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Ethics and Compliance

Global anti-corruption enforcement continues to increase. Choosing the wrong providers to support your international missions can expose you to serious risk.

With us, you have a partner taking proactive steps to keep you and your missions from running afoul of compliance enforcement actions.

Our Commitment

At Universal, we conduct our business globally with integrity and in compliance with applicable domestic and international laws and regulations. We continue to set high standards within our organization and for the industry in which we serve, and we are often asked to speak on compliance-related matters by industry trade associations.

A Dedicated Compliance Department maintaining a comprehensive program aligned with U.S. Sentencing Guidelines, reinforcing our commitment to legal and ethical standards

Routinely asked to speak on compliance-related matter by industry trade associations

Satisfactorily answering >200 compliance-related inquiries per year

Ethics & Compliance Program

Program Oversight
  • Corporate Compliance and Internal Audit Plan
  • 5-year audit program with Audit Committee oversight
  • Regular program effectiveness assessments
  • Dedicated Compliance and Data Protection leadership
Code of Business Conduct

Our Code of Business Conduct and Ethics serves as the foundation of our compliance program. All employees globally complete:

  • Annual Statement of Compliance Certification
  • Annual FCPA Entity Certification Questionnaire (all Universal entities)
  • Regular policy and procedure reviews and attestations
Comprehensive Policies

We maintain detailed policies covering key compliance areas:

  • Universal Code of Conduct
  • FCPA/Anti-Corruption Compliance Policy
  • Gift, Travel & Entertainment Guidelines for Non-U.S. Government Officials
  • Data Privacy Policy with Standard Contractual Clauses
  • Economic Sanction Guidelines
  • Third-Party Due Diligence Procedures
Risk-Based Due Diligence

Our third-party management program includes:

  • Comprehensive supplier screening and monitoring
  • Online training program for key third-party suppliers in top travel destination markets
  • Regular due diligence updates
  • Specially Designated Nationals (SDN) screening process
  • Continuous monitoring and auditing of business relationships
Training & Education

We deliver comprehensive training to employees and key third-party suppliers through multiple channels, including:

  • Online and in-person mandatory sessions
  • Annual refresher curriculum
  • Role-specific compliance training
Economic Sanctions Compliance

Our program includes robust controls for:

  • Sanctions screening and monitoring
  • Export compliance verification
  • SDN list checking procedures
  • Transaction monitoring
  • Documentation requirements
Data Privacy

Our data privacy program comprises:

  • Protection against accidental disclosures of information and putting our customers’ data at risk
  • Data privacy and security requirements for third parties who have access to personal data
  • A process for updating and deleting personal data
  • Certified Information Privacy Professional staff oversight

Resources:

Reporting & Investigation

We maintain multiple reporting channels:

  • Third-party managed Universal® AlertLine for anonymous reporting – via phone or web
  • In-person reporting
  • Formal investigation procedures
  • Documentation protocols
  • Response tracking
  • Resolution monitoring

Zero Tolerance for Unlawful Facilitation Payments

Regulatory Environment

Global anti-corruption enforcement has intensified, with authorities increasingly prosecuting violations of the Foreign Corrupt Practices Act (FCPA) and UK Bribery Act (UKBA). This heightened enforcement environment directly impacts the business aviation industry, where frequent interactions with government and airport officials create elevated compliance risks.

Our Position

Universal maintains a zero-tolerance policy towards facilitation payments in compliance with global anti-corruption laws. While the FCPA contains limited exceptions for facilitation payments, we align with the UKBA’s stricter standard, which prohibits all such payments. This conservative approach provides clear guidance and maximum protection for our customers’ operations worldwide.

Industry-Specific Risks for Business Aviation

For pilots and international operators, frequent interactions with government and airport officials can pose risks of running afoul of these anti-corruption enforcement actions. This includes:

  • Direct interactions with government officials
  • Indirect interactions by contracted third parties working on your behalf, such as ground handlers
  • Multiple government touchpoints during any international mission, including:
    • CIQ procedures
    • Permit processing
    • Government-owned handlers, fuelers and other service providers
Prohibited Activities

Our zero-tolerance policy strictly prohibits:

  • Payments to expedite routine government actions
  • Unofficial fees for customs, immigration, or quarantine processing
  • Cash payments to airport officials or regulatory personnel without a receipt or invoice
  • Tips or gratuities to government employees
  • Payments by contracted third parties intended to influence official actions

Key Resources

Operational Insight

Chairman’s Note: 2023 Reflections * Triumphing Over...
on January 11

Dear Friends and Colleagues, As we start 2024, I wanted to pause to reflect on a challenging and rewarding year for our industry. My first reflection […]

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Chairman’s Note: AsBAA Icons of Aviation Are Back:...
on November 16

Services Asia and the region's local ground handling teams were named the winner of the "Best Operational Support Services, 2023" award. This is a […]

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Chairman’s Note – NBAA BACE, Las Vegas * Hope to See...
on October 12

If you’re planning to attend NBAA, we’d love to see you in our exhibit #C8709 to talk about what’s new at Universal and some of the ways we can […]

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