Business Integrity Program

1. Introduction

1.1 Purpose of the Business Integrity Program

AEROLINEAS ATA CARGO SPA considers the implementation and practice of its values a fundamental challenge; to achieve this, it is important that all employees understand our position on Ethics.

The purpose of this program is based on the following reasons:

• It is a good tool to ensure that we know and live our values as a company, and that our entire team is clear about the behavior expected of us.
• This program and the mechanisms it establishes are tools to help us in our daily conduct.
• To demonstrate our integrity, which speaks to what we do, who we are and what we project, even when no one is watching.
• Doing the right thing sometimes takes courage, and if we put this in writing and communicate it well, our team will know that we are all in this together, committed to doing what is right.

1.2 Scope of the Integrity Program

This Program applies to all of the company's employees, regardless of their activities and responsibilities. In addition, AEROLINEAS ATA CARGO SPA seeks and encourages its stakeholders to act in accordance with the guidelines contained in this program.

1.3 Main ethical responsibilities

• Always comply with the law, this Integrity Program and the internal rules of AEROLINEAS ATA CARGO SPA.
• Lead with integrity and always by example.
• Maintain a healthy work environment that encourages ethical behavior and an atmosphere of trust in which people feel comfortable asking questions and reporting ethical concerns without fear of retaliation.
• Ask before acting if you have any doubt, report what is wrong and cooperate with AEROLINEAS ATA CARGO SPA investigations.

If you have any questions, you can always turn to Human Resources Management, the HR department or its representative.

1.4 Exceptions

Although this program applies to all of us, in very exceptional cases a waiver of its application may be requested, provided this does not compromise our integrity.

Requests must be submitted in writing to Management and/or the HR department, in advance of the conduct for which approval is sought, and they must respond in writing to the requester.

2. Our vision

This Program is built on our institutional purpose and values. If we direct our decisions toward fulfilling the Purpose of AEROLINEAS ATA CARGO SPA and act by putting its Values into practice, we strengthen corporate integrity. We live our Purpose by always acting in accordance with our four values:

• Trust: We believe in our team and in empowering people. Trusting one another and being positive and ambitious are traits that inspire everyone to contribute to growth.
• Responsibility: We recognize and respect our commitments, our environment and our employees. We want to be a force that drives positive change.
• Unity: Camaraderie is a fundamental part of the AEROLINEAS ATA CARGO SPA culture. We act united by our goals and projects.
• Excellence: We are passionate about what we do and strive to improve every day.

3. Integrity organizational structure

To ensure that our commitment to ethics works, AEROLINEAS ATA CARGO SPA has an organizational structure that allows us to properly disseminate our values and educate employees and stakeholders of AEROLINEAS ATA CARGO SPA in order to professionally manage all inquiries and reports received.

3.1 HR Management

This is the area responsible for ensuring the proper functioning of our Ethics Program and faithful compliance with the Integrity Program, handling inquiries, reports and investigations professionally and confidentially. In addition, it will develop training and awareness campaigns to guide employees on our ethics.

3.2 Integrity Advisors

We will have certain employees who specialize in the program and are therefore trained to advise us on integrity matters, clarifying doubts and concerns and confidentially channeling any reports made to them.

3.3 Ethics Officer

This is the employee appointed by the General Manager to act as liaison between the company and HR Management.

4. Integrity channel

When making a decision, we may have ethical doubts. On other occasions, we may have doubts about the integrity of other employees' conduct, or we may have learned that a crime or unlawful act has been committed within AEROLINEAS ATA CARGO SPA.

This information is very important to AEROLINEAS ATA CARGO SPA in order to properly guide the conduct of its employees or sanction conduct that breaches the law, our internal rules or the Integrity Program.

AEROLINEAS ATA CARGO SPA provides the following means through which we can contact HR Management directly:

• Direct access via website: www.aerolineasata.cl
• Toll-free phone number: +56 9 5401 0256
• Email: mguerra@aerolineasata.cl
• In person, by going directly to the HR Management offices.

It is important to note that all information received by AEROLINEAS ATA CARGO SPA through the various Integrity Channel means will be treated in strict confidence, protecting the identity of the whistleblower, the accused and everyone involved in an investigation, as well as all related data. Everyone who becomes aware of an ethics case also has a duty to maintain the utmost confidentiality.

Likewise, an employee or third party may, with due seriousness and responsibility, file a report anonymously.

5. Procedure and safeguards for raising ethical concerns

5.1 Questions

AEROLINEAS ATA CARGO SPA wants all employees to understand this Integrity Program very well. That is why we have specialists to resolve any doubt or concern.

All inquiries are important and will therefore be handled professionally, promptly and confidentially.

Questions, doubts or concerns may be raised directly with the Integrity Advisor or HR Management, using any of the Integrity Channel contact means.

5.2 Reports

We all build corporate integrity, day by day. That is why your contribution is vital, not only through your own ethical conduct but also by reporting situations that depart from expected behavior.

If you become aware of or witness a breach of the Integrity Program, AEROLINEAS ATA CARGO SPA expects you to report it so the situation can be investigated and any necessary measures taken. Every report will be handled by HR Management and investigated confidentially, protecting the identity of the whistleblower, those who provide testimony in an investigation and all data related to the investigation.

Remember, failing to report a breach of the Integrity Program can be as harmful as the breach itself. That is why it is important to use the various Integrity Channel contact means to provide this kind of information. Don't hold back from asking or reporting thinking someone else will. If you see something wrong, report it.

5.3 No retaliation

It is important to AEROLINEAS ATA CARGO SPA to receive all ethical concerns employees may have, in order to respond to their questions. For employees to come forward freely, it is essential to have an environment where everyone feels confident raising concerns without fear of harm or retaliation.

Retaliation means any conduct that negatively affects an employee because they raised a concern or report in good faith or cooperated in an ethics investigation.

Retaliation against employees who raise ethical concerns will never be tolerated and will be considered a serious breach of the Integrity Program. Therefore, once retaliatory conduct has been proven, measures will be taken against the employee who committed it.

That said, AEROLINEAS ATA CARGO SPA expects employees to act in good faith, that is, with a genuine and honest belief in what they are raising, even if it is later determined that there was an error. Conversely, if an employee makes a report knowing it to be false, the company may take measures against them.

If an employee believes they have suffered retaliation, they must immediately report it to HR Management through the channels the company makes available.

6. How do we act with integrity in our workplace?

6.1 Respecting people

Respect for the rights and dignity of our employees is fundamental to building corporate integrity, and AEROLINEAS ATA CARGO SPA is therefore committed to always protecting it.

Any violation of the dignity of its employees or of third parties with whom AEROLINEAS ATA CARGO SPA interacts will be duly sanctioned.

AEROLINEAS ATA CARGO SPA seeks to promote workplace and social diversity and inclusion, as stated in our Quality, Food Safety, Occupational Health and Safety and Environmental policy, and therefore expects relationships among our employees to be based on respect and inclusion.

In particular, the company is committed to:

• Respecting all people regardless of their religious beliefs, sexual orientation, race, gender, ideological and philosophical positions, political views, nationality, ethnicity or origin.
• Promoting diversity and inclusion as a source of mutual enrichment among employees.
• Protecting the person, health and dignity of everyone with whom it interacts.
• Prohibiting the use of child and forced labor.
• Training employees so they can continue their personal and professional development.
• Supporting employees' right to freedom of association in unions or trade groups, within the framework of recognized labor associations.
• Protecting the identity of employees who ask questions or file reports.
• Ensuring that employees who file reports in good faith do not suffer retaliation.

6.2 Maintaining good relationships with our customers

Our company exists for our customers, which is why we are committed to providing them with professional and honest service. In this way, customers will receive friendly, respectful and non-discriminatory service, and truthful, complete information suited to their needs.

6.3 Maintaining good relationships among employees

We are responsible for creating a healthy and safe work environment built on mutual respect and trust.

As employees, we commit to acting without endangering or harming the health, safety, dignity, integrity or reputation of the people who are part of this organization. Likewise, we treat one another with honesty, respect and kindness.

For these reasons, the following are strictly prohibited within AEROLINEAS ATA CARGO SPA:

• Abuse of authority.
• Sexual and workplace harassment.
• Psychological harassment.
• Arbitrary discrimination.
• Contemptuous or humiliating treatment.
• Any other action that affects us negatively.

6.4 Declaring and managing our conflicts of interest

As employees, we have the responsibility and obligation to make decisions and act in the best interest of the company. We must therefore avoid any situation in which our personal interests are, or appear to be, in conflict with the interests of AEROLINEAS ATA CARGO SPA.

A conflict of interest exists if, when making a decision on behalf of the company, the employee's objectivity is affected by the possibility of obtaining a personal benefit or a benefit for a third party.

Sometimes conflicts of interest are real and sometimes they are apparent. But being apparent does not mean they cannot be serious, because your reputation and the reputation of AEROLINEAS ATA CARGO SPA could be affected.

Situations that give rise to conflicts of interest can arise in various ways and may not be negative or wrong in themselves. The best way to prevent such situations from creating a conflict between the employee's interests and those of AEROLINEAS ATA CARGO SPA is to disclose them promptly.

In general terms, any financial interest, personal or business relationship with other workers, customers, suppliers and/or competitors must be disclosed, as well as outside employment and any other activity, association or relationship with other people that could create a conflict of interest.

If in doubt, consult directly with your line manager or HR Management, who can guide you.

6.5 Complying with the law and internal rules on alcohol and drug use

The safety of our employees and customers is one of the main responsibilities and concerns of AEROLINEAS ATA CARGO SPA.

The use of illegal drugs and the misuse of medication and alcohol can undermine this level of safety and, at the same time, have harmful consequences for people. Furthermore, the sale and distribution of illegal drugs is a crime. For these reasons, our company strictly prohibits the possession, distribution, sale and consumption of illegal drugs and/or alcohol at work.

Occasionally, due to an illness or health condition, a doctor may have instructed you to take medication that, although legal and prescribed, may impair some of the faculties you need to do your job, such as your concentration or reflexes. If this happens, it is important that you discuss with your doctor whether it may pose any risk to you, your coworkers, customers or the assets of AEROLINEAS ATA CARGO SPA, and that they advise and instruct you accordingly.

Smoking is not permitted on company premises, in accordance with applicable law.

6.6 Rejecting all forms of harassment and discrimination

AEROLINEAS ATA CARGO SPA values and protects diversity of race, color, sex, marital status, association, religion, political opinion, nationality, ethnic ancestry, sexual orientation or social origin.

AEROLINEAS ATA CARGO SPA will seek to identify and correct, promptly and appropriately, any conduct that harms our employees, but the responsibility for maintaining a healthy, safe and discrimination-free work environment, among ourselves and with our customers, suppliers and third parties in general, belongs to everyone.

6.7 Maintaining good relationships with suppliers and third parties

In our relationships with suppliers and third parties with whom the company has any connection, the pursuit of benefit for our customers must always be present. To this end, we must build relationships based on clear and transparent communication, efficiency and compliance with current legislation.

AEROLINEAS ATA CARGO SPA will always seek better terms, higher quality and better service, without arbitrarily favoring or discriminating against any supplier or third party.

We will seek not to do business or maintain commercial relationships with people and companies that deliberately depart from the law, engage in illicit business or whose conduct deliberately breaches the principles and values of AEROLINEAS ATA CARGO SPA. We will protect our reputation by seeking to work with those who share our ethical standards.

6.8 Complying with internal rules on gifts and invitations

Giving or accepting gifts or invitations in business contexts is a reality. However, it can lend itself to abuse; it can foster corruption; it blurs the line between professional and personal matters; and it increases the overall cost of doing business, to the detriment of customers and AEROLINEAS ATA CARGO SPA.

In addition, accepting gifts or invitations can cause a conflict of interest, or the appearance of one, between your personal interests and your responsibilities as an employee.

We must not accept gifts or invitations from any supplier, potential supplier, institution or public official, customer, business partner or competitor. Such a gift or invitation may be seeking to influence commercial or business decisions.

Notwithstanding the above, we may accept certain goods or items provided they are of clearly low value, customary according to the culture, place and circumstances in which they are given, whether or not they bear the supplier's brand as a way of promoting its company or services, and are distributed in good faith and indiscriminately to suppliers or customers as a marketing activity, such as key rings, pens and caps, among others.

If you have any doubts, you can consult the Integrity Advisor or HR Management.

6.9 Taking care of AEROLINEAS ATA CARGO SPA assets

We must all take care of and protect the assets of AEROLINEAS ATA CARGO SPA. We must therefore safeguard its products, information, facilities and equipment.

We must not misuse them, that is, use them for personal purposes or in a careless or excessive way. Nor may these assets be removed from the premises where AEROLINEAS ATA CARGO SPA placed them, unless you are duly authorized.

Customer and supplier lists or files, databases, trade secrets and the like are the property of AEROLINEAS ATA CARGO SPA and must be handled in strict confidence.

In addition, they may only be used for business purposes and by people authorized to do so. Any intellectual creations we generate in performing our duties are the property of AEROLINEAS ATA CARGO SPA.

We must not download or install software on AEROLINEAS ATA CARGO SPA computers, as we could expose our network to computer viruses or violate software licenses. The software and information-processing systems provided by the company may only be used for our work. Corporate email may only be used for business purposes, not personal ones.

We will use AEROLINEAS ATA CARGO SPA letterhead, stamps and any representation of the organization solely for matters relating to the performance of our duties.

All employees are responsible for protecting the assets of AEROLINEAS ATA CARGO SPA from fraud, misuse, robbery, theft, loss or damage, and for reporting it when we become aware of it.

7. How do we act with integrity in the marketplace?

7.1 Competing fairly

We seek to compete openly and independently in the markets where we operate, guided by loyalty to consumers and respect for free competition. Accordingly, we do not use methods that prevent, restrict or hinder free competition or that constitute unfair competition, all of which ultimately harm our customers.

To guarantee free competition, we will not participate directly or indirectly in any situation that may prevent, restrict or hinder free competition, such as collusive price-fixing agreements, abuse of a possible dominant position or predatory practices. Likewise, we reject conduct contrary to good faith that seeks to attract a competitor's customers through illegitimate means.

7.2 Respecting financial and documentary integrity

All transactions carried out by AEROLINEAS ATA CARGO SPA must strictly comply with the law. In addition, all our transactions and operations must be carried out according to their type and characteristics, without disguising them as something they are not. Finally, all our transactions must be documented and recorded truthfully in form, date and substance, whether in our contracts, communications, presentations or accounting.

To this end, we will keep complete and accurate contracts, documents, presentations, correspondence, books, records and accounts that reflect the operations or transactions of AEROLINEAS ATA CARGO SPA. Omitting or falsifying information in these books, records and accounts is not permitted under any circumstances.

We must not use the money of AEROLINEAS ATA CARGO SPA for any purpose other than the one it has assigned. Only expressly authorized persons may sign documents and represent AEROLINEAS ATA CARGO SPA.

Those authorized to incur expenses must keep supporting documentation for each transaction and provide accurate and timely accounts of them, in accordance with the company's internal rules on handling money.

Likewise, we will maintain the accuracy and truthfulness of all documentation circulating within AEROLINEAS ATA CARGO SPA, without intentionally altering or modifying its date, content or any other aspect.

7.3 Handling information in accordance with the law and internal rules

Information is an important asset of AEROLINEAS ATA CARGO SPA, and it is therefore our responsibility to protect it regardless of the medium in which it is held.

Through our duties, we may have access to private data of our customers, suppliers, shareholders and/or employees that is protected by law; commercially sensitive information that we cannot share with competitors; strategic information; and inside information. It is our obligation to protect, handle and store information in strict compliance with the law, internal rules and the guidelines of AEROLINEAS ATA CARGO SPA, with absolute discretion, without using it for our own benefit or that of third parties, and likewise to destroy it securely when appropriate.

AEROLINEAS ATA CARGO SPA has special policies and procedures for classifying information according to its sensitivity and how it must be handled. It is your obligation to know and comply with these policies and procedures. In general, we may only disclose information to people who need to know it because of their role in the company.

Respecting privacy and protecting personal data

All employees and other persons to whom this Program applies are required to respect the privacy of the customers, employees and suppliers of AEROLINEAS ATA CARGO SPA, strictly complying with Personal Data Protection regulations and the company's internal rules on the matter.

In addition, employees and any other persons to whom this Program applies must bear in mind that the personal data held by AEROLINEAS ATA CARGO SPA in its databases is its exclusive property and must not be disclosed to third parties without its express authorization, unless validly required by local authorities and laws.

Both employees and other persons to whom this Program applies must handle personal data with particular care. Such data may therefore only be used for the purposes authorized by the data subjects, in compliance with the company's internal rules governing the processing of personal data.

Likewise, throughout the entire process of handling personal data of AEROLINEAS ATA CARGO SPA, employees and other persons to whom this Program applies must safeguard its confidentiality and respect, at all times, the security measures established by AEROLINEAS ATA CARGO SPA for this purpose.

7.4 Respecting intellectual and industrial property

We are an innovative company, and we promote creativity both in our own-brand products and in those we acquire from third parties. However, we must always respect industrial and intellectual property rights.

8. How do we act with integrity in society?

8.1 Complying with the law

As employees, we are responsible for complying with the various laws and regulations that apply both in our country and in the other countries with which AEROLINEAS ATA CARGO SPA has dealings or operations, and for never engaging or participating in fraudulent activities.

8.2 Rejecting all forms of bribery

Bribery is illegal and unethical; it increases the cost of doing business, introduces uncertainty into commercial transactions, destroys trust in institutions and prevents markets from functioning efficiently.

In light of the above, AEROLINEAS ATA CARGO SPA strictly prohibits any employee from making or offering improper payments to any person, or receiving bribes from them, in order to obtain any benefit or gift or to give them an advantage.

Bribery means promising or giving a benefit of any kind, as well as accepting a request for a benefit from a person, whether or not a public official, so that they do or refrain from doing something. No employee may commit bribery, even under the pretext of giving courtesy gifts.

As employees, we must not offer, promise, give or consent to the giving of a benefit of any kind to a public or private employee, domestic or foreign, under any pretext or circumstance and by any means, whether to obtain advantages, influence a decision or speed up a procedure.

8.3 Acting responsibly toward communities and the environment

We are part of the community. We seek not only the profitability of AEROLINEAS ATA CARGO SPA; our challenge is to have a positive impact on people and to protect the environment. We will also comply with all environmental laws and regulations.

We are committed to taking responsibility for any effects or consequences our actions may have in the places where we work, always striving to improve relationships with all stakeholders involved.

8.4 Protecting the health and safety of employees and customers

We are committed to providing safe and healthy working conditions and environments, together with participatory, systematic, planned and ongoing occupational risk management to prevent incidents, accidents, occupational illnesses and health deterioration, by identifying hazards and assessing and controlling the risks inherent in our employees' activities, while also ensuring compliance with current legal requirements and the standards of our customers and stakeholders.

8.5 Complying with product safety and quality

We guarantee the quality and safety of our products and services, with a focus on customization and the clear and transparent communication our customers require, based fundamentally on compliance with current legislation.

The safety of our customers is a fundamental concern of AEROLINEAS ATA CARGO SPA. It is therefore extremely important to comply with all applicable laws and regulations on product safety.

Likewise, we must require our suppliers to comply with them so as to ensure that, throughout the entire supply chain, there are no problems that could affect our employees or customers.

8.6 Dealing with authorities with integrity

We will cooperate with requests made by authorities in the exercise of their duties, with transparency, truthfulness, integrity and efficiency.

As employees, we sometimes have to carry out procedures before authorities on behalf of AEROLINEAS ATA CARGO SPA. In these cases, we must take care to comply with our internal rules governing how we deal with authorities.

We will treat authorities respectfully, avoiding any act that could negatively affect our institutional image.

8.7 Obtaining authorization before making statements to the media

Communication plays an essential role in today's globalized world. Accordingly, and to ensure the accuracy and timeliness of information provided to the public through the media, only authorized departments or spokespersons may make statements on behalf of AEROLINEAS ATA CARGO SPA.

8.8 Acting with integrity at work and beyond

Just as you expect AEROLINEAS ATA CARGO SPA to always be a loyal and law-abiding corporate citizen, and not only as an employer, AEROLINEAS ATA CARGO SPA also expects you to be ethical and act with integrity at work and outside it.

The company does not intend to intrude on your personal life, only to invite you to live ethics and integrity both at work and outside it. Likewise, responsible use of social media is expected with regard to statements that could affect the image or reputation of AEROLINEAS ATA CARGO SPA.

Dishonest or unethical conduct by an employee in their personal life can affect not only the reputation of AEROLINEAS ATA CARGO SPA, but also the credibility their peers and subordinates place in the importance they give to corporate integrity.

9. Crime prevention at the company

AEROLINEAS ATA CARGO SPA is committed to preventing the commission of crimes within the organization, whether or not they benefit it.

The commission of any crime within the organization is considered a breach of the Integrity Program. The crimes of bribery, handling stolen goods, money laundering, terrorist financing, private-sector corruption, unfaithful management, incompatible negotiation, misappropriation, offenses under the fishing law, and any other crimes subsequently added to the catalog of Law No. 20,393 will be considered serious breaches of this Integrity Program. For this reason, AEROLINEAS ATA CARGO SPA will apply the appropriate sanctions or disciplinary measures as a clear sign of its commitment.

Employees must not offer or consent to giving an undue benefit to a public or private employee, whether domestic or foreign, under any pretext or circumstance and by any means. Nor may they receive such undue benefits.

Employees will always ensure that money or assets they receive on behalf of AEROLINEAS ATA CARGO SPA or in connection with their work do not come from illicit activities of any kind; will ensure they are never used to finance illicit activities; will ensure they are properly managed; and will not carry out acts contrary to the interests of AEROLINEAS ATA CARGO SPA or of third parties who own the assets being managed.

10. How should we act when facing an ethical challenge?

When facing complex decisions, the certainty that we are acting with integrity is not always clear.

When we face an ethical dilemma, and before acting, we should ask ourselves the following questions:

1. Do I feel good about what I am doing?
2. Is it legal?
3. Does it represent any conflict of interest?
4. Is it aligned with the company's values?
5. Would someone I trust act the same way?
6. How would I feel if it were published on the front page of a newspaper?
7. Would my family be proud of me?

On the other hand, we all have a natural tendency to look for or invent justifications to conclude that what we have done or are about to do is not wrong, even when it is. This psychological process of accommodating or justifying the discomfort of our ethical conscience is called rationalization. Some typical examples of rationalization are the following justifications:

1. Just once doesn't matter
2. No one will notice
3. Everyone does it
4. We've always done it this way
5. In practice, that's how it works

Careful! Phrases like these are often excuses that allow us to do what we know is wrong.

If you have doubts, we recommend that you approach the Integrity Advisor or HR Management, who will guide you so you can make the best decision.

11. Measures applicable in case of non-compliance

AEROLINEAS ATA CARGO SPA may apply disciplinary measures ranging from a verbal warning to dismissal of the employee in the event of non-compliance with our Integrity Program or with current laws or regulations.

The measures applied will be determined by the seriousness of the non-compliance, its impact and significance for AEROLINEAS ATA CARGO SPA and the responsibility of the person who committed it. In addition, anyone who intentionally makes false accusations or lies when asked to cooperate in an ethics case investigation will also be subject to these sanctions.

12. Our commitment to integrity

Principles and values can remain a dead letter if we lose sight of what matters most: our commitment to integrity.

By signing as acknowledgment of having received a copy of this Program and having read and understood it, I commit to the following:

• Accept personal responsibility for upholding the integrity of AEROLINEAS ATA CARGO SPA in each of my actions and decisions, respecting the values, principles, standards and policies described in this Integrity Program and in the company's other official policies and documents.
• Accept the duty to lead by example, always maintaining a proper attitude and avoiding situations that could harm our customers, employees or the reputation of AEROLINEAS ATA CARGO SPA.
• Ask questions when in doubt about the scope of ethical obligations and report in good faith any situations that represent a breach of these rules.
• Maintain due confidentiality after filing a report or cooperating in an ethics investigation.

We all build the company's integrity.