commission (the SEC ) or in other public communications. All information transmitted, both within and outside Frontier, must be honest and well founded. Frontier will not accept or tolerate misrepresentations or shading of information to create a misleading business picture. Frontier has established a Disclosure Committee consisting of senior management to assist in monitoring disclosures of a financial nature. Frontier has also established disclosure controls and accounting controls for financial reporting to provide reasonable assurance regarding the reliability of our financial reporting and the preparation of our financial statements for external purposes in accordance with generally accepted accounting principles. Employees, officers and directors are responsible for the reports and records they prepare, information they provide others, and the information they provide for computer systems. All Frontier accounts, financial reports, research reports, marketing information, sales reports, tax returns, expense accounts, time sheets, claims and any other Frontier documents, including those submitted to governmental agencies, must be accurate. All entries on Frontier s books and records must represent, and not conceal, the true nature of each transaction. The intentional falsification of records, hard or electronic copy, is always unethical and generally illegal. Employees, officers and directors must never withhold or fail to communicate information that should be brought to the attention of any level of management. Memoranda, letters, computer correspondence and notes should reflect these same high standards. Competitive bids and bid evaluations are also subject to these criteria. The integrity and completeness of record-keeping is not only Frontier s internal policy, it is required by the laws of both the United States and the foreign jurisdictions in which Frontier operates. Frontier must keep books, records, and accounts that accurately and fairly reflect its transactions and maintain an effective system of internal controls. The improper alteration, destruction, concealment or falsification of records or documents is strictly prohibited and may result in criminal penalties. While these requirements are especially applicable to the CEO, CFO and members of the Accounting Department, you are each responsible for complying with Frontier s disclosure controls, procedures, and internal controls for financial reporting. If you have any questions concerning Frontier s disclosure controls, procedures, and internal 3

4 accounting controls, you may contact the Internal Audit Department or the General Counsel s Office. If you have concerns regarding accounting or auditing matters that you believe to be questionable, you may submit your concerns (confidentially and anonymously, if you wish) by following the instructions in Reporting Violations of the Code below. 4. Conflicts of Interest All employees, officers and directors must avoid any activity, investment, interest, or association that compromises (or even appears to compromise) the independent exercise of judgment and the performance of work in the best interest of Frontier, its affiliates, shareholders, customers and the public. A conflict of interest exists where a person or entity s interests interfere in any way, or even appears to interfere, with Frontier s interests or benefits. While it is impossible to describe every situation in which a conflict of interest may arise, some examples of potential conflicts of interest include: Outside employment in any capacity, for a competitor, customer, contractor or supplier while employed by Frontier. Any outside employment or business activities must not conflict with, or even appear to conflict with, the employee's ability to properly perform work for Frontier. Our policy on outside employment is found in the Frontier Employee Handbook. Accepting gifts of more than modest value or receiving payments or other benefits as a result of your position with Frontier from a competitor, customer, contractor or supplier. If you receive or are offered a gift or gratuity of more than nominal value, you should politely refuse or return the gift or gratuity with an explanation of Frontier s policy, and notify your supervisor or manager. Regardless of value, you should decline any item offered with the intent to improperly influence the performance of your duties for Frontier. Having a direct or indirect interest in transactions involving Frontier, its customers or suppliers (not including routine investments in publicly traded companies). Receiving a loan or guarantee of an obligation as a result of your position with Frontier. Directing business to a supplier or contractor owned or managed by, or which employs, a relative or friend. Additionally, you must not exploit for your own personal gain any business opportunities that are discovered through the use of Frontier s property, information, or your position at Frontier unless the opportunity is disclosed fully in writing to Frontier s Board of Directors and the Board of Directors declines to pursue the opportunity. 4

5 Situations involving conflicts of interest may not always be obvious or easy to resolve. Ultimately, however, it is your responsibility to avoid any situation that would even appear to be a conflict of interest or to be improper. We encourage you to discuss any potential conflicts of interest with the General Counsel s Office. In order to avoid conflicts of interest, you must disclose any material transaction or relationship that reasonably could be expected to give rise to a conflict of interest to the General Counsel s Office. You must receive the Audit Committee s written approval before you enter into any material financial transaction or relationship that may give rise to an actual or potential conflict of interest. 5. Trading on Inside Information Using non-public information to trade in securities, or providing a family member, friend or any other person with a tip, is illegal. All non-public information should be considered inside information and should never be used for personal gain. You are required to familiarize yourself and comply with Frontier s policy against insider trading, found in the Frontier Employee Handbook. You may contact the General Counsel s Office with any questions about your ability to buy or sell securities. 6. Confidentiality Frontier believes that each employee, officer, and director has the responsibility and duty to not disclose to any third party any information that is proprietary or confidential, except where the disclosure is required or mandated by law or is otherwise properly authorized. You must be careful not to disclose non-public information to unauthorized persons, and must exercise care to protect the confidentiality of information received from another party. If you are uncertain as to whether information may be disclosed, you should discuss it with your supervisor or manager or seek advice from the General Counsel s Office. Proprietary information includes all non-public information that might be useful to competitors or that could be harmful to Frontier or its customers if disclosed. You must also protect all intellectual property like trade secrets, patents, trademarks and copyrights, as well as business, research and new market plans, objectives and strategies, records, databases, salary and benefits data, employee medical information, customer, employee and suppliers lists and any unpublished financial or pricing information. Additionally, we respect the property rights of other companies and their proprietary information and you must observe these rights. Frontier s policies regarding confidentiality are also found in the Frontier Employee Handbook. 7. Employment Matters Discrimination and Harassment. Frontier encourages a creative, culturally diverse and supportive work environment, and will not tolerate discrimination or harassment. Frontier s policies regarding discrimination and harassment, as well as procedures for reporting violations of these policies, are found in the Frontier Employee Handbook. 5

6 Competition and Fair Dealing. You should endeavor to respect the rights of, and deal fairly with, Frontier s customers, suppliers and competitors. You should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other intentional unfair-dealing practice, including misappropriation of the proprietary or trade secret information of others. Workplace Health and Safety. Frontier strives to provide a safe and healthy work environment. Our policies regarding security, health and safety, and drug and alcohol abuse are found in the Frontier Employee Handbook and in your applicable operations manual. Public Communications. Frontier has specific policies regarding who can communicate information to the press, the financial analyst community and others who are not employees or members of the Board of Directors. For more information, see the Media Contacts/Official Statements on Behalf of the Company section in the Frontier Employee Handbook. 8. Protection and Proper Use of Frontier s Assets Protecting Frontier s assets against loss, theft or other misuse is the responsibility of every employee, officer and director. You are responsible for the proper use of Frontier s assets and must safeguard these assets against loss, damage, misuse or theft. Loss, theft and misuse of Frontier s assets can directly impact our profitability. Any suspected loss, misuse or theft should be reported to your supervisor, manager, Human Resources, Internal Audit, or the General Counsel s Office. Frontier provides equipment, vehicles and supplies for the conduct of its business and should only be used for Frontier business consistent with Frontier s guidelines. For more information, refer to the Frontier Employee Handbook or your applicable operations manual. 9. Community and Professional Organizations Frontier has a long-standing commitment to good corporate citizenship. Frontier supports and encourages involvement in community activities and professional organizations. Frontier expects its employees, officers and directors to pursue these interests in a responsible manner and in a manner that will reflect favorably upon the employee, officer or director and Frontier. Before accepting any position with a community or professional organization, employees, officers and directors should evaluate carefully whether the position could cause, or even appear to cause, a conflict of interest. 6

7 10. Compliance and Consequences It is all of our responsibility to comply with and help enforce the standards of this Code. Situations that may involve a violation of ethics, laws or this Code may not always be clear and may require difficult judgment. Management may supplement these standards, as necessary, to address specific requirements of the various functions in their areas of responsibility. Managers and supervisors should maintain an open-door policy regarding this Code. You should discuss issues and concerns with higher levels of management, including your supervisor or manager, officers, the General Counsel s Office, or Internal Audit. We must all work to ensure prompt and consistent action against violations of this Code, including using the following steps when faced with difficult questions or problems in determining whether a Code violation has occurred. Make sure you have all the facts. In order to reach the right solutions, we must be as fully informed as possible. Ask yourself: What specifically am I being asked to do? Does it seem unethical or improper? This will enable you to focus on the specific question you are faced with, and the alternatives you have. Use your judgment and common sense; if something seems unethical or improper, it probably is. Clarify your responsibility and role. In most situations, there is shared responsibility. Are your colleagues informed? It may help to get others involved and discuss the problem. Discuss the problem with your supervisor. This is the basic guidance for all situations. In many cases, your supervisor will be more knowledgeable about the question, and will appreciate being brought into the decision-making process. Remember that it is your supervisor s responsibility to help solve problems. Seek help from Company resources. In the rare case where it may not be appropriate to discuss an issue with your supervisor, or where you do not feel comfortable approaching your supervisor with your question, discuss it locally with your office manager or contact Human Resources, Internal Audit, or the General Counsel s Office. You may report ethical violations in confidence and without fear of retaliation. If your situation requires that your identity be kept secret, your anonymity will be protected. Frontier does not permit retaliation of any kind against employees for good faith reports of ethical violations. Always ask first, act later: If you are unsure of what to do in any situation, seek guidance before you act. You should be alert to possible violations and report potential violations to Internal Audit or the General Counsel s Office. You must cooperate in any internal or external investigations of possible violations. Frontier will not tolerate any reprisal, threats, 7

8 retribution or retaliation against any person who has in good faith reported a violation or a suspected violation of law, this Code or other Frontier policies or against any person who is assisting in any investigation or process with respect to such a violation. Actual violations of law, this Code, or other Frontier policies or procedures must be promptly reported as described in Reporting Violations of the Code below. You are responsible for ensuring that your conduct and the conduct of anyone reporting to you complies fully with the policies governing Frontier s business dealings, including this Code of Ethics. Compliance, both personal and by subordinates, will be a factor in annual performance reviews. Violations of Frontier s policies can result in disciplinary actions, up to and including the termination of your employment. Determinations of the type of disciplinary action to be taken will be made by Frontier s management or, in the case of a member of the Board of Directors, CEO, CFO, or members of the Accounting Department, by the Governance Committee. Where Frontier has suffered a loss, it may pursue its remedies against the individuals or entities responsible. Where laws have been violated, Frontier will cooperate fully with the appropriate authorities. 11. Reporting Violations of the Code You should report any concerns or questions about violations of laws, rules, regulations or this Code to the your supervisor, manager or officer, General Counsel s Office, or to Internal Audit. Interested parties may also communicate directly with the Board of Directors Governance Committee using the contact information below. Any concerns about violations of laws, rules, regulations, or this Code by any officer or director should be reported promptly to the General Counsel s Office, and the General Counsel s Office will notify the Governance Committee of any violation. Conflicts of interests involving the General Counsel s Office should be reported directly to the Governance Committee. Reporting of violations may also be done anonymously by calling the telephone hotline listed below or in writing to the General Counsel s Office, Internal Audit, or the Governance Committee. Any report, including anonymous reports, should provide enough information about the incident or situation to allow Frontier to investigate properly, including a description of the questionable practice or behavior, the names of any persons involved, the names of possible witnesses, dates, times, places, and any other available details. If concerns or complaints require confidentiality, including keeping an identity anonymous, we will endeavor to protect this confidentiality, subject to applicable law, regulation or legal proceedings. Nominating and Corporate Governance Committee General Counsel David Sislowski 7001 Tower Road Denver, CO

9 Director of Internal Audit Kirk Stevens 7001 Tower Road Denver, CO Hotline Number Reporting Questionable Accounting or Auditing Matters Supervisors and managers who become aware of any questionable accounting or auditing matters, or who receive complaints or concerns from other employees, must immediately report them directly to the Audit Committee in accordance with this policy. Supervisors and managers who receive complaints of questionable accounting or auditing matters must consult with the Audit Committee before undertaking an investigation or other action. The Audit Committee has final responsibility and authority for the investigation and handling of any concerns or complaints relating to accounting and auditing practices. The Audit Committee will oversee the receipt and handling of allegations of questionable accounting or auditing matters, including directing an appropriate investigation and response. Based on its investigation, the Audit Committee will direct Frontier to take prompt and appropriate corrective action in response to the complaint or concern if necessary to ensure compliance with legal and ethical requirements relating to financial, accounting and audit matters of Frontier. If the Audit Committee determines that a particular complaint or concern is not covered by this policy, it will refer the complaint or concern to the Chief Executive Officer of Frontier for appropriate handling and response. 12. Waivers and Amendments Frontier s Board of Directors must approve any amendments to this Code. Frontier will promptly disclose to its shareholders any amendments of the provisions in this Code applicable to the CEO and the senior financial officers. Waivers of the Code for employees must be approved in writing by the General Counsel. Pursuant to SEC and Nasdaq rules, the amendment of certain provisions of this Code, or the waiver of certain provisions of this Code for certain officers and members of the Board of Directors, must be approved in writing by Frontier s Board of Directors and promptly disclosed to the public pursuant to applicable laws and regulations. 9

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