JetBlue Business Partner Code of Conduct

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1 JetBlue Business Partner Code of Conduct JetBlue s foundation is built on our Values Safety, Caring, Integrity, Passion and Fun. We use our Values to guide our actions, distinguish us from our competitors, and help us deliver superior Customer and Crewmember experiences. Our Values are embedded in our culture, and our long-term success is dependent on our integrity. We deal fairly, honestly and in good faith with our Crewmembers, Business Partners, and Customers. The best way to outperform our competition is through fair and honest competitive advances and never through unethical or illegal practices. We are committed to the highest standards of safety, service, ethics, and compliance. These standards are rooted in our culture, Crewmembers, and business practices and should be reflected through our business partnerships as well. We realize that our Business Partners have different laws and regulations that they must comply with and that they operate in different cultural environments throughout the world. We expect our Business Partners to do the right thing at all times and in all circumstances. The JetBlue Business Partner Code of Conduct herein referenced as Code of Conduct serves as the standard for assessing the ethical business practices of our Business Partners. This Code of Conduct incorporates standards on human rights, labor rights and environmental and anti-corruption principles as set out in the UN Global Compact. All Business Partners providing products or services to JetBlue either directly or indirectly must comply with this Code of Conduct. Legal Compliance Business Partner s business activities shall comply with all applicable laws and regulations in the countries and jurisdictions in which they operate and conduct business. This includes activities in locations where the Business Partner s goods are produced, related services performed, and entered into the supply chain. Record keeping, Financial Integrity & Fraud All information you record or report on JetBlue s behalf, whether for our purposes or for third parties, must be true and accurate. All of JetBlue s records, including accounts and financial statements, must conform to Generally Accepted Accounting Principles (GAAP), must be maintained in reasonable and appropriate detail, must be kept in a timely fashion, and must accurately and appropriately reflect our transactions. Falsifying records or keeping unrecorded funds and assets is a severe offense and may result in prosecution and/or termination of the business relationship. We have a legal responsibility to provide accurate and complete information to the investing public. If you are involved in the preparation of materials for dissemination to the public (including to our regulators), you must ensure that the information is accurate and complete.

2 JetBlue maintains a zero-tolerance policy for Business Partners who, through the course of work at JetBlue, engage in any scheme to defraud anyone of money, property or honest services. Fraudulent activity violates the law and carries severe penalties. Fraud can range from minor theft to a significant misstatement of our earnings and holdings. Antitrust & Fair Competition Business Partners must adhere to all antitrust and fair competition laws. This includes not participating in any of the following: price fixing, volume/capacity agreements among Business Partners, collusive bidding, market/customer allocation, illegal price discrimination in products, tie-ins, attempts to monopolize any market, reciprocal dealing requirements, and theft or trade secrets. Conflicts of Interest JetBlue s Business Partners must disclose promptly all information regarding financial and personal relationships, arrangements with JetBlue Crewmembers, representatives, or their close relatives as that could appear to influence the outcome of an agreement and potentially create a conflict of interest. If you are aware that a JetBlue Crewmember s close family relative is working or performing services for your organization, you may be in a situation involving a potential conflict of interest. To disclose potential conflicts of interest, please contact Business Ethics and Compliance team. Insider Trading It is illegal to buy or sell securities (e.g., stocks, bonds, options, etc.) when you are aware of inside information material, non-public information relating to the securities. JetBlue policy prohibits you from using or disclosing either intentionally or accidentally any inside information about JetBlue or one of our Business Partners. You cannot use information gained through JetBlue, before this information is known publicly, to buy or sell the securities of any company, including JetBlue. Nor can you give inside information to anyone else so that they can trade. This applies no matter where you live or where the recipient of the information lives. Securities law violations are taken very seriously. Government agencies are able to monitor trading activities through computerized records searches, and violations of the securities laws can result in large civil and criminal penalties. Both JetBlue Crewmembers and JetBlue Business Partners are required to abide by the Insider Trading Policy. Confidential & Proprietary Information Business Partners must protect JetBlue s intellectual property including trademarks, patents, copyrights, business methodologies, and trade secrets. Business Partners may not use any of JetBlue s intellectual property or confidential information except as provided in the Business Partner s contract. Business Partners have a duty to keep proprietary information strictly confidential and protected from disclosure. If you think proprietary data has been inadvertently disclosed, please inform the JetBlue Business Ethics and Compliance team.

3 Gifts & Other Business Courtesies Business Partners are permitted to offer Crewmembers business gifts or hospitalities as long as the gift or hospitality is customary in size, cost, frequency or nature. Because it is not always clear what gifts and/or business courtesies are fitting, exercise sound judgment and make every effort to assure that your decision is appropriate. JetBlue s Gift Policy contains guidelines of acceptable and unacceptable gifts; specifies that gifts cannot be offered during an active RPF, contract renewal or contract negotiations; and requires gifts valued at $250 or more to be disclosed, and gifts valued at $500 or more to be approved. Information Security & Data Privacy Business Partners shall have privacy and security programs in place to ensure the protection of personal information of everyone they conduct business with including Business Partners, Crewmembers, customers, and consumers. Business Partners shall also comply with all privacy and security laws and regulatory requirements regarding the collection, storage, process, and transmission of personal information. Blogs and Social Networks JetBlue understands that some Business Partners may wish to create and maintain blogs and/or social networks. While we respect your right to personal expression, we expect all Business Partners to refrain from behavior that could adversely impact JetBlue. Health & Safety All work must be done in a safe and responsible manner. Health and safety policies, management systems, proper safety equipment, and training must be in place by Business Partners to promote a healthy and safe environment, prevent injury, and provide a secure working environment that complies with national laws and regulations. Drugs & Alcohol Business Partners shall prohibit the use, manufacture, distribution, sale, or possession of narcotics, drugs, controlled substances, paraphernalia and literature that promotes illegal drugs and substance use. Business Partners shall also prohibit any use of alcohol that adversely affects their employee s job performance, or is within eight hours of an employee reporting for work, training, or other opportunities representing JetBlue. Public Communication with Media & Investors Business Partners shall not make public statements to the media on behalf of JetBlue without obtaining prior, express approval from JetBlue's Legal Department or other senior management. If you receive TV, radio or media questions, or calls, s or letters from our shareholders, please refer them to Corporate Communications Media Hotline at which is staffed 24 hours a day, 7 days a week. Freely Chosen Employment Business Partners shall not use any form of forced, bonded, prison, indentured or compulsory labor including slavery or human trafficking.

4 Child Labor Business Partners shall adhere to the minimum employment age limit defined by national laws and regulations, and comply with relevant International Labor Organization (ILO) standards, and must ensure that hours and tasks performed by these employees does not hamper their education, health, safety, and mental or physical development. Business Partners shall ensure that no underage labor has been used in the production and/or distribution of their goods. Wages and Benefits Business Partners shall ensure that their workers are paid lawful wages, including overtime, premium pay, equal pay for work, and legally mandated benefits. Compensation shall be provided in a way that is prompt and easily understood. Conditional payments or disciplinary deductions are not tolerated. Working Conditions Business Partner must provide fair working conditions for their employees as well as adequate rest periods and leave. Freedom of Association and Collective Bargaining In addition to all local laws and regulations governing the legal rights of their employees, Business Partners must respect the rights of workers to join or not to join worker organizations including trade unions without penalty or interference. Employees must also have the right to collectively bargain if they choose not to be represented. Harassment, Discrimination, and EEO Business Partners shall ensure that all employees are provided with equal employment opportunities and are not harassed or discriminated against in any way. Forms of harassment or discrimination may include, but are not limited to physical, sexual, verbal, and psychological on any basis prohibited by applicable law including race, color, religion, sex, national origin, age, disability, pregnancy, veteran status, genetic information, citizenship status, marital status, sexual orientation, gender identity or expression. Environmental Considerations Business Partners shall maintain an effective environmental policy and/or environmental management system that support environmental protection, prevention of pollution and management of natural resources. In addition to meeting legal and regulatory requirements, JetBlue expects Business Partners to pursue proactive efforts to minimize the impact of waste materials on the environment through effective controls and recycling initiatives. Business Partners should also use non-hazardous materials, and save energy. Diversity and Inclusion Respect for all individuals is the foundation of an inclusive work environment. It supports JetBlue s success, sustainability, and profitability. Our desire is to conduct business with partners who operate with a similar mindset. Business Partners are expected to deliver innovative solutions that reflect diverse experiences, thoughts, and identities throughout their business. Government Contracting

5 Business Partners providing goods or services for JetBlue on a government contract must comply with JetBlue s Code of Business Conduct that outlines our position on Government Contracting. Assessment and Review Business Partners are subject to monitoring and verification of these efforts on an announced and unannounced basis by JetBlue or its representative and shall respond to all requests in a timely manner, including performance evaluations, and scheduled business reviews. Business Partners shall also provide all requested supporting documentation and provide honest, complete information. JetBlue reserves the right to audit compliance of this Code of Conduct. If an audit identifies a violation of this Code of Conduct, Business Partners shall promptly correct the situation to meet JetBlue s expectations. Business Partners are required to promptly report non-compliance of these standards committed by their employees or representatives, or by any Crewmember or representative of JetBlue. A Business Partner s disclosure of misconduct by their employee(s) does not guarantee that the misconduct will not adversely impact JetBlue s continued relationship with the Business Partner. Disclosure will be viewed as evidence of the Business Partner s good faith intent to comply with this Code of Conduct. Any form of retaliation against anyone, who in good faith, reports misconduct or non-compliance with this Code of Conduct is prohibited by JetBlue. JetBlue will work with Business Partners to support them in their remediation efforts; however, any failure to follow the Code of Conduct may result in termination. Business Partners must have management systems in place to document their compliance with all requirements of this Code of Conduct. Code Implementation Business Partners will post, implement, and integrate this Code of Conduct and supporting guidelines into their operations and will ensure compliance among approved sub-contractors. This Code of Conduct shall be prominently posted in the workplace in the local language. This Code of Conduct must be communicated to all tiers of the supply chain in the appropriate language and in a manner that could be understood. JetBlue values the relationships that we have with our Business Partners. All of our Business Partners and their suppliers should to be aligned with our values and adhere to everything contained within this Code of Conduct. Reporting Obligations It is the duty of every Business Partner and all other individuals affiliated with JetBlue to comply fully with all applicable laws, regulations, JetBlue policies, procedures, and Code of Conduct. Business Partners are required to report to the Business Ethics and Compliance team or the JetBlue Business Integrity Hotline any actual or suspected violations of the Code of Conduct, JetBlue s policies and procedures and/or federal, state or local law.

6 Business Partners must also report any other compliance-related issues, including but not limited to, conflicts of interest, fraud, or other misconduct of any type relating to JetBlue s operations. Please contact our Legal department at for guidance on this Code of Conduct and if you have any questions concerning laws and acceptable business practices. Alternatively, reports of violations or suspected violations may be submitted confidentially or anonymously in writing to: JetBlue Airways Corporation Queens Plaza North Attn: Manager Compliance (Confidential) To anonymously report concerns and potential or actual violations of this Code of Conduct (if you see something say something) contact our JetBlue Business Integrity Hotline, which is operated by an independent third party, for reporting, documenting and routing concerns related to accounting, internal controls, and auditing matters or for violations of this Code of Conduct. Reports will be routed to the appropriate JetBlue Leadership for investigation. Any such concerns may be submitted to the hotline 24 hours a day, 7 days a week via: Telephone: or Web: jblu.alertline.com Long Island City, NY 11101