Disclaimer and Policies

Disclaimer

The information contained in this Web Site or referred as www.jetprivilege.com is only for general information about Jet Privilege Pvt. Limited, its subsidiaries* and associates* (hereinafter referred to as ‘JetPrivilege’) and the services that they offer and is not in any way binding on JetPrivilege. It does not constitute advice and should not be relied upon in making or refraining from making any decision.

JetPrivilege hereby excludes any warranty (either express or implied) as to the correctness, completeness, timeliness, accuracy, fitness for a particular purpose of the Web Site or any of its contents.

By accessing this Web Site you agree that JetPrivilege will not be liable for any direct or indirect or consequential loss, damages or compensation arising from the use of the information and material contained in this Web Site or from your access of other material on the internet via web links for this Web Site.

Unless otherwise stated, copyright or similar rights in all material contained in this Web Site is owned by JetPrivilege. Your access to it does not imply a free license to use it unless permitted by law.

* Will apply as and when such entities come into existence

Disclaimer for Social Networking

The JetPrivilege Social Media Space on Facebook, Twitter, YouTube, LinkedIn, Pinterest, Instagram or any other social networking channels has been created to provide our fans and followers with an opportunity for discussions related to JetPrivilege Products and Promotions. All content, comments, videos, visuals, images and any other material posted/tagged by users on this site does not necessarily reflect the opinions or ideals of Jet Privilege Pvt. Limited, its employees or its affiliates.

JetPrivilege does not endorse any statements, external product claims made on this site nor warrants the accuracy of any information thereof and is not responsible for any user generated content put up on these spaces /site.

All users must comply with the Terms of Use of Facebook, Twitter, YouTube, LinkedIn, Pinterest, Instagram or any other social networking channels and JetPrivilege Terms of Use for the JetPrivilege Facebook, Twitter, YouTube, LinkedIn, Pinterest and Instagram or any other social networking channels page(s) & account(s).

JetPrivilege expects that users will not post any content / materials that may fall into any of the following categories:

  • Abusive, Defamatory or Obscene
  • Fraudulent, ambiguous or misleading
  • In Violation of Intellectual Property of another
  • In Violation of Facebook/Twitter/YouTube/LinkedIn/Pinterest/Instagram or any other social networking channels’ respective Terms of Service
  • In violation of any law or regulation (including rights of privacy and publicity)
  • Offensive in any other way

JetPrivilege reserves exclusive right to remove any such material / content that may fall under JetPrivilege the aforementioned categories. Only that content which is relevant to the topics discussed on this page will be allowed to stand.

US rule for non-discrimination on the basis of disability

A full copy of rule is available for viewing on request at our airports serving the US.

Contact the US Department of Transport directly using the following methods:

  • For calls made from within the United States, by telephone via the Toll-Free Hotline for Air Travelers with Disabilities at 1-800-778-4838 (voice) or 1-800-455-9880 (TTY)
  • By telephone to the Aviation Consumer Protection Division at 202-366-2220 (voice) or 202-366-0511 (TTY)
  • By mail to the Air Consumer Protection Division, C-75, U.S Department of Transport, 1200 New Jersey Ave., SE., West Building, Room W96-432, Washington, DC 20590
  • On the Aviation Consumer Protection Division Wesite: www.dot.gov/airconsumer

Whistle Blower Policy

PREAMBLE

This policy is formulated to provide opportunity to employees and directors of the Company to have access in good faith, to the Ethics and Compliance Office in case they observe unethical and improper practices or any other wrongful conduct in the Company. This policy protects such employees from any adverse action being taken against them.

APPLICABILITY:

This policy applies to all permanent Jet Privilege employees and directors of the Company.

POLICY:

In line with our vision and values, which we cherish in our organization and as a part of Good corporate governance, this Whistle Blower Policy has been formulated. The Policy is meant to encourage employees to report to the Ethics and Compliance Office for addressing and redressing if they observe unethical and improper practices or any other wrongful conduct in the Company.

No adverse personal action shall be taken or recommended against an employee in retaliation to his disclosure in good faith of any unethical and improper practice or alleged wrongful conduct. This policy protects such employees from unfair termination and unfair prejudicial employment practices.

However, this policy does not protect an employee from an adverse action which occurs pursuant to poor job performance, or any other disciplinary action etc. unrelated to his disclosure in good faith of any unethical and improper practice or alleged wrongful conduct.

ALLEGED WRONGFUL CONDUCT

Alleged Wrongful Conduct shall mean violation of law, infringement of Company's Code of Conduct or Ethics policies, mismanagement, misappropriation of monies, actual or suspected fraud, substantial and specific danger to public health and safety or abuse of authority.

Alleged wrongful conduct as illustrated below may include but is not limited to:

  • Forgery, falsification or alteration of documents
  • Unauthorized alteration or manipulation of computer files and data
  • Fraudulent reporting or willful material misrepresentation
  • Pursuit of a benefit or advantage in violation of the Company's interest
  • Misappropriation/misuse of Company's resources, like funds, supplies, vehicles or other assets
  • Authorizing/receiving compensation for goods not received/ services not performed
  • Authorizing or receiving compensation for hours not worked
  • Improper use of authority
  • Unauthorized release of Proprietary Information
  • Accepting kickbacks, bribes, expensive gifts, directly or indirectly from business connections including vendors & contractors
  • Theft of cash
  • Theft of Goods/Services
  • Unauthorized Discounts
  • Falsification, Destruction of Company Records
  • Fraudulent Insurance Claims
  • Harassment
  • Providing (unauthorized) confidential information to external agencies

RESPONSIBILITY

Responsibility for administering this Policy lies with the Ethics and Compliance Office. Oversight responsibility rests with the President and Chief Executive Officer, Audit Committee, and ultimately the Board of Directors.

The Ethics Committee comprises the Senior Vice President Audit, Compliance and Risk (Chair), Chief People and Performance Officer, and the General Counsel. Senior personnel from other departments such as Finance and Corporate Security may also be requested to attend when required.

INVESTIGATIONS

Etihad takes breaches of the Code of Business Conduct seriously and is committed to conducting thorough but confidential investigations of all allegations. Once a concern has been raised, an early decision will be made on the department that is best placed to conduct or manage the investigation. The Compliance Office or Corporate Security departments will typically be the first choices.

Employees who are being investigated will be given an opportunity to be heard before a final decision is made on their case.

DECISIONS

At the conclusion of an investigation, the Ethics Committee will decide on the appropriate disciplinary action to be taken (if any) for Code violations. Where the violation falls within the Fraud Control Policy the Committee’s role shall be limited to making a recommendation for disciplinary or other action to the President and Chief Executive Officer of Etihad Airways.

Disciplinary action linked to the final outcome of investigations may include prosecution, termination of employment, suspension, demotion, or loss of benefits and will depend on the circumstances of each case.

REPORTING OF INVESTIGATION RESULTS

The Ethics and Compliance Office periodically reports the results of all Code investigations and disciplinary action taken to senior management, the President and Chief Executive Officer, and the Audit Committee. Representative samples of actual breaches of the Code, with personal identifying details removed, will also be posted on the Ethics and Compliance website to raise awareness amongst all employees of the ethical issues encountered within the company.

THE ETHICS AND COMPLIANCE OFFICE

The Compliance office is available to answer any questions you may have on the Code of Business Conduct or company policies and procedures, or to discuss any concerns you may have about potential Code violations.

To contact the Compliance Office, Call +971 (2) 511 1100 Email:ethicscompliance@etihad.ae By post: The Ethics and Compliance Office, Internal Audit Etihad Airways Head Quarters Khalifa City ‘A’ PO Box 35566 Abu Dhabi United Arab Emirates

ACKNOWLEDGEMENT

All employees must acknowledge that they have read and understood this Code of Business Conduct, and that they will abide by its provisions. Similar certifications will be required of all employees periodically.

Failure to complete this acknowledgment does not absolve any employee of any breaches of the Code of Business Conduct.

GOOD FAITH

An employee shall be deemed to be communicating in `good faith' if there is a reasonable basis for communication of unethical and improper practices or any other alleged wrongful conduct. Good Faith shall be deemed lacking when the employee knew or reasonably should have known that the communication about the unethical and improper practices or alleged wrongful conduct is malicious, false or frivolous.

MANAGERIAL PERSONNEL

Managerial Personnel shall include a Director, all Executives at the level of Manager and above, who has authority to make or materially influence significant personnel decisions.

UNETHICAL AND IMPROPER PRACTICES

Unethical and improper practices shall mean -

  • An act which does not conform to approved standards of social and professional behavior;
  • An act which leads to unethical business practices;
  • Improper or unethical conduct;
  • Breach of etiquette or morally offensive behaviour, etc.

WHISTLE BLOWER

An employee or director of the Company who discloses in good faith any unethical & improper practices or alleged wrongful conduct to the Ethics and Compliance Office

GUIDELINES

Internal Policy & Protection under Policy

This Policy is an internal policy on disclosure by employees of any unethical and improper practices and access to the Ethics and Compliance Office This Policy prohibits the Company from taking any adverse action against its employees for disclosing in good faith any unethical & improper practices or alleged wrongful conduct to the Ethics and Compliance Office Any employee against whom any adverse personnel action has been taken due to his disclosure of information under this policy may approach the Ethics and Compliance Office

False Allegation & legitimate Employment Action

An employee who knowingly makes false allegations of unethical & improper practices or alleged wrongful conduct to the Ethics and Compliance Office shall be subject to disciplinary action, up to and including termination of employment, in accordance with Company rules, policies and procedures. Further, this policy may not be used as a defense by an employee against whom an adverse personal action has been taken independent of any disclosure of information by him and for legitimate reasons or cause under Company rules and policies.

Disclosure & Maintenance of Confidentiality

Confidentiality of the Whistle Blower shall be maintained to the greatest extent possible.

PROCEDURE

A perceived wrongdoing or an act for Whistle Blowing may be reported by a Whistle Blower through a telephone hotline service run by an experienced and independent third party company called Expolink

The Expolink telephone hotline service can be used to report matters such as theft, fraud or damage to property by managers, colleagues or suppliers. Issues could also be more personal to you, such as discrimination, bullying or harassment.

One can raise issues in complete confidence. Your call will not be traced or recorded and you won’t be asked your name, although you are encouraged to provide it.

Calls are taken by Expolink’s experienced and independent staff who are specially trained to handle these calls. The information you provide will be passed to a senior manager who will act on it without compromising you in any way.

The hotline is available 24 hours a day, seven days a week and the free telephone number to call if you are in India is 000 800 440 1286. Expolink will give you a unique code number in case you wish to phone back with more information.

PROTECTION OF THE WHISTLE BLOWERS

The Management assures full protection to a Whistle Blower from any kind of harassment, victimization or unfair treatment and redress any Advance Personal action taken against the Whistle Blower. The decision of Ethics Committee shall be final and binding. If and when the Ethics Committee is satisfied that the alleged unethical & improper practice or wrongful conduct existed or is in existence, then the Ethics Committee may –

a) Recommend to the Managing Director to reprimand, take disciplinary action, impose penalty, punishment, and order recovery when any alleged unethical & improper practice or wrongful conduct of any employee is proved.

b) Recommend termination or suspension of any contract or arrangement or transaction vitiated by such unethical & improper practice or wrongful conduct. Managing Director shall pass necessary orders in consultation with HR / Head of Department concerned.

NOTIFICATIONS

All employees shall be informed about the policy by the HR department and statement in this regard should be periodically submitted to the Compliance Officer.

This policy as amended from time to time shall be made available on http://www.jetprivilege.com/

RETENTION OF DOCUMENTS

All Disclosures in writing or documented along with the results of investigation relating thereto shall be retained by the Company for a minimum period of 3 years

AMENDMENT

The Company through its Audit Committee reserves its right to amend or modify this Policy in whole or in part, at any time without assigning any reason whatsoever. However, no such amendment or modification will be binding on the employees unless the same is notified to the employees in writing.

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