Our Code of Conduct and Ethics - ONE AIR NEW ZEALAND - DOING WHAT'S RIGHT
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ONE AIR NEW ZEALAND — DOING WHAT’S RIGHT Our Code of Conduct and Ethics LAST UPDATED: SEPTEMBER 2021
A MESSAGE ABOUT OUR CODE OF
FROM GREG CONDUCT AND ETHICS
We are an iconic New Zealand business
committed to enriching our country by
The Code applies to all of us 2. Operate safely, responsibly and
reliably at all times
connecting New Zealanders to each other The Code of Conduct and Ethics (the “Code”) • Follow the health and safety procedures for
and New Zealand to the world. Under Kia provides guidance on standards of integrity and your area.
Mau, we each have a role in keeping our business conduct. It doesn’t attempt to address • Only undertake work if you are medically fit
promise of Manaaki – taking care further than every situation that we might encounter. for duty, sufficiently rested and alert enough
to perform your duties.
any other airline to our customers every day. Air New Zealand has specific policies and standards
that apply globally, geographically or to certain 3. Act with integrity, honesty
Let’s all take pride in working for this uniquely divisions, functions or departments. Take the time and transparency
Kiwi organisation and together commit to doing to understand the policies that are referred to in this
Code and how they apply to you in your role. • Be vigilant about IT security.
what’s right.
You are encouraged, and expected, to seek • Use the business resources in a responsible
Our Code of Conduct and Ethics reflects the way
additional help whenever you have questions or are and ethical manner. This is especially important
we do things here, and is a guide to how we should
unsure about the right course of action. Managers, if you are working from home.
behave and for the daily decisions we make.
Be honest, act with integrity, transparency and Human Resources and our Risk & Compliance • Be mindful of what you are sharing on social
mutual respect. team are available to help you if you need them. media. Only authorised spokespeople can speak
to the media on behalf of our airline.
It is absolutely essential that all Air New Zealanders
read, understand and live by this Code. Apply the 4. Protect our people, property
principles to the work you do every day and speak
up if you have concerns about any behaviour
What we expect of you and information
• Protect, sensitive, confidential and strategic
you feel is in breach of this Code.
This Code brings together all of our policy principles information about Air New Zealand, our
Ngā mihi, to set out what we expect from every person company, employees and customers at all times.
working for, and with Air New Zealand, regardless Don’t share with anyone without permission.
of location – including our executives, employees, • Secure equipment and other property properly
subsidiaries, directors, contract workers or agents to prevent unauthorised use, damage or theft.
who provide services on our behalf. We also expect • Immediately report any lost property, security
our suppliers and business partners to uphold risks or unusual/suspicious activity to the
Greg Foran
equally high standards, and abide by our Supplier Security team.
Chief Executive Officer
Code of Conduct.
• Only use approved suppliers and agreed
processes for finding and buying goods
We need all Air New Zealanders and services.
to read, understand and • Always stay within your delegated financial
live by this Code and it’s limits for any expenses or purchases and
consider whether the expense is essential for
5 key principles the company’s business.
• Respect individual privacy when accessing,
1. Treat people fairly and with respect using or sharing personal information – report
in all your dealings any concerns to Privacyofficer@airnz.co.nz.
• Be kind. Treat your colleagues with dignity 5. Comply with the Law
and respect.
• Operate within all applicable laws, rules and
• Do no harm. We do not tolerate any form of regulations at all times.
discrimination, harassment or bullying.
ABOUT OUR CODE OF CONDUCT AND ETHICS ABOUT OUR CODE OF CONDUCT AND ETHICS
Make a commitment Our Code reinforces our commitment to both There are three ways
the letter and spirit of our legal requirements
to do what’s RIGHT and our policies. It cannot cover all laws, to speak up:
regulations and other legal requirements of all
jurisdictions we operate in. • Report it to your Manager
When making a business decision or deciding It’s not always easy to raise your concerns. We value open
what action to take, ask yourself: Make sure you are familiar with the relevant
Speak Up
and honest communications, so you’re encouraged to
laws and regulations that apply where you work. discuss any concerns with your manager.
• Is this aligned with our Business
If there is a difference between a local legal
Principles? • Report it to your Human Resources team
requirement and our Code, apply the most Don’t ignore behaviour that is unacceptable,
• Is it dishonest? stringent standard. If in any doubt, contact your If it’s not appropriate, or if you are not comfortable
even small things, because small things can make discussing the issue with your manager, you should
• Is this legal and ethical? manager or our Legal team. a big difference. SPEAK UP. discuss it with your HR Business Partner (ask your
• Does it comply with our policies and manager if you don’t know who yours is).
Whatever your concern, don’t wait until it becomes
approved processes?
• Am I acting with integrity? Your Compliance a serious problem.
We encourage everyone to raise concerns about
• Report it confidentially using the
Speak Up line
• Who is this good for? Responsibilities conduct that may be unethical or illegal. Our Just You may want to report your concern to someone who is
• Could I explain or defend it if it appears Culture policy and procedures support a fair and independent from the situation. Search Speak Up on the
in the media? As an employee you must: confidential process. intranet to find the phone numbers, or form to make a
• Could I explain it to family, friends report online.
• Understand and comply with the Code Hold your colleagues accountable for behaving
and colleagues? ethically and for following this Code. If you see
• Complete mandatory annual refresh training
• Could anyone be harmed? behaviour at work that you feel may breach this
• Is this the right thing to do?
on their obligations under the Code; and
Code, seems illegal or unethical, or is an abuse Our promise of
• Immediately report any non-compliance
• Could there be any possible with the Code.
of our systems, processes or policies, you must
report it, even if you only suspect it.
non-retaliation
unintended consequences?
Additionally if you are a leader, you must also: This could be bullying or harassment, potential
If you are not comfortable with any of your Air New Zealand has a non-retaliation policy
• Enforce the Code consistently for all your conflicts of interest, danger to the health and
answers above, DON’T do it. when a genuine concern has been reported.
employees. safety of employees or customers, bribery, theft or
This means that no action will be taken against
If are still unsure, seek help by talking to your fraud, price fixing or a breach of data privacy.
• Prioritise our ethics over business objectives you, and you will be protected against any form
manager, HR Business Partner or the Risk
wherever there is a conflict. For safety-related incidents or issues, continue to of harassment if you report concerns in good
& Compliance team.
use our safety reporting process as a first priority. faith, even if proven not to result in a breach.
• Support appropriate business conduct, ethical
behaviours and compliance activities.
Comply with the law • Make sure appropriate controls are in place in
your team.
The airline industry is highly regulated by local • Never cover up or ignore any actual or
government and the governments of other potential business conduct or ethical problem;
countries where we do business. Without address the matter immediately and seek
exception, Air New Zealand aims to comply guidance if necessary.
with all applicable laws, rules and regulations in
• Encourage your team members to ask questions
the jurisdictions in which we operate, including
and raise any conduct or ethical concerns by
export control, sanctions and customs,
speaking up. Make sure that no one is treated
competition and anti-money laundering laws.
unfairly as a result of speaking up.
• Deal with concerns when they are raised.
POLICIES COVERED:
JUST CULTURE AND REPORTING POLICY
RISK MANAGEMENT POLICY
AIR NEW ZEALAND CODE OF CONDUCT / 2
OUR BUSINESS PRINCIPLES OUR BUSINESS PRINCIPLES
OUR BUSINESS
PRINCIPLES
Our Business Principles
are at the heart of our
Code of Conduct and Ethics.
They form the foundation of how
our Company does business
everywhere we operate, and reflect
the commitments we make to
our people, our business partners
and stakeholders.
AIR NEW ZEALAND CODE OF CONDUCT / 4
OUR BUSINESS PRINCIPLES OUR BUSINESS PRINCIPLES
Our Business Principles apply to the Company as
they apply to you. This is how the Company will
apply the Principles.
1. Operate safely, responsibly and reliably • We will not tolerate any form of forced or • We will only spend company money where there • We trust each other to deliver on our
compulsory labour, including human trafficking, is a legitimate business need and where the cost commitments and obligations, and value
slavery, torture, cruelty, inhuman or degrading is worth the benefit. collaboration as the best means of working
• We will protect the health, wellbeing, safety and treatment or other violation of human rights in • We will take into account social, ethical and together to achieve superior outcomes.
security of our customers, employees and the any part of our business or in our supply chain. environmental considerations in our procurement • We will empower our people to enhance their
communities in which we operate. • We will avoid any activity or contracts that may and supply chain decisions. personal potential by offering satisfying and
• We will not tolerate anyone being affected by lead to, or suggest, a conflict of interest between • We will secure and safeguard our confidential challenging work and career opportunities,
alcohol or other drugs in the workplace. personal activities and Air New Zealand. and sensitive information from improper investing in development and personal growth.
• We will operate our business with discipline and • We will build trust through integrity, disclosure to prevent harm to Air New Zealand, • We will reward and recognise our people
excellence to ensure sustainability, resilience transparency, honesty and objectivity in our our stakeholders, employees or customers who for work which contributes to our mission to
and effectiveness. business dealings and relationships. have trusted us with their information. supercharge New Zealand’s success, and for
• We will protect and safeguard the natural • We will use business resources in the best interest • We will protect and safeguard our brand, property, demonstrating the right behaviours that reflect
environment (our Tiaki promise), minimising our of Air New Zealand and not for personal gain. intellectual property and financial assets. our values.
use of finite resources and the release of harmful • We will communicate honestly, responsibly and • We will respect people’s legal rights to privacy • We will respect people’s lives outside of work,
emissions to the environment. transparently with all stakeholders within the and the confidentiality of personal information. balancing life activities, and valuing their
• We will invest in society and communities bounds of commercial confidentiality. contribution to society.
ensuring effective use of our resources and in • We will not tolerate child labour and are
line with our mission. committed to the elimination of all forms of
4. Treat people fairly and with respect
forced and compulsory labour.
3. Protect our people, property and information
2. Act with integrity, honesty and transparency • We will not accept any form of discrimination,
• We will base our investment decisions and harassment or bullying. 5. Comply with the Law
business relationships on economic criteria from • We will treat people fairly, with dignity and will
• We will conduct our business with proper
objective and complete due diligence information. pursue equality of opportunity and inclusion for
regard for ethical business practices in all
• We will not commit to expenditure without all employees through our employment policies • We will comply with all applicable domestic and
communities in which we operate.
appropriate authorisation. and practices. international laws and regulations, appropriate
standards and principles, including all export
• We value diversity of people and thought. control, sanctions and customs, competition,
• We will recruit, select and develop our people and anti-money laundering laws in the
on merit – irrespective of age, race, colour, jurisdictions in which we operate.
origin, gender, religious beliefs, disability, family • We will not tolerate any form of bribery,
or marital status, sexual orientation or other including improper offers of payments or gifts
prohibited grounds. to or from employees.
• We will perform at our best, demonstrating
professionalism, living our values and operating
with acute customer focus at all times. We will
proactively address under-performance.
• We will work in good faith, within the
appropriate legal framework, with trade unions
and other bodies that our people collectively
choose to represent them.
AIR NEW ZEALAND CODE OF CONDUCT / 6
OPERATE SAFELY, RESPONSIBLY AND RELIABLY OPERATE SAFELY, RESPONSIBLY AND RELIABLY
1. OPERATE SAFELY,
RESPONSIBLY
AND RELIABLY
Safety Avoiding Alcohol Crisis, Emergency and Airline Security
Safety at Air New Zealand is a top priority. We and Other Drugs Business Disruption Global security remains volatile and we must
are committed to achieving a Zero Harm work
environment and a culture of safety and continuous Alcohol and other drugs must never affect us in our Management take our safety and security seriously. We must
all have a high level of security awareness and
improvement to protect our people, customers work. Our safety, and that of our colleagues and consistently apply appropriate security measures
customers, depend on it. Any possession, use, sale Crisis, emergency and business disruption
and communities in which we operate. It is vital that management is important to protect our people to protect our customers, employees, assets,
we maintain occupational health and help stop the or distribution of illegal substances at work will be premises and property.
treated very seriously. Air New Zealand provides and reduce any damage or loss. Effective crisis,
spread of COVID-19. emergency and business disruption planning helps
support to those affected by problems with alcohol What this means for you:
or other drugs. minimise damage and impact to the Company, and
What this means for you:
keeps our operations going after any disaster. • Always wear your security ID in secure areas
• You are responsible for your own safety and What this means for you: so it is visible to others – make sure it’s current,
wellbeing, and the safety of your colleagues and What this means for you: accurate and valid for the area in which you work.
our customers. • Never work, under any circumstances, while
affected by alcohol or any other drug that • Know your individual responsibilities and local • Immediately report to our Security team
• Comply with applicable safety laws and follow impairs judgement, performance or behaviour. emergency contact details. any actual or perceived security risks,
the safety procedures and requirements specific Be drug free and maintain a zero blood alcohol • Help develop and implement crisis, emergency weaknesses, threats, or unusual or suspicious
for your area. This includes vigilantly following level while working. This includes being free and business disruption plans for your business activity or behaviour.
workplace guidelines and recommended from the negative effects of legal drugs, such as area as requested – test these to improve • Vigilantly adhere to safety and security protocol,
practices on vaccines, masks and testing. prescription medication. response preparedness. standards and practices at all times, and follow
• Never compromise on safety or knowingly • Never drive a vehicle used for business • Debrief following an event to ensure lessons are requirements for your area.
create situations where the safety and purposes if you aren’t drug and alcohol free. learned and actioned. • Only bring unauthorised individuals into secure
wellbeing of any person is put at risk. areas after appropriate security checks and
Intervene where you see unsafe practices or • Don’t store or consume alcohol on our premises • Follow crisis, emergency and business
unless it’s authorised (e.g. sponsored and disruption procedures. authorisation. Always escort your visitors while
non-compliance with procedures. they are on the premises – never leave them
supervised functions on our premises). • Continually assess risks and threats that may
• Only undertake work if you are medically fit for alone in secure areas.
duty, sufficiently rested and alert. • Don’t use, sell, distribute or be in possession of impact your business area.
alcohol or other drugs while working or while • Store equipment and other property securely to
• If injured, ensure you do all you can in your on our premises. prevent unauthorised use or theft.
recovery and rehabilitation for a safe and timely • Report any loss of property including security
return to work. • Discuss with the Medical team prescription
medication or other legal drugs which may ID cards, Air New Zealand uniforms or branded
• Prevention is critical – identify and report impair your ability to work. work wear straight away, to local police and our
any hazards. Security team.
• Report in confidence any concerns you have
• Report safety and wellbeing concerns, no about your own use, or a colleague’s use, of • Read travel advisories and security tips before
matter how small, including any near miss, alcohol or other drugs to our Medical team. travelling overseas for business.
incident, accident, injury, illness, unsafe or Refer to the Information Security section for
unhealthy condition. • You may be required to undergo alcohol and
other drug testing for safety sensitive roles or protecting and securing data and information.
• Always drive safely, responsibly and legally where there is cause.
when operating company vehicles.
• Limit using mobile devices in the workplace
to maintain your attention to safety. Never use POLICIES COVERED:
handheld mobile devices while driving. PEOPLE HEALTH SAFETY AND WELLBEING POLICY
AIRLINE SAFETY POLICY
ACCEPTABLE USE OF BUSINESS RESOURCES POLICY AND SUPPORTING STANDARDS
AIR NEW ZEALAND CODE OF CONDUCT / 8
OPERATE SAFELY, RESPONSIBLY AND RELIABLY ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY
2. ACT WITH INTEGRITY,
HONESTY AND
TRANSPARENCY
Sponsorship, Grants Environment
and Donations Sustainability
As New Zealand’s national carrier, we are We are committed to preserving and protecting
Ethical Behaviours Human Rights Protection
committed to keeping our Tiaki promise. New Zealand’s natural environment for the future
Our ethics set standards of conduct and guide us As part of our commitment to our communities
By properly managing our grants, sponsorships by operating in an environmentally sustainable
on what is the right thing to when making business expressed in our Slavery and Human Trafficking
and donations, we protect Air New Zealand’s way and improving our energy performance.
decisions or entering into commitments. You can Position Statement, we will not tolerate any
reputation with all stakeholders.
What this means for you: put your ethical dilemmas through the following form of forced or compulsory labour, including
What this means for you: tests to see if they bring up any red flags. human trafficking, slavery, torture, cruelty,
• Comply with applicable environmental laws inhuman or degrading treatment or other
• Ensure all sponsorships or donations are and regulations – report any non-compliance • Even if its legal, is it the right thing to do?
violation of human rights in any part of our
appropriately authorised. with environmental laws and regulations to your • Who could be harmed? business or in our supply chain.
• Ensure that your personal fundraising activity Property and Facilities Manager.
• Does it involve any kind of dishonesty?
is not construed by the public as being endorsed • Do your bit to reduce, recycle, reuse and be
• Will you be forced to rationalise it to justify
by, or on behalf of Air New Zealand. energy efficient in your work environment
your action?
• Never request sponsorships or use and support the Company’s environmental
sustainability initiatives. • Are there any possible unintended
company money to make charitable consequences?
donations, to close deals, seek favours • Support using and procuring sustainable
from decision makers, support illegal energy-efficient design, products and services
If you are faced with an ethical dilemma or have identified a red flag, seek guidance from the Risk and
activity or for personal gain. to help improve our energy performance.
Compliance team or the General Counsel and Company Secretary.
• Question any charitable donation or • Educate, support and encourage others
sponsorship that gives rise to any actual (including suppliers and customers) to take
or perceived conflict of interest. responsibility for efficient energy practices
in their workplaces and communities.
• Remove yourself from decisions involving hiring,
Be Free of Conflicts supervising, managing, promoting, rewarding, or
of Interest advancing any relative, close friend or partner.
• Never influence the terms and conditions of
A conflict of interest can happen if an employee’s a contract for service, or for employment,
personal, social, financial or political activities of any employee, contractor or supplier who is
interfere (or could be seen to interfere) with their a relative, close friend or partner.
judgement at work. Whenever possible, conflicts of • Exercise care when providing travel services
interest should be avoided – even the appearance to relatives, friends or co-workers. Providing
of a conflict of interest can be harmful. preferential treatment to them such as
unauthorised deviations from established
What this means for you: rules for pricing, issuing, exchanging or
• Act in Air New Zealand’s best interest and make refunding tickets, inappropriate upgrades,
objective decisions. improperly withholding seats from inventory
or blocking space and ignoring boarding
• Remove yourself from business decisions or
priorities is not allowed.
activities where you have a personal interest.
• Avoid working or consulting for, or providing
• Discuss conflict of interest concerns with your professional services to, anyone external
manager and disclose them on the Conflicts of
that you deal with as part of your job at
Interest Register.
Air New Zealand.
POLICIES COVERED:
SPONSORSHIPS AND DONATIONS POLICY POLICIES COVERED:
SUSTAINABILITY POLICY CONFLICT OF INTEREST POLICY
AIR NEW ZEALAND CODE OF CONDUCT / 10
ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY
• Never use business resources for personal • Think about the context of the gifts or
political activity, make political donations or
Outside activities or investments
You may have a personal interest in one of Air
entertainment – imagine how it might look Using our Digital
endorse any candidate, campaign or political
issue in Air New Zealand’s name.
New Zealand’s existing or potential competitors,
to someone outside of Air New Zealand or to
the media.
Communication Systems
suppliers or customers, which might affect or
• Never provide sensitive or confidential compromise our business, or your ability to • Never accept any cash or cash equivalent, even Air New Zealand invests in strengthening our digital
information to a competitor or third party, perform your job. as a tip for great service. workforce and provides a range of IT resources to
including friends or relatives. • Never give or accept gifts from competitors or connect and collaborate as one Air New Zealand.
These situations can create an actual or perceived
• Never knowingly maintain substantial financial conflict of interest if they involve you: public officials. This gives us access to valuable information,
interests or investments in a competitor, sensitive data and internal and external networks
• Having a second job • Never ask for gifts, entertainment or any other
customer or supplier without disclosing them. that must be protected and used responsibly.
inducements.
• A relative or close personal friend cannot • serving as a director or consultant, or providing
professional services Refer to additional guidance on inducements under What this means for you:
have any business dealings with you, anyone the Bribery and Improper Payments section.
who reports to you (direct report), or anyone • having material financial interests in a • Use digital resources in a responsible, ethical
working in your business unit (indirect report). competitor, supplier or customer, or and legal manner. Don’t use them for activities
such as gambling, pornography or other
• Outside activities should not interfere
or conflict with your job responsibilities.
• taking part in civic or public duties. Using Business Resources inappropriate purposes.
Knowingly maintaining substantial financial
This includes selling goods or services for • Don’t use company computers and equipment
interests or investments in a competitor, customer Resources are provided to you to perform the
personal profit during work time or using for personal activities.
or supplier without disclosing them is not allowed. requirements of your job. All business resources
your employment at Air New Zealand as an • You are personally accountable and liable for
have an economic value, so we must all use
endorsement for personal business. all activities associated with your user accounts
them effectively, responsibly and only for
See our Subsidiary Directorships Policy and
Industry Associations Policy for information on
Giving and Receiving Gifts business purposes. and company equipment. Incidental personal
use of IT resources (email, internet, social
the invitations for directorships within the and Entertainment What this means for you: media) at work is acceptable as long as it:
Air New Zealand Group or for Group representation – doesn’t affect your, or others’ job performance
• Use business resources and assets (computer
on industry association boards/committees. We support reasonable and proportionate giving or productivity, and
equipment, access to networks, software,
and receiving of gifts and entertainment as part of internet, desktops, laptops, mobile devices, office – doesn’t interfere with operations or system
Here are some examples of when you might face
a normal business relationship or cultural practice. furniture, equipment and supplies, vehicles and performance (e.g. sending large personal files)
a conflict of interest:
We prohibit the giving or receiving of significant car parks, branded material and official company or consume significant time or resources, and
gifts or benefits that may be seen as preferential images and content) for company business.
Friends, relatives and co-worker relationships – doesn’t create risk to Air New Zealand, and
treatment – these actions can create conflicts of
• Business relationships with relatives, spouses, interest or raise questions about our judgement. • Only use resources that you are authorised to use. – doesn’t violate other company policies.
partners/significant others or close friends • Only access or use authorised resources or
• Similarly, intimate relationships of any duration What this means for you: information where there is a legitimate
between co- workers can, depending on the • Record gifts, hospitality and entertainment on business need.
work roles, create an actual or apparent conflict the Gifts Register if valued at NZ$250 or more. • Use resources responsibly and cost effectively.
of interest.
• Seek prior approval for gifts, hospitality and • Don’t engage in personal activities during work
Political or civic involvement entertainment valued at NZ$1000 or more. hours that interfere with you fulfilling your job
• Avoid giving or accepting anything of responsibilities.
Your involvement in any civic or political
activities must be on your own time, and with
inappropriate value. • Take all reasonable and necessary steps to
• Avoid giving or accepting any gifts or protect company resources and assets, including
your own resources.
entertainment during a tender process that from theft.
would be perceived as preferential treatment • Follow our confidentiality and privacy guidelines
or providing an unfair advantage. when using business resources.
POLICIES COVERED: POLICIES COVERED:
CONFLICT OF INTEREST POLICY ACCEPTABLE USE OF BUSINESS RESOURCES POLICY AND POLICIES COVERED:
SUBSIDIARY DIRECTORSHIPS POLICY SUPPLEMENTARY STANDARDS MEDIA COMMUNICATIONS POLICY
AIR NEW ZEALAND CODE OF CONDUCT / 12
ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY
• Separate your personal social media sites and
Duty Travel Speaking on Behalf of Using Social Media accounts from work-related ones. Avoid using
As an airline, we must balance the needs of Air New Zealand We recognise the importance and benefit of
Air New Zealand sites to distribute personal
communications, and never use official company
commercial customers with our business travel communicating through social media. We images on personal social media.
requirements. When planning your business travel, As a publicly-listed company, we are bound want to empower all our employees to be good
by strict rules to ensure that publicly released • Clearly show when posts or comments are your
find the right balance between business need, ambassadors for our brand, but be mindful
information is appropriately disclosed and own views, and not that of Air New Zealand’s,
environmental impact, financial cost and your that what you post online could have
accurately reflects the Company’s position. when you talk about work related matters.
health and safety. unintended consequences.
• Don’t disclose information about others, misuse
What this means for you: What this means for you: personal data or post photos without their
Follow these general guidelines when using
• Only make comments on behalf of Air New Zealand social media – both inside and outside of knowledge and permission.
• Only travel on business when there is a
genuine need. if you are authorised to do so. This includes when the Company: • Be mindful of copyrights, trademarks and
contributing to professional journals or presenting intellectual property rights of others. Never post
• Obtain the appropriate approvals for travel. at industry association conferences.
Think before you post copyrighted material (including published music,
• Use the defined procedures to book travel. • Before contributing to professional journals or movies or video content) without permission.
• Use preferred suppliers to help minimise the any speaking engagements, gain approval from Be truthful, accurate, and respectful • Honour any confidentiality and non-disclosure
cost of travel. your GM and have your content reviewed by our requirements, even on personal sites.
• Only claim business expenses that are necessary Corporate Communications team.
Use good judgement and common sense • Never post information about legal matters,
and reasonable for your business travel. Use a • Direct any media enquiries or requests to the including corporate transactions or
company credit card for travel-related expenses Corporate Communications team. investigations.
Do no harm
whenever possible. • Never disclose commercial or strategic • For security reasons, never post details
• Ensure you are medically fit for your planned information about the Company, our employees What this means for you: (including videos or photos) of any secure or
travel and review safety protocols and security or our customers without permission, even after restricted area, such as aircraft hangars or
advisories for your destination – discuss any you leave Air New Zealand. This includes sharing
• You are personally responsible and liable
for anything you post online, whether maintenance areas, runways, airline passenger
concerns with our Safety and Security teams. information intended for internal use only with areas, interiors of aircrafts cabins, cockpits,
speaking personally or in an official capacity
• Personal travel is not be taken in conjunction third parties. under carriage, landing gear and baggage
for Air New Zealand.
with business-related travel. • Return any unsolicited confidential information holding areas.
• To reduce risk, executives, management you receive to the sender or ensure it’s deleted.
groups or other key individuals should avoid
travelling together.
• Maintain professionalism at all times – you are
an ambassador for the airline.
Air New Zealand honours any provision in
employment agreements regarding duty travel,
where it differs to policy.
POLICIES COVERED: POLICIES COVERED: POLICIES COVERED:
DUTY TRAVEL AND TRAVEL-RELATED EXPENSES POLICY MEDIA COMMUNICATIONS POLICY SOCIAL MEDIA POLICY
AIR NEW ZEALAND CODE OF CONDUCT / 14
PROTECT OUR PEOPLE, PROPERTY AND INFORMATION
3. PROTECT OUR
PEOPLE, PROPERTY
AND INFORMATION
Accurate and Complete Protecting Privacy
Information, Records, and Confidentiality
Reporting and Accounting
Financial Integrity Committing to Contracts Privacy is about how we collect, use, process and
share personal information about individuals,
We expect all Air New Zealanders to understand and Expenditure Honest, complete and accurate recording and
reporting of information is critical to protecting
and how we respect the rights of our customers,
employees and business partners with regards to
the financial management responsibilities relevant our credibility and reputation, and meeting our their information. Privacy is also about regulatory
to their roles and be good stewards of company It is critical for Air New Zealand to have oversight legal obligations. Failure to keep accurate and
of it’s spend and commitments across the entire compliance. As an international airline, we are
funds. Our financial and accounting controls complete records, falsifying information or creating obligated to comply with personal information
ensure we apply sound financial principles in our lifecycle We have defined processes for interacting misleading information could constitute fraud, with
with suppliers, negotiating supply contracts and protection guidelines, specifications and
business transactions. We are all responsible civil and criminal liability for Air New Zealand and legislation everywhere we fly.
for following our policies and legal, financial and making purchasing decisions. Legally binding individuals involved.
accounting regulations. contracts, with agreed terms and conditions, are What this means for you:
required before we can commit our resources. What this means for you:
What this means for you: • Take care when you are accessing or using
These agreements protect us from financial, • Always follow the correct governance for the personal information and treat it as confidential.
• Understand the financial management commercial and legal risk. approval of contracts and projects.
responsibilities, policies and processes relevant • Limit sharing, or access, to authorised people
What this means for you: • Record and report company information only who have a clear business need for that
to your role. accurately and objectively, with reasonable
• Ensure you understand how Delegated Financial information.
• Understand when you can and when you can’t Authority (DFA) rules apply to your role. detail and supporting documentation for all
commit company funds. transactions. • Keep personal information no longer than
• Ensure every purchase, requisition or order you necessary to accomplish the legitimate purpose
• Only spend company funds on legitimate make is approved within DFA. • Don’t make false or misleading entries (or (legal, regulatory or legitimate business need).
business needs. Spend responsibly and keep inappropriately alter) on company books,
expenditure within budget. • Only make commitments or decisions on behalf records or expense claims for any reason. • Be aware of local privacy laws, especially when
of Air New Zealand if you are authorised and transferring personal information outside of its
• Strive to find the best value when spending within your DFA. Unless explicitly delegated, • Comply with the Company’s system of country of origin.
company money by considering quality, service, no employee or contractor may commit to a internal controls.
reliability, sustainability, compliance with our • Be objective when making written comments
contract or incur expenses. • Be alert for unauthorised payments or invoices about people, as all personal information may
finance and procurement policies and any terms – ensure that no undisclosed or unrecorded
and conditions. • Follow defined processes and use approved be disclosed. Personal information, including
suppliers when sourcing and purchasing goods or ‘off the books’ amount, fund or asset is your opinions, should be relevant, appropriate,
• Base your financial decisions on sound and and services. established or maintained (see the Anti-money accurate and justifiable.
objective information. Laundering section for more information).
• Report any breaches of DFA to your 2-up • When using electronic communications,
• Run transparent tendering processes for manager, or to your delegator’s 2-up manager, • Cooperate fully with Internal Audit, Group take extra care to ensure that any sharing of
suppliers and business relationships. in accordance with the DFA Policy. Finance and external auditors and provide them personal information is done in a secure and
• Report any suspected misuse of company with accurate information and unrestricted protected way.
• Ask Procurement if in doubt before ordering access to necessary resources.
property or funds. a product or service. • If you believe personal information has been
• Report any concerns or irregularities in accidentally or intentionally viewed, shared,
accounting, auditing or internal controls. altered, stolen or used in an unauthorised way
• Secure all information to prevent unauthorised contact Privacyofficer@airnz.co.nz.
access or disclosure.
• Understand and follow our data retention
standards for creating, retaining and destroying
company information.
POLICIES COVERED: POLICIES COVERED:
FINANCE AND ACCOUNTING POLICIES FINANCE & ACCOUNTING POLICIES
PROCUREMENT POLICY RECORD RETENTION AND DESTRUCTION POLICY POLICIES COVERED:
DELEGATED FINANCIAL AUTHORITY POLICY AUDIT INDEPENDENCE POLICY PRIVACY POLICY
AIR NEW ZEALAND CODE OF CONDUCT / 16PROTECT OUR PEOPLE, PROPERTY AND INFORMATION PROTECT OUR PEOPLE, PROPERTY AND INFORMATION
• Use Confidentiality Agreements before disclosing
Keeping Information Protecting and Respecting What this means for you:
• Protect all confidential, proprietary or other IP confidential information to outside parties.
Secure our Property information (whether printed material, electronic • Avoid disclosing any details of new products,
files, email, or verbal conversations), even after designs, patents, trademarks or other
Information is one of our most valuable assets. Our brand, designs, patents, trademarks, you leave Air New Zealand. confidential or IP in public places, or with friends
We must protect our company and customer copyrights, trade secrets and know-how – our and family, or anyone not authorised to access it.
• Comply with our Brand Guidelines.
information from unauthorised access by securing intellectual property (‘IP’) are valuable assets that • Report any suspected misuse or theft of logos,
it appropriately at all times. we must safeguard. • Never allow any third party to use our brand or
trademarks or other Air New Zealand IP to Legal.
trademarks without first discussing it with Legal.
What this means for you: We must comply with applicable laws and • Report any lost or stolen confidential
regulations that help us protect our IP from theft or • Retain confidential or proprietary information
• Classify and store information that you use for work information or other property immediately to
misuse – and in doing so, ensure it’s available to us or other IP in accordance with our Record
in line with the Information Classification Policy. Legal and Security.
for future innovation. Retention Policy, and only share it with those
• Protect your password. Don’t share it with anyone who are authorised and have a business need • Obtain permissions before using the IP of
or write it down. IP includes: for the information. others and report any activities that infringe on
– our brand, designs, patents, trademarks, the IP of others.
• Protect information sensitive and confidential
documents at all times. This includes looking copyrights, trade secrets and know-how
after laptops, mobile devices and storage devices – pricing, marketing and customer strategies
when left unattended. and plans
• Dispose of information securely when it’s no – research and technical data
longer needed. – business ideas, processes, proposals or
• Never save sensitive or confidential information strategies
on unauthorised systems or storage devices. – new product and/or package design and
• Lock your computer screen if you leave your development
computer unattended and switch off your – software bought or developed by the Company
computer at the end of the day.
– information used in trading activities.
• Report incidents, breaches or lost laptops or
mobile devices immediately to the IT Service Desk.
• Think before you click. Be careful when opening
attachments from unknown addresses. Don’t
click links which may take you to unsafe websites.
• Only use authorised software and hardware.
• Notify the Information Security team of any
suspicious activity such as phishing emails
or scams.
POLICIES COVERED:
POLICIES COVERED: CONFIDENTIALITY POLICY
CYBERSECURITY POLICY AND STANDARDS RECORD RETENTION AND DESTRUCTION POLICY
AIR NEW ZEALAND CODE OF CONDUCT / 18TREAT PEOPLE FAIRLY AND WITH RESPECT TREAT PEOPLE FAIRLY AND WITH RESPECT
4. TREAT PEOPLE
FAIRLY AND
WITH RESPECT
Preventing Bullying Air New Zealand will not tolerate any form
of harassment or sexual harassment in the
and Harassment workplace, whether that is internal or third-
party harassment towards an Air New Zealand
Equality, Diversity Merit-based We are all responsible for ensuring that
employee, contractor or other representatives
of the Air New Zealand Group. We may initiate
and Inclusion Talent Acquisition harassment and bullying doesn’t happen at
Air New Zealand. Harassment and bullying can
disciplinary or legal action against people who
harass or bully others. This includes suppliers,
take many forms and have serious repercussions.
We strive to create a working environment where We are committed to attracting, developing and customers and other visitors to our premises.
everyone feels respected and valued, and that advancing the best people through a fair and Harassment includes language or conduct
reflects the diversity and characteristics of merit-based process, and ensuring the process that may be derogatory, intimidating or offensive
to others.
the communities in which we operate and the
customers we serve. We respect and value the
is free from bias and discrimination. We adhere
to all employment regulations regarding staff, Bullying and intimidating behaviour is repeated Ethical Business
contribution of each team member, and regard
discrimination as unfair, unacceptable and
contractors and other complementary workforce
(outsourced workers, agents).
inappropriate behaviour that undermines
someone’s right to respect at work.
Practices of Suppliers
unlawful. The Air New Zealand Group has zero We engage with suppliers who share our
tolerance for any form of Unlawful Discrimination of What this means for you: What this means for you:
commitment to sound, sustainable, safe and
employees or potential employees. • Base your decisions about recruitment, • Never be derogatory or abusive to or ethical business principles.
selection, development and advancement of about others. We are committed to doing business with
What this means for you:
employees on merit. • Never behave in a way that is unwelcome, suppliers who, as a minimum:
• Act fairly and show respect towards others in • Never allow race, colour, religion, gender, intimidating or offensive, including threats, • Supply products that are manufactured in safe
all your dealings. disability, age, country of origin, sexual bullying, inappropriate jokes or actions of and healthy conditions
• Actively seek, value and be mindful of cultural orientation, gender identity, marriage status a sexual nature. Discourage others from
• Operate in an ethical manner
sensitivities and different perspectives present or any other characteristic protected by any engaging in this behaviour.
• Use voluntary workers (not indentured, forced
in our global community. applicable law to influence your judgement. • Always communicate in accordance with our or bonded labour of any kind), that are paid a
• Challenge discriminatory behaviour. • Understand your responsibilities and comply Code no matter how informal you are being. proper wage under human conditions, are not
• Be inclusive in the language you use when with all applicable labour and employment laws. • Report, and encourage others to report, discriminated against, exploited or subject to
communicating. • Expect others you work with (contractors, incidents of harassment, sexual harassment any kind of abuse, and work in conditions which
• Report any incidents that are inconsistent agents, joint ventures) to act in a way that is bullying or retaliation. are humane
with our commitment to equal opportunity, consistent with our fair treatment and equal • Take all harassment, sexual harassment and • Do not use child labour.
inclusion and diversity. opportunity standards. bullying complaints seriously. Managers should
• Report any breaches of law or this Code, or immediately address behaviour or conduct that What this means for you:
any incidents that are inconsistent with our may be offensive. • Before engaging a supplier or business
commitment to equal opportunity, inclusion • Don’t retaliate against anyone who makes a partner, do your due diligence on ethical
and diversity when you become aware of them. good-faith complaint of harassment, sexual conduct requirements.
Cooperate with company investigations. harassment or bullying, or who cooperates in
an investigation of a complaint.
• Seek support from your manager, your
manager’s manager, your HR Business Partner
or People Safety teams.
POLICIES COVERED:
HARASSMENT AND SEXUAL HARASSMENT: PREVENTION
POLICIES COVERED: AND COMPLAINTS POLICY POLICIES COVERED:
EQUALITY, DIVERSITY AND INCLUSION POLICY WORKPLACE BULLYING PREVENTION AND COMPLAINTS POLICY SUPPLIER CODE OF CONDUCT
AIR NEW ZEALAND CODE OF CONDUCT / 20COMPLY WITH THE LAW COMPLY WITH THE LAW
5. COMPLY WITH
THE LAW
• Escalate to the Executive any contract or project • Maintain accurate and complete records of
Anti-money Laundering which you think may involve potentially unethical Eliminating Bribery, payments made to third parties to evidence the
Money laundering is the use of transactions by
activities or sensitive industries (e.g. concerns
around human trafficking, child labour, mining,
Corruption and business reason for such transactions.
• Providing money or gifts to any Public Official
criminals, terrorists, or others to conceal the
illegal source of their funds. We are committed to
contracts with military involvement. Improper Payments for the purpose of influencing them in their
• Consider where you are undertaking business official capacity is not allowed.
the highest standards of anti-money laundering The law prohibits bribery in every kind of
and whether that country raises any geopolitical
compliance to prevent use of our products and commercial setting. Facilitation payments, or
risks or reputational concerns.
services for money laundering purposes or for
financing of terrorism. • Seek guidance from Government Affairs or the
Group Security team and consult the Legal team
kickbacks, are examples of bribery and are illegal.
Giving or receiving gifts or entertainment might Avoiding Insider Trading
also be bribery in certain circumstances, as many
What this means for you: if in doubt. In most countries, it is illegal for people to
countries have stringent rules that prohibit giving
• Use defined processes in your area to identify anything of value to public officials to influence profit from insider trading ( trading securities
and manage money laundering activities and their actions. or manipulating share prices based on ‘inside
the financing of terrorism. Ensuring Continuous information’ – information that is not publicly
available that we may have as a result of working
What this means for you:
• Complete customer due diligence to verify
their identity.
Disclosure • Be cautious when giving or receiving gifts or
for Air New Zealand, and that is ‘material’ or
could have an impact on the value of those
• Look out for any suspicious transactions using entertainment, especially when a public official
Air New Zealand is a listed public company under shares or securities if it was made public). These
cash payments or monetary instruments. is involved (refer to the Gifts and Entertainment
the New Zealand Stock Exchange, and must rules apply regardless of how you acquire the
policy for more information).
• Follow procedures to report money laundering comply with the NZX Listing Rules. Harsh penalties inside information, whether you are aware of the
or illegal financing activity. exist for breaches of the Listing Rules and other • Ensure that all gifts and entertainment are sensitivity of the information, and continue even
applicable laws which may result in personal permitted by local law. after you stop working for Air New Zealand.
• Report any suspicious activity to Legal
exposure to regulatory penalties, company liability • If you are engaging third parties, always Insider trading can result in severe penalties
immediately.
and disciplinary action. complete sufficient due diligence to confirm including criminal liability, fines, and imprisonment.
that bribery is unlikely, before any agreement
What this means for you: or contract is signed or renewed, or before any What this means for you:
Export and Sanctions • If you become aware of anything that may work is undertaken under that relationship. • Protect inside information from accidental
be considered ‘material information’, • Refuse to pay facilitation or other improper disclosure.
What this means for you: immediately discuss it with a member of the payments. • Never spread false information or engage in
• Do not undertake work or contract or project, Disclosure Committee. Material information
• Never make donations to political parties, activities to manipulate the price of publicly
at its outset or over time, that involves work for means any information that a reasonable person
candidates, or to any political cause or listed securities.
any military outside of the Five Eyes without would expect, if it were available to the general
election fund. • While having ‘inside information’, you are
Executive approval. market, to have a material effect on Air New
Zealand’s share price (i.e. commercially and • Never make charitable donations for purposes prohibited from directly or indirectly:
• Check carefully before exporting whether the of gaining commercial advantage.
price sensitive) – trading securities of Air New Zealand
relevant goods are on the Ministry of Foreign
Affairs and Trades’ NZ Strategic Goods List. • If in doubt whether it is ‘material information’, • Never make, offer to make or authorise – trading securities of any other publicly
keep it confidential and seek guidance payment to a third party knowing that the traded company
• Screen all parties involved in a transaction or payment will be offered or given to secure an
from Legal.
agreement against the Countries of Concern List. improper commercial advantage or secure an – leaking, tipping off or otherwise passing
• Keep the material information confidential until inside information to third parties.
• Escalate to the Executive any contracts involving improper business benefit. Even charitable
officially disclosed to the public.
the countries or industries listed on the Countries donations can be seen as bribes if payments • If you have questions or concerns about insider
of Concern List. • Only conduct discussions with analysts, are made to facilitate a process or secure a trading, contact Legal for guidance.
investment professionals, shareholders or other commercial advantage.
market participants if you are an Authorised
POLICIES COVERED: Spokesperson as defined in the Continuous POLICIES COVERED:
CONTINUOUS DISCLOSURE POLICY
Disclosure Policy. POLICIES COVERED: ANTI-BRIBERY & CORRUPTION POLICY
ANTI-BRIBERY & CORRUPTION POLICY ANTI-BRIBERY & CORRUPTION POLICY GIFTS AND ENTERTAINMENT POLICY
GIFTS AND ENTERTAINMENT POLICY GIFTS AND ENTERTAINMENT POLICY SECURITIES TRADING POLICY
AIR NEW ZEALAND CODE OF CONDUCT / 22COMPLY WITH THE LAW LIVING OUR CODE
LIVING
OUR CODE
• Always collect competitor information in legally This Code is not a contract of employment,
Competing Fairly appropriate and ethical ways.
• Unless you obtain prior approval from Legal,
and Air New Zealand may interpret,
We make independent business decisions that are
in our best commercial interests, compete fairly,
don’t: modify or rescind some or all of the Code
and comply with all applicable competition laws – engage in benchmarking or other information provisions, as well as related policies and
exchanges or activities with competitors – use
around the world.
publicly available information instead
standards, at any time.
What this means for you: – begin any negotiations on mergers, acquisitions,
• Never pursue any unfair advantages or joint ventures or similar transactions, especially
misrepresent facts about our business when if competitors are involved
engaging with customers, suppliers and – negotiate in joint activities with competitors to
competitors. influence government action.
• Never exchange sensitive information with • Never use trade associations or professional
competitors. societies for contacts or communications with
• Never make false or misleading statements competitors that violate the law or company
about our competitors. policy, such as discussions about price or other
sensitive information.
• When dealing with competitors, do not to
participate in any arrangement that could be • Never encourage customers, suppliers or
construed as anti-competitive collusion. former employees of competitors to provide
information that they should keep confidential.
• Never enter into anti-competitive agreements
with competitors, (such as price fixing, bid • If you have any concerns, contact Legal.
rigging, market allocation and agreements) to
restrict supply to another competitor.
• Never discuss costs, pricing or competitive
bids with competitors or agree on who will win
a competitive bid.
Abiding by our Code
Agreement to abide by the Code
All Air New Zealanders must acknowledge that they’ve read, understood and agree to abide by the Code.
We are required to do this when we are hired and to renew this commitment annually by completing Code of
Conduct refresh training.
Consequences of non-compliance
Our Code represents our commitment to do the right thing, including respecting the rights of others. As an
Air New Zealander, you agree to uphold this commitment. If you don’t, you could put yourself, your colleagues
and Air New Zealand at risk.
Our Just Culture philosophy focuses on open reporting, process improvement and prevention 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
action and even dismissal. Breaches of law may also result in civil or criminal penalties.
POLICIES COVERED:
COMPETITION LAW POLICY
AIR NEW ZEALAND CODE OF CONDUCT / 24You can also read
