Investigations

AAR is committed to investigating all allegations of misconduct, including those related to suspected corruption or bribery. Under AAR’s Speaking Up and Non-Retaliation Policy, reports of potential misconduct must be reported to management, human resources, the Compliance Department, the Law Department, or through AAR’s EthicsPoint Hotline (www.aar.ethicspoint.com).

AAR’s Investigation Committee (comprised of AAR’s Chief Human Resources Officer, AAR’s General Counsel and AAR’s Chief Ethics and Compliance Officer (CECO)) is responsible for ensuring investigations into allegations of Code of Conduct violations are handled in a fair and objective manner. [1]  Matters involving significant potential misconduct concerns are elevated to senior management as well as the Chair of the Audit Committee of the Board of Directors.

AAR ensures quality and consistency in its investigations by ensuring that its investigations are handled by qualified, objective investigators and that those investigators have access to the resources necessary to conduct such an investigation.

During the course of an investigation, the investigator must keep the Investigation Committee informed. Where allegations of misconduct are confirmed, remedial actions are taken, documented in the company’s case management tools, and reported to the Investigation Committee. The Investigation Committee ensures that findings from such investigations are communicated to appropriate parties for consideration of whether corrective action and/or discipline is warranted.

The CECO regularly briefs the chair of the Audit Committee on any significant investigations and reports any materials findings to the Audit Committee. When appropriate, anonymized findings and “lessons learned” from investigations, including those related to agents or representatives, are shared during training sessions and in other appropriate settings.

Non-Retaliation

AAR does not tolerate any retaliation, retribution or harassment against anyone who reports an actual or potential violation of a compliance issue he or she reasonably believes to be illegal or unethical, or against anyone who otherwise assists in an investigation.

[1] Any reports made to HR regarding minor workplace misconduct that generally is resolved through ordinary channels and methods and that does not involve a member of AAR’s Board of Directors or a Corporate Officer may be resolved by HR without reporting the matter to the Investigation Committee.