Ethics and compliance in Ethics and governance

At United, we are committed to conducting our business ethically, honestly and legally, each and every day.

Governing compliance

Our Ethics and Compliance Office “ECO”, led by our Chief Compliance Officer, sets the direction of our ethics and compliance program and helps to reinforce a culture of integrity through a layered strategy of policies, procedures, education, and communication.

Code of Ethics and Business Conduct

United’s Code of Ethics and Business Conduct (“Code”), available on the United.com Investor Relations website, serves as the baseline for our ethics and compliance program. The Code applies to all employees and officers of United and its subsidiaries and the members of the United Board of Directors. It is a tool to help us make the right decisions and ensure that we conduct our business ethically and legally.

Topics in the Code

The Code states our commitment to complying with laws and regulations and conducting our business in a manner consistent with guiding U.S. and international principles on human rights. It provides guidance on various topics, including:

  • Ethical decision making
  • Conflicts of interest
  • Business gifts and entertainment
  • Insider training
  • Antitrust and other competition laws
  • Interacting with the government
  • Bribery and corruption
  • Political contributions
  • Lobbying
  • Accuracy and retention of records
  • Data protection for customer and employee personal information
  • Confidential information
  • Intellectual property
  • Building a great place to work including:
    • preventing harassment and discrimination
    • fostering appropriate workplace behavior

Anti-Bribery/Anti-Corruption Compliance Policy

We reinforce our commitment to integrity through our Anti-Bribery/Anti-Corruption Compliance Policy (“ABAC Policy”). The ABAC Policy applies to all employees and officers of United and its subsidiaries as well as third-party representatives, and provides specific guidance for individuals who interact with government officials. We understand that even the appearance of impropriety can jeopardize the company’s interests and is inconsistent with our business principles; accordingly, nearly all transactions with government officials require approval by the Ethics & Compliance Office.

Raising concerns and whistle-blowing

We regularly highlight the multiple avenues for employees to raise concerns or seek guidance – from managers, to Human Resources, to the Ethics and Compliance Office including the Ethics and Compliance Helpline and Web Reporting, which are confidential, available 24/7 with multi-language capabilities and provide the ability to report anonymously where possible.

Protection for whistle-blowers

The Code makes clear that United prohibits retaliation against anyone who in good faith files a report about suspected illegal or unethical behavior or participates in an investigation. Confidence in reporting non-anonymously has increased year over year.

Taking action

The Ethics and Compliance Office reviews all reports to the Helpline and Web Reporting, and dedicated staff are tasked with investigations of improper conduct. We also have established corrective action procedures for review of substantiated improper conduct by a multi-disciplinary team of leaders.

Training

The Ethics and Compliance Office develops an online training curriculum for all employees covering the Code, ABAC Policy and other policies and topics, such as anti-harassment and discrimination, diversity, equity and inclusion, cybersecurity, and workplace violence.

Timely completion of assigned training is required. In addition, certain workgroups receive live training, customized to address relevant scenarios and issues. We continue to strengthen our culture of integrity by issuing company-wide and workgroup-specific communications and questionnaires and increasing employee engagement through quizzes and recognition programs.

Management and Administrative employees are assigned compliance training annually. Frontline employees receive corporate compliance training every other year. Yearly antitrust compliance training and regular communications with employees in antitrust-sensititve areas are further established controls preventing antitrust compliance issues from arising.