Governance
Introduction
CEO letter
Air SERBIA’s Story
Air Serbia in 2025 - year in review
Materiality analysis and stakeholder engagement
Environment
Economic value and connectivity
Social
Appendix
6.4 Ethics and compliance
Air Serbia conducts its business in accordance with high ethical standards and a zero-tolerance approach to corruption and anti-competitive conduct. The company's ethical framework is set out in its Code of Business Conduct, supported by a dedicated Conflict of Interest Manual and overseen by the company's ethics and compliance function. Together, these instruments define the standards of conduct expected of everyone acting on the company's behalf and the channels available for raising concerns.
Anti-corruption and anti-bribery
All of the company's operations fall within the scope of the Code of Business Conduct, which establishes the company's anti-corruption rules and expectations across the organization. A formal, dedicated corruption-risk assessment of individual operations has not yet been conducted; the company intends to develop a structured approach to assessing corruption-related risks as its compliance framework matures. Operations covered by anti-corruption rules
The Code of Business Conduct (Third Edition) applies to all employees , including directors, permanent and temporary staff, agents and other representatives acting on the company's behalf , at the Belgrade headquarters and across the entire network. It is a principle-based framework built around the company's core values , embracing change, accountability, commitment, service excellence and integrity in everything the company does , and guides employees on the protection of confidential information, the proper use of company assets, accurate business and financial record-keeping, the equal treatment of employees and dignity and mutual respect in the workplace. Where the Code's provisions and local law diverge, applicable law prevails. A principle-based Code of Business Conduct
Air Serbia prohibits the payment or acceptance of bribes and kickbacks in any form, consistent with applicable anti-corruption legislation including the US Foreign Corrupt Practices Act and the UK Bribery Act. The Code of Business Conduct sets out specific rules for dealings with public officials , interpreting "anything of value" broadly and requiring prior approval , and prohibits facilitation payments. Due-diligence requirements apply to agents such as general sales agents, sub-contractors, consultants and intermediaries, given that the company may be held liable for corrupt acts committed on its behalf. Clear rules also govern the giving and receiving of gifts and business entertainment, so as to avoid any perception of improper influence.
Third Edition Code of Business Conduct in force
0 confirmed incidents of corruption in 2025
24/7 independent Ethics Line
Sustainability Report 34
Made with FlippingBook interactive PDF creator