Code of ethics

Code of ethics

The principles and values that guide our activities with integrity, transparency and responsibility

1. Introduction

FlyWay operates in the charter flight sector, organizing commercial passenger and cargo transportation with the objective of providing reliable, safe, efficient services tailored to the needs of its customers.

Trust is the foundation of every relationship established by the Company with passengers, commercial clients, suppliers, institutional partners, aviation authorities, employees, and collaborators.

This Code of Ethics defines the values, principles, and standards of conduct that guide all Company activities and serves as a reference for everyone who operates, directly or indirectly, on behalf of FlyWay.

Every business decision must be made in compliance with the law, operational safety, professional integrity, and social responsibility.

2. Mission

FlyWay aims to contribute to the development of commercial air mobility by providing transportation services that combine:

  • operational safety;
  • reliability;
  • punctuality;
  • innovation;
  • sustainability;
  • customer focus;
  • recognition and development of people.

The Company’s objective is not solely to achieve financial results, but to create lasting value for all stakeholders.

3. Core values

FlyWay’s activities are based on the following values.

3.1 Safety

Safety is the Company’s highest priority and is never subordinated to economic or commercial considerations.

All operational activities are planned and carried out to minimize risks to people, aircraft, cargo, infrastructure, and the environment.

Every employee and collaborator has both the right and the duty to report situations that could compromise safety.

3.2 Integrity

FlyWay conducts its business with fairness, transparency, and honesty in every professional relationship.

Fraudulent, deceptive, or unlawful conduct is not permitted.

3.3 Professionalism

All activities must be carried out with technical competence, responsibility, continuous professional development, and compliance with national and international aviation standards.

3.4 Responsability

Every individual is accountable for their own actions and contributes to achieving shared objectives through conduct consistent with the Company’s values.

3.5 Customer centric

FlyWay considers the customer to be the primary beneficiary of its commitment.

The Company promotes a service based on:

  • attentive listening;
  • availability;
  • punctuality;
  • quality;
  • reliability;
  • respect.

3.6 Scope

This Code applies to:

  • directors;
  • executives;
  • employees;
  • collaborators;
  • consultants;
  • business partners;
  • suppliers;
  • intermediaries;
  • anyone acting in the name of or on behalf of the Company.

Compliance with this Code is an essential element of the relationship with FlyWay.

3.7 Compliance with laws

FlyWay operates in full compliance with:

  • Italian legislation;
  • European legislation;
  • the regulations of the competent aviation authorities;
  • aviation safety regulations;
  • privacy legislation;
  • anti-money laundering legislation;
  • environmental legislation;
  • occupational health and safety regulations.

No business interest may justify conduct that violates the law.

3.8 Operational safety

Safety is the guiding principle of every activity.

FlyWay promotes an organizational culture in which:

  • errors are analyzed to prevent their recurrence;
  • the reporting of risks is encouraged;
  • continuous training is regarded as an ongoing investment;
  • aircraft maintenance is considered a strategic priority;
  • every operational decision places safety first.

The Company fosters a culture of accountability, prevention, and continuous improvement.

3.9 Customer relations

FFlyWay guarantees:

  • clear information;
  • fair contractual practices;
  • transparency of commercial and financial terms;
  • protection of confidentiality;
  • professional handling of complaints;
  • respect for the dignity of every individual.

Every customer must be treated with impartiality, courtesy, and professionalism.

3.10 Supplier relations

Suppliers are selected based on the following criteria:

  • quality;
  • reliability;
  • competence;
  • sustainability;
  • commercial fairness;
  • regulatory compliance.

Discrimination and favoritism are not permitted.

3.11 Relations with public authorities

FlyWay maintains relationships based on the highest level of cooperation with:

  • ENAC;
  • ENAV;
  • competent European agencies;
  • airport authorities;
  • public administrations.

All communications must be truthful, complete, and timely.

It is prohibited to offer or promise money or any other benefit in order to obtain an improper advantage.

3.12 Conflict of interests

All recipients of this Code must avoid situations in which personal interests may interfere with those of the Company.

Any potential conflict of interest must be promptly disclosed to the appropriate managers.

3.12 Gifts and benefits

Only gifts of nominal value that are consistent with accepted business practices are permitted.

It is prohibited to offer or accept benefits that could influence the impartiality of decision-making.

Anti-corruption

FlyWay conducts its business in accordance with the principles of legality, transparency, and fairness, adopting a policy of zero tolerance toward any form of corruption, extortion, undue inducement, fraud, or any other unlawful conduct intended to obtain improper advantages.

The Company prohibits all recipients of this Code from:

  • offering, promising, requesting, or accepting money, gifts, benefits, or any other improper advantage;
  • improperly influencing decisions made by public officials, persons entrusted with public service, or private individuals;
  • using intermediaries, consultants, or third parties to engage in conduct that violates the law or this Code;
  • making payments that are undocumented or not justified by legitimate contractual relationships.

All dealings with public administrations, aviation authorities, regulatory bodies, customers, suppliers, and business partners must be conducted with the highest standards of transparency, traceability, and fairness.

All recipients are required to promptly report any requests or situations that may constitute corruption or other unlawful conduct.

3.13 Respect for people

FlyWay promotes a working environment based on:

  • respect;
  • inclusion;
  • equal opportunities;
  • recognition and development of skills;
  • collaboration.

The Company does not tolerate:

offensive behavior.

discrimination;

harassment;

intimidation;

violence;

Respect of human rights

FlyWay recognizes respect for human dignity as a fundamental value and is committed to operating in full compliance with internationally recognized human rights.

The Company promotes an inclusive, safe, and respectful workplace that values diversity and opposes all forms of discrimination based on, including but not limited to:

  • gender;
  • age;
  • ethnic origin;
  • nationality;
  • religion;
  • personal beliefs;
  • sexual orientation;
  • gender identity;
  • disability;
  • any other personal characteristic.

FlyWay rejects all forms of:

  • forced labor;
  • labor exploitation;
  • child labor;
  • human trafficking;
  • harassment;
  • intimidation;
  • physical or psychological violence.

The Company encourages conduct based on mutual respect, collaboration, and the recognition of individual skills, while promoting equal opportunities for professional growth and personal development.

FlyWay also strives to ensure that suppliers, business partners, and collaborators share these same ethical principles and commitment to the protection of fundamental human rights.

3.14 Health and safety at work

FlyWay considers the protection of employees’ health and safety to be a permanent objective.

Every employee is required to comply with operating procedures, use the prescribed protective equipment, and follow all safety instructions.

Prevention is a shared responsibility.

3.15 Environmental protection

FlyWay is committed to reducing the environmental impact of its activities through:

  • efficient use of resources;
  • reduction of consumption;
  • proper waste management;
  • optimization of operations;
  • promotion of sustainable practices.

3.16 Protection of information

Company information is a valuable corporate asset.

All recipients are required to protect its:

  • confidentiality;
  • integrity;
  • availability.

Unauthorized disclosure of Company or customer information is strictly prohibited. non autorizzata di dati aziendali o dei clienti.

3.17 Use of company assets

The Company’s tangible and intangible assets must be used exclusively for business purposes and with due care, efficiency, and responsibility.

3.18 Financial and acocunting management

OEvery transaction must be:

  • authorized;
  • documented;
  • verifiable;
  • accurately recorded;
  • compliant with applicable laws and regulations.

Financial transparency is a fundamental principle of corporate governance.

3.19 Reporting

FlyWay encourages the good-faith reporting of conduct that violates the law or this Code.

Reports are managed in a manner that guarantees:

  • confidentiality;
  • impartiality;
  • protection against retaliation;
  • objective verification of the facts.
Whistleblowing and protection of reporting persons

FFlyWay promotes a culture based on transparency, accountability, and the prevention of unlawful conduct.

Anyone who becomes aware of conduct that violates the law, this Code of Ethics, Company procedures, or principles of fairness may submit a report through the reporting channels established by the Company.

Reports are handled in accordance with the principles of:

  • confidentiality of the identity of the reporting person and all individuals involved;
  • impartiality;
  • timely investigation;
  • protection against any form of retaliation, discrimination, or adverse treatment;
  • compliance with applicable whistleblower protection laws.

The Company guarantees that no person who makes a report in good faith will suffer any adverse consequences as a result.

Reports that are knowingly false, made with malicious intent or gross negligence, and intended solely to harm others constitute a violation of this Code and may result in the application of measures provided for by applicable laws and Company regulations.

3.20 Implementation of the code

The Company promotes awareness and implementation of this Code through:

  • training;
  • internal communication;
  • periodic updates;
  • monitoring of its application.

Any violation of this Code may result in the application of measures provided for by applicable laws, contractual obligations, and Company regulations.

Final provisions

This Code of Ethics represents a concrete commitment undertaken by FlyWay toward its people, institutions, the marketplace, and the wider community.

Operating with integrity means building relationships every day that are founded on trust, safety, and responsibility, while contributing to the development of a modern, sustainable, and excellence-driven air transport industry.

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