Policies in Ethics and governance

Our policies help our people and partners understand the standards we expect, what they can expect of United, and where to go if they identify any problems

United Airlines, Inc. political activity policy

We believe that participating in the political process and policy advocacy in a transparent manner is key to good governance and an important way to promote healthy corporate citizenship. United Airlines Holdings, Inc. and United Airlines, Inc. (together ”United“) participates in the political process and policy advocacy through regular engagement with government officials and policymakers, by making contributions to candidates and organizations and by encouraging political engagement by our employees in order to advocate for the long-term interests of United because of the potential impact public policy can have on our businesses, employees, communities and customers. We advocate for policies that modernize infrastructure, advance industry sustainability goals, rationalize our tax burden, reduce unnecessary regulation, mitigate fuel cost and enhance global competitiveness in the airline industry, among other items.

This policy requires that United’s participation in policy advocacy and the political process comply with all federal, state and local laws and regulations that govern political activities. Additionally, we are guided by our internal Code of Ethics and Business Conduct to engage in policy advocacy in an ethical and transparent manner. All of our policy advocacy, political contributions, lobbying expenditures, and related activities are intended to focus on promoting our business and strategic interests without regard to the personal political preferences or affiliations of any of our directors, officers or employees. From time to time, we may inform our U.S. employees about important legislative issues at the federal, state or local level and encourage them to communicate with their elected officials.

Political contributions

United participates in the political process by making political contributions to candidates, political parties and political committees. All political contributions, and the reporting thereof, comply with applicable laws. United and its company-sponsored political action committee make contributions consistent with our public policy objectives. Contribution decisions are based on meeting one or more of the following criteria:

  • The candidate’s involvement with and position on issues affecting the airline industry
  • The presence of United’s employees, facilities, or resources in the candidate’s district or state
  • The candidate’s demonstrated leadership or potential for leadership
  • The candidate’s committee assignments and seniority within Congress, state or local government
  • The candidate’s alignment with United’s shared purpose and values

No contribution may be given or offered in anticipation or recognition of, or in exchange for, an official act.

United PAC contributions

United has established the United Airlines, Inc. Political Action Committee (the ”UAPAC“) to encourage its employees to participate in the political process. The UAPAC is a voluntary unincorporated organization established pursuant to the Federal Election Campaign Act of 1971, as amended. In accordance with federal law, United’s executives, administrative personnel and stockholders may make voluntary contributions to the UAPAC. Foreign nationals and represented employees may not contribute to the UAPAC. The UAPAC is governed by a board of directors (the ”UAPAC Board of Directors“), which consists of senior leaders from across United. The UAPAC Board also oversees all of United’s corporate political contributions and provides annual reports regarding United’s corporate political contributions to the Public Responsibility Committee of the United Airlines Holdings, Inc. Board of Directors (the ”UAL Board“).

As required by U.S. federal law, we file regular reports that disclose our political contributions. These contribution disclosure reports may be viewed at https://www.fec.gov/data/browse-data/?tab=filings by searching for ”United Airlines, Inc. Political Action Committee.“ We file similar publicly available reports with state and local agencies as required by state and local law.

Corporate political contributions

Federal law prohibits United from contributing corporate funds to candidates for federal office. Accordingly, United does not contribute corporate funds to federal candidates, federal political parties, or federal PACs. United does not make direct independent expenditures urging the defeat or election of a candidate and does not contribute to independent expenditure committees.

United may make contributions to state or local candidate campaigns, parties, political committees, and ballot measures to the extent permitted by applicable law, with the approval of the UAPAC Board of Directors.

We file publicly available reports that disclose our political contributions with state and local agencies as required by state and local law. A list of 2021 corporate political contributions can be found here. We update this information semi-annually.

Corporate trade association memberships and indirect lobbying

As a business that operates in nearly every state and in countries across the world, we are members of a wide range of organizations, from general business associations to others more specific to our industry. As part of our collaborative efforts, United works directly with policymakers as well with coalitions of businesses and NGOs, think tanks, and traditional business trade associations that represent a wide variety of United’s policy interests in the general business community and aviation industry. 

In particular, we belong to a number of industry associations, which we believe gives us a platform to share and receive business expertise and technical knowledge for the betterment of our industry. This involvement also allows us to advocate for policies that encourage a thriving and competitive industry and business environment.

A portion of the support provided to these organizations may be used by the organizations for lobbying, though we have no direct control over how those expenditures are directed. Our primary trade associations advocate for a broad range of issues, including operational efficiency improvements, infrastructure investments, health and safety standards, tax policy, climate strategy and workforce development among others. While our positions may not always fully align with these organizations, we work with them to advance progress where opportunities exist and use our influence with these organizations to advocate for policy changes when needed.

Lobbying expenditures

As required by U.S. federal law, we file quarterly reports that disclose our lobbying expenditures and detail our lobbying activities. These lobbying disclosure reports may be viewed at disclosurespreview.house.gov by searching for United Airlines, Inc. We file similar publicly available lobbying reports with state and local agencies as required by state and local law, which in some cases have even broader disclosure requirements than federal law. Any lobbying firms we hire are required to file similar reports. The trade associations we belong to are also subject to public disclosure obligations regarding their lobbying efforts.

Annually, we publish a list of member organizations where our dues and other contributions used for lobbying activities exceed $25,000. In fiscal year 2021, there were four trade associations that received in excess of $25,000 from United in annual dues used for lobbying activities:

  1. Airlines for America (A4A)
  2. Business Roundtable (BRT)
  3. International Air Transport Association (IATA)
  4. U.S. Chamber of Commerce

Accountability and oversight

United and its subsidiaries are committed to the highest ethical standards and we have procedures and policies in place designed to ensure that our policy advocacy, political contributions, and lobbying expenditures and related activities are subject to appropriate oversight. We take diligent steps designed to ensure that we are in compliance with applicable rules and regulations and our Code of Ethics and Business Conduct, which is publicly available on our website at ir.united.com. At least annually, the Public Responsibility Committee will review this policy and recommend any revisions it deems necessary or appropriate to the UAL Board.

Oversight over lobbying activity

Our policy advocacy and lobbying activities are determined by senior management with oversight by the UAL Board, which has delegated this oversight responsibility to its Public Responsibility Committee. Our Government Affairs and Global Public Policy organization oversees and executes our policy advocacy, lobbying expenditures and related activities. Our Senior Vice President, Government Affairs and Global Public Policy, also reports regularly to the UAL Board on our policy advocacy, lobbying expenditures and related activities, periodically reviewing with the Public Responsibility Committee the strategic priorities for United’s lobbying activity.

Oversight over political contributions

The UAL Board has delegated oversight responsibility of our political contributions to its Public Responsibility Committee. Our Government Affairs and Global Public Policy organization makes recommendations on political contributions to the UAPAC Board of Directors, who in turn reviews and approves all UAPAC and corporate political contributions. Our Senior Vice President, Government Affairs and Global Public Policy provides the Public Responsibility Committee an annual report on political contributions of the Company and the UAPAC for the prior year.

Human rights

As a global enterprise, United acknowledges and respects the guiding U.S. and international principles on human rights. United’s Human Rights policy statement and Global Policy on Worker Welfare reflects our commitment to conducting our business in a manner consistent with these principles including, for example, the principles reflected in the Universal Declaration of Human Rights issued by the General Assembly of the United Nations. United supports and respects internationally proclaimed human rights and is not complicit in human rights abuses. United’s core values and culture embody a commitment to ethical business practices and good corporate citizenship.

This Human Rights policy statement and Global Policy on Worker Welfare is consistent with our broader commitment to ethical business practices, which are embodied in the Code of Ethics and Business Conduct. The Code serves as the cornerstone of the company’s ethics and compliance program. United has appropriate mechanisms in place to monitor compliance with the Code and facilitate reporting of possible violations.

As discussed in the Code and the Working Together Guidelines, United is an equal opportunity employer committed to providing its employees with a non-discriminatory work environment that promotes open and honest communication and embraces dignity, respect and diversity in all aspects of its business operations. United further supports the elimination of all forms of forced, bonded or compulsory labor, as well as the freedom of association. As reflected in our Anti-Bribery/Anti-Corruption Policy, United prohibits all forms of corruption and bribery.

United condemns all forms of exploitation of children. The company does not recruit child labor and supports the elimination of exploitative child labor. United also supports laws duly enacted to prevent and punish the crime of sexual exploitation of children and will cooperate with law enforcement authorities on these matters.

Human trafficking awareness

As part of our commitment to human rights, United has increased its efforts to support the global fight against human trafficking. We have implemented targeted internal policies and procedures across many of our business functions where we believe we can make the greatest impact, particularly in the areas of training of our frontline employees on recognizing and reporting suspected human trafficking and establishing fair labor standards in the procurement process for our supplier relationships and subcontractors for our government contracts.

In conjunction with the Blue Campaign initiated by the Department of Homeland Security (”DHS“), we have been a partner with DHS, Customs and Border Protection (”CBP“) and the Department of Transportation in the Blue Light Initiative. Beginning in 2016, we have provided mandatory human trafficking awareness and reporting procedure training to our flight attendants, and in 2019 we expanded this mandatory annual training to include our front-line agents, who provide customer service at various stages in the check-in and boarding process. Since 2018, we have provided over 52,000 employees with human trafficking awareness and reporting procedure training. Our hope is that, with this training, our frontline employees will be equipped with the tools and resources to be able to identify potential signs of human trafficking and can then involve the appropriate law enforcement officials for further investigation. We acknowledge the role that the transportation industry plays in eliminating human trafficking and we are committed to doing our part to help put an end to the human trafficking crisis.

In addition to our human trafficking awareness and reporting procedure training, we have established certain procedures in our procurement processes that are designed to help ensure that our suppliers and subcontractors are also complying with applicable laws and held to the same standard set forth in our Human Rights policy statement and Global Policy on Worker Welfare. For example, we have added certain provisions regarding fair labor practices to our supply contracts, including provisions that require our counterparties to provide notice if they become aware of any non-compliance with applicable fair labor laws. We also conduct due diligence with respect to our counterparties and their operations, which can include third party reputation analyses and site checks. Looking ahead, we are working on a new initiative to adopt a supplier code of conduct to ensure our suppliers understand our commitments to integrity and our expectations with respect to those with whom we do business.

United’s Code of Ethics and Business Conduct

For more information on our Code of Ethics go to the Ethics and Compliance page of this report. 

Diversity, Equity and Inclusion (DEI) policy

For more information on our approach to DEI go to the DEI pages of this report and go to our dedicated DEI site.

Environmental sustainability commitment

For more information on environmental sustainability at United go to the sustainability pages of this report.