Royal Dutch Airlines 1KLM CODE OF CONDUCT March 2007 INTRODUCTION KLM Royal Dutch Airlines and its subsidiaries (jointly “KLM”) value the reputation of being a reliable airline. Being a reliable airline means integrity in conduct and excellence in operating businesses. This KLM Code of Conduct (the “Code”) contains rules relating to KLM operating its businesses and to working with KLM. The Code is designated to set a conduct standard and to provide guidance to the members of the Supervisory Board of KLM Royal Dutch Airlines (the “Supervisory Board”), the Board of Managing Directors of KLM Royal Dutch Airlines (the “Board of Managing Directors”), the KLM executives and any and all other KLM employees, including hired staff, (all of the persons mentioned above will hereinafter individually and together be referred to as the “employee” or “employees”) in complying with ethical and legal obligations. Doing business in an ethical manner is vital to KLM’s reputation and success. The standards and guidelines in the Code are and may be further implemented by category-specific policies and procedures as referred to throughout the Code. These policies and procedures form an integral part of the Code. The Code will be reviewed by the Board of Managing Directors on a regular basis and revised if necessary. The Code does not replace or limit any obligations placed upon employees by their (collective) labour agreement and/or applicable laws. The Code cannot address in detail every possible problem or decision. Good judgement, integrity, sensitivity to what is right and a strong desire to do nothing that violates the (spirit of) the Code or might bring discredit upon KLM will be the main sources of guidance. QUESTIONS At any time, including before taking any action or making a (business) decision, that you have any questions concerning the contents, clarification, guidance and assistance with regard to this Code, please contact KLM’s Compliance Officer, the Company Secretary (AMS/DS), KLM’s Privacy Officer (AMS/PI) or KLM’s Legal Department (AMS/DJ). Do not be afraid to ask, if you are uncertain what to do.
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