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May 2008

Code of ConductEthical rules and guidelines for the SAS Group


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Content

3. Introduction

8. Customers

10. Employees

14. Security, theft & loss

16. The society around us20. Environment

22. Shareholder influence &transparency

24. Reporting

26. Insider trading

28. Doing business

32. Communication &dialogue

34. Conflicts of interest

36. Infringements &reporting

Code of Conduct 1


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Introduction

As a business, it is important that we are soundly profitable. That

is essential if we are to survive. It is important that we develop

the business, and that we develop ourselves and all the functions

we perform, in order to secure our future. It is important that we

communicate, learn and adapt to the world around us that we both

serve and make our living from. The world around us is extensive

and varied. As are our customers, colleagues, partners and all

those with whom we are in contact in one way or another.

Companies are playing an increasing role in social development,

both locally and globally. And at the same time, those around us

are demonstrating a growing interest in knowing how businesses

conduct themselves.

At SAS, we want to be open and are interested in showing that

we are honest in our actions and that we meet the requirements

of the world around us. As a workplace, SAS is our shared pivot

point for thousands of different situations in which we have to

make decisions, carry out routine jobs, establish contacts, answer

enquiries, show understanding, maintain an overview, perform

tasks competently and act according to the situation in which we

find ourselves.

The key to developing the SAS Groups reliability and

competitiveness is to demonstrate a high level of continuity,

objectiveness and openness. Ethics and the way we act are

two sides of the same coin. As a business we have a great

responsibility, and we all help to meet this responsibility. This

Code of Conduct summarizes the rules, values and policies that we

share. Every employee should know these and work according to

the principles described.

Code of Conduct 32 Code of Conduct


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Complying with applicable laws and regulations goes without

saying and is an absolute requirement. In certain cases, this

Code of Conduct which contains rules for our business conduct

and responsibilities towards colleagues, customers, suppliers,

shareholders, authorities and the world at large goes further,

and it is to be applied Group-wide.

On April 28th, 2008 the Board of Directors of SAS AB, the parent

company of the SAS Group, adopted this Code of Conduct. The

Code will be reviewed annually and may be amended at any timeby the Board.

The Board has the overall responsibility for implementing the

Code of Conduct and monitoring compliance with it.

All employees have a responsibility to understand and follow

this Code of Conduct. Violations may result in disciplinary action

including possible termination of or dismissal from employment.

SAS has established a reporting system in case of suspicion

of infringements. If normal ways of reporting cannot be used,

everybody has the right and duty to inform the Groups code

responsible about unlawful or other serious infringements.

This whistleblowing-function can be used via e-mail:

[email protected] Read more about it on page 36.

The SAS Groups values. The Code of Conduct is based on SAS

common values, which form the basis for our actions towards all

stakeholders as individuals and groups.

Application and compliance

This Code of

Conduct contains

rules and guidelines

for our relations with

one another at work,in our business

relationships and

with the world

around us.

It is a matter of

responsibility,

confidence and

trust!

Code of Conduct

Consideration: We care about our

customers and employees and

acknowledge our social and

environmental responsibilities.

Reliability: Safe, trustworthy and

consistent in word and deed.

Value creation: A professional

businesslike approach and

innovation will create value for our

owners.

Openness: Open and honest

management focused on clarity for

all stakeholder groups.

Values

Code of Conduct 5


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Our shared responsibility!You are holding in your hand (or reading online) a new version

of the SAS Groups Code of Conduct a document that concerns

our common rules on business ethics and our approach. Thefirst edition of our Code of Conduct was issued in 2005. Since

then, both the Group and the world around us have undergone

various changes, so we are now issuing a somewhat revised

version of the Code. The Code has also been supplemented

with a web-based training program that you can access via

www.sastraining.com

Our brand, SAS, is one of our greatest assets by far. It is

therefore of utmost importance that we all - our Board of

Directors, myself, the entire management and all employees -

respect the rules and attitudes described in the Code. It is also a

very important part of our culture.

As in all companies, it is not just our ability to meet our

customers needs that is important. The outside world judges usjust as much on how we do so, and how we earn our money.

I want to encourage you to study the Code, to go through the

training program on the web and to discuss the dilemmas

presented there with your colleagues.

Stockholm, May 2008, Mats Jansson, President and CEO

Code of Conduct Code of Conduct 7


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Customers

We are always focused on our customers and take care of their

interests.

Our attitude towards customers is to be characterized by quality,

respect and dialogue in all situations. By this we mean:

Safety. Safety always has top priority for the SAS Groups

operations. With regard to flight safety, all flights are to beoperated with safe aircraft and other equipment, qualified

personnel and in accordance with applicable laws and

regulations. All employees are obligated to report non-

conformance with the adopted standards, rules and procedures

to ensure that relevant actions are taken and to help bring about

continual improvements in safety work.

Punctuality. It is the duty of all employees in every affected

business in the SAS Group to take an active part in achieving our

punctuality and regularity targets.

Service commitment. Every promise to a customer is a

commitment we aim to take seriously in all situations. The SAS

Group is engaged in an ongoing dialog with customers and wecontinuously measure and follow-up on customer satisfaction.

Through an increased focus on the customer and the service we

promise, we maintain our customers loyalty to and trust in our

brand.

We take our service

commitment

seriously and take

responsibility

for meeting the

customers demands

for quality and

choice.

Code of Conduct Code of Conduct 9


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Employees

Key words. Our employees are our most valued resource.

Competence, motivation and commitment are vital, both when

meeting customers and for creating a favorable working climate.

The key words of our human resource policy are:

Trust. All relat ions are to be based on honesty, loyalty,

consideration and respect.

Change. Work methods are to be characterized byunderstanding, acceptance and a positive attitude towards

change.

Opportunities. All employees shall be given the opportunity to

affect, develop and improve their skills to achieve their own as

well as the Groups targets.

Responsibility. All employees have a shared responsibility for

their own and the Groups development.

Leadership. Our managers shall be committed to the SAS Group

values, and our leadership style shall be

Consistent

Straightforward

Reliable

Our managers also have a very important task to fulfill

in contributing to and developing the business. The SAS

Leadership Profile states that: The SAS leader delivers

commercial results based on customers needs through

cooperation and by mobilizing and developing staff. This

leadership style and profile form the basis for our managers

to encourage everyone to use their creativity, initiative and

commitment.

All employees

have a shared

responsibility for

their own and

the SAS Groups

development.

0 Code of Conduct Code of Conduct 11


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Diversity. The aim of the SAS Groups social composition is to

reflect the diversity of the community. In all recruitment, human

resources development, promotions and other interactions,

the SAS Group assumes the equal worth of all persons. All

employees and job applicants are to be treated according to

formal, objective criteria. No one working, or applying for a job,

in the SAS Group may be discriminated against or preferred on

the basis of age, gender, ethnic background, nationality, religion,

sexual orientation, disability, political conviction or social status.

Nor do we accept physical, psychological, verbal or sexual

harassment. Related to diversity and equality and with respect

for collective bargaining agreements, the principle of equal pay

for equal work applies.

Right to organize. The SAS Group respects its employees rights

to join associations and organizations and to organize unions

and, in line with national law and practice, conclude collective

bargaining agreements.

Working environment. In all our operations we give high priority

to employees health and safety. This concern for safety pertains

all forms of working environment. No employee should haveto suffer physically or mentally at his or her workplace. The

manager is responsible for his or her team, group or department,

but all involved are committed to cooperating and striving for

continuous improvements and to preventing all kind of damage

and injuries.

The SAS Group policy allows smoking in designated areas only

and never if co-workers or others consider it a nuisance.

All employees

shall be familiar

with, respect and

take seriously

the SAS Groups

zero tolerance

of all forms of

discrimination.



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Security, theft & loss

The aim of our security work is to protect SAS property and

the use of our systems as well as to reduce the risk of illegal

encroachment, sabotage, damage, interruptions, hacking or

other acts that may result in losses in any form.

IT security. Security aspects refer to materials and equipment

as well as information and expertise. It is incumbent upon all

employees to maintain high standards in their security work,

which includes controlling and handling passwords and PINcodes on computers and mobile units. It is not permitted to

use work tools such as computers and mobile phones or our

communication system to prepare, send, receive, store, print

out or otherwise disseminate information that is false, illegal,

harassing or otherwise incompatible with professional conduct.

All employees are responsible for using the companys

information and communication systems properly and in

accordance with IT policies. Personal use must not impede or

reduce an employees ability to perform service and production

or affect the company or its reputation in any adverse way.

Theft and loss. Crime in all its forms, such as theft, loss,

embezzlement or fraud, is unacceptable and will lead to

disciplinary measures that may result in termination ofemployment or dismissal. In addition, such acts may be reported

to the police.

Crime can be multifaceted. That is why we work actively to inform

about, prevent, uncover and prosecute crime in all aspects of

our operations. The SAS Groups policy on these issues has

been developed in accordance with national and international

legislation in this area.

We work actively

to inform about,

prevent, uncoverand prosecute crime

in our operations.



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The society around us

Good corporate citizen. The SAS Group endeavors to act

responsibly in all countries and contexts where the Group

operates. This means, among other things, that the Group is

always interested in developing dialog and interaction with

stakeholders and society.

Sustainability work. To contribute to sustainable development,

employees must, in their daily work, take the SAS Groups

environmental and social impact into account in addition to its

financial performance. Better resource management and a lower

environmental impact lead to higher long-term profitability and

improved competitiveness.

Responsibilities at work. Consuming alcohol at work, or before

going to work, is not compatible with our business.

All use, selling or distribution of illegal drugs at or in the

proximity of our premises is strictly forbidden.

Responsibilities when traveling. During business travel or when

traveling for leisure using our travel benefits we do not allow or

tolerate our employees being involved in or associated with any

kind of activity that involves:

Exploitation of persons, such as the purchase of sexually

related services

Import or export by sale or distribution of illegal objects or

dutiable/taxable goods

In general, SAS Group employees should at all times avoid acts

or behaviors that could compromise, embarrass or jeopardize

his/her own goodwill and image or that of SAS. Commercial

activities in connection with the use of private travel benefits are

against our rules and regulations.

We must

take the SAS

Groups financialperformance into

account as well as

its environmental

and social impacts

on the community.



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UN Global Compact. In June 2003 the SAS Group signed

the UN Global Compact. This program is for companies and

organizations that want to be a part of the international work to

advance ten universal principles in the areas of human rights,

labor standards, environmental challenges and anti-corruption.

By being committed to social issues and by joining the UN

Global Compact, the SAS Group has pledged in all activities to

defend and promote human rights and to combat corruption,

discrimination and all forms of forced labor. You can read more at

www.unglobalcompact.org



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Environment

Environmental consideration. The Groups most significant

environmental impact is the consumption of nonrenewable

energy. In the air and on the ground the SAS Group aims to

minimize its environmental impact and optimize resource

management by reducing emissions, reducing consumption

of energy and water, reducing noise and treating waste as a

resource, among other measures.

SAS aims to create responsible and sustainable traffic growth,

while reducing environmental impact.

We aim to be leaders in sustainable development efforts in

the airline industry and thereby contributing to sustainable

society development. SAS has one of the airline industrys

most ambitious long-term environmental programs, and the

environmental targets are measured through each companys

environmental efficiency index.

In the SAS Group we are also working actively to create

awareness based on interest in and commitment to

environmental efforts among all employees. SAS expects that all

employees show respect for the environment in daily work.

The SAS Group

takes the climate

threat seriously

and has adopted

an ambitousenvironmental

strategy.



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Shareholder influence &

transparency

Corporate Governance. Well-functioning corporate governance

principles are essential for assuring shareholders that the SAS

Groups activities are characterized by reliability, transparency

and effective internal and external control.

The SAS Group will apply principles and guidelines that ensure

the adequate dissemination of information to shareholders, real

shareholder influence and effective management and Board

work. The SAS Group is constantly adapting new principles to its

needs in compliance with applicable corporate governance codes

and regulations.

Transparency in

the governance

of the SAS Group

is absolutely vital

for the Groups

reputation and

credibility.



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Reporting

The SAS Group publishes an annual report containing

economical results, data and information about all Groups and

companies activities.

The SAS Group must comply with all security and exchange

legislation as well as listing agreements and other exchange

rules in Denmark, Norway and Sweden. The SAS Group aims

to deliver quick, timely, correct and relevant information to

shareholders, the community and media and to work for an

active, open dialog with the market. Communication with

analysts, investors and general capital markets is handled at

Group level and must not be engaged in at subsidiary level

without special authorization.

Market-sensitive information. The SAS Group has explicit

routines for how market-sensitive information is to be made

public and by whom. If these routines are breached by

individuals this will have consequences.

Reporting principles. The SAS Group has strict standards and

principles regarding the reporting of financial information and

has deployed internal control functions.

Sustainability reporting. As an integral part of its annual

reporting the SAS Group reports its sustainability development.

This includes corporate social responsibility reporting based

on internal as well as external guidelines, with the purpose of

satisfying different stakeholders needs.

Communication with

the stock market is

conducted at Group

level and must

not be engaged

in at subsidiary

level without

authorization.



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Insider trading

The Board of the SAS Group has laid down rules for insiders and

trading in SAS shares.

Insider information. Insider information refers to information

that has not been made public and that could affect the price of

the share or other financial instruments. You may have access to

insider information even if you are not registered as an insider.

In which case, you may not - either directly or indirectly - buy

or sell shares in SAS AB or in listed companies with which the

SAS Group is negotiating or has a business relationship.

Nor may you disclose insider information to anyone else,

including family or friends.

You may have

access to insider

information even

if you are not

registered as an

insider, in which

case the same

prohibitions against

trading in SAS

shares apply to you.



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Doing business

SAS Group companies and employees must comply with all laws

and regulations that apply to their business activities. Every

employee is obligated to be familiar with or seek out information

on statutory requirements and other legal issues affecting his or

her job tasks.

Competition.The SAS Group supports competition as the basis

of all business development and innovation and has establisheda strict Competition Law Compliance Program, which shall be

complied with by all employees. The SAS Groups companies are

to compete within the framework of each countrys legislation,

applying the Groups codes, standards and policies. Employees

of the SAS Groups companies and business units may not

participate in anticompetitive activities, such as price fixing,

dividing up the market, abuse of a dominant position or in other

contexts where free competition is illegally obstructed, limited or

weakened. In case of doubt, consult your manager or SAS Group

Corporate Legal Affairs.

Purchasing. All purchasing must help to keep costs as low

as possible and have the Groups best interests in mind. In

connection with purchasing, choosing suppliers and ensuringthe best commercial terms are factors impacting the Groups

profitability and competitiveness. All purchasing shall be

done professionally, applying sound ethical principles, high

standards of integrity and in compliance with applicable

legislation and SAS Group policies. Savings are to be achieved

through standardization, binding framework contracts and close

collaboration with selected suppliers.

SAS Group

companies and

employees must

comply with all laws

and regulations

that apply to their

business activities.

The SAS Group

expects its suppliers

and partners to share

its views on these

topics!



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Priority shall be given to suppliers that are certified to ISO 14001

or able to demonstrate that they follow a similar environmental

management system and that work in compliance with the UN

Global Compact.

The SAS Group complies with the UN Convention on the Rights

of the Child and with Save the Childrens guidelines for dealing

with the rights of children and demands the same of its suppliers.Information regarding ongoing purchasing negotiat ions and

possible suppliers shall be treated confidentially.

Receiving or paying bribes and improper perquisites. Each

employees integrity helps to uphold the Groups good name

and credibility in the market. In no circumstances shall the

SAS Groups employees or companies promise, offer or accept

payments, compensation, loans or other financial benefits to,

through or from persons or companies in violation of applicable

laws. Nor is it permitted to use middlemen, agents or other

intermediaries to circumvent the aforementioned prohibitions

against giving or accepting payments or other benefits.

Gifts and entertainment. The Groups employees or companiesmay not promise, offer or accept gifts, entertainment or other

personal benefits or favors to or from persons in violation of

applicable laws or if this can, or may be considered to, affect the

performance of their jobs or the outcome of a business deal.

In case of doubt, consult your manager or SAS Group Corporate

Legal Affairs.

The integrity of all

employees helps to

uphold the Groups

good name and

credibility in themarket.



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Communication & dialogue

A fruitful dialogue is based on openness between the company

and its employees. Communication is a strategic management

tool intended to help convey the SAS Groups strategies and

goals and ensure that they are accepted and realized throughout

the Group. Communication and dialogue with the Groups

stakeholder groups are therefore key aspects of our daily work.

Communication work is to be conducted at a high, professional

level and shall abide by the laws and regulations that apply to

listed companies. In SAS communication is a management

responsibility.

The role of the communication departments is to support

management in effectively communicating with internal and

external audiences.

Individual SAS employees may not, without management

approval, make statements on SAS behalf regarding SAS or its

businesses to the media, investors, financial or trade analysts or

on Internet chat rooms or in other public forums or contexts.

A fruitful dialogue

is based on

openness between

the company and

its employees

and external

stakeholders.



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Conflicts of interestConflicts of interest arise when an individuals objectives do not

coincide with those of the SAS Group and his or her decision may

harm the Group. Employees must therefore report situations

or transactions that may bring about a conflict of interest. If

you suspect that you are or are at risk of being involved in such

a conflict, consult your superior. If he or she cannot or will not

decide, you must contact SAS Group Corporate Legal Affairs.

Conflicts of interest can also arise when a close family member

has a financial or other interest that may affect an employees

judgment to the detriment of the SAS Group.

Business opportunities. You may not, on your own or a family

members behalf, benefit from business opportunities rightfully

belonging to the SAS Group. Nor may you use the Groups informa-

tion, property or your position in the Group for personal gain.

Other employment. You may not have an employer other than

the SAS Group or be involved in business activities outside

the Group if this could adversely impact your work for the SAS

Group. Always consult your superior before accepting other

employment or more extensive engagements.

Service on boards of directors and other external

engagements. If you serve or are asked to serve on a board or

other body outside the SAS Group, make sure that this cannotlead to a conflict of interest. Such engagements require the

formal approval of your superior.

Political activities. The SAS Group does not make any

contributions or give other support, direct or indirect, to political

parties or individual politicians. Nor are you allowed to make

contributions at the Groups expense or to provide assistance in

the form of funds or resources from the Group.

Employees of the

SAS Group are

always to work forthe good of the

Group. Members

of the Board and

executives must set

a good example.



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Infringements & reporting

Conduct or actions that are, or may for good reasons be

perceived as, infringements of laws or this Code of Conduct, are

to be reported. You are encouraged to report any such conduct

or action to your superior, or if the superior is involved or will not

act, to the next level in the organization. We expect superiors/

managers to treat reported matters seriously and in compliance

with the SAS Groups policies and values.

Reporting infringements (whistleblowing). The SAS

Group has established a whistle blowing procedure. Reports

of infringements of laws or non-compliance with this Code

of Conduct concerning, for example, competition law, crime,

accounting and financial reporting, insider trading or serious

conflicts of interest or in situations where managers are involved

or not taking appropriate action on submitted reports may

also be reported to Senior Vice President & General Counsel,

Corporate Legal Affairs, SAS Group. Reports may be made

directly on the SAS intranet. Employees and others can also

report via e-mail: [email protected]

No one shall be discriminated against or punished for reporting

in good faith actual or suspected infringements. Reports willbe treated confidentially and on an anonymous basis, if so

requested.

On the SAS Groups

Portal there is a

page for reporting

infringements of this

Code of Conduct.


SAS AB, May 2008(STODH, STODL, STODP, STODX)

Text, layout & production: CPHPP

in coop eration with SAS Training

CVR-no. 556606-8499

SE-19 5 87 Stockholm

Phone +46 8 797 00 00

www.sasgroup.net

ISO 14001


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Code of Conduct

This Code of Conduct applies to the entire SAS

Group and must be respected by all employees.

The rules in the Code of Conduct are based on theSAS Groups common values.

Documents

CocBookletEngelsk LR Uppslag