Other potential conflicts of interest include, but are not limited to the following:

• Employment outside ABX - If you are employed outside ABX, it should not interfere, compete, or conflict with the company’s best interests or hinder your ability to meet your responsibilities at ABX. If in doubt, contact your manager for current clarification.
• Volunteer Activities/Community Involvement -You are encouraged to be involved in community, industry, and charitable activities, including directorships in non-profit community organizations, as long as they do not compete with or create demands that interfere with your job.
• Employment of Relatives - ABX permits the employment and promotions of qualified relatives of employees as long as such employment does not, in the opinion of ABX, create actual or perceived conflicts of interest.
• Subcontracting, Contracting, or Approval of payment for services of any kind - No person with a close personal friendship or Relative as defined in this policy, shall award or approve payments to anyone with an actual or perceived conflict of interest.

• Act in the best interest of the company when dealing with customers, suppliers, contractors, competitors, or any person doing or seeking to do business with ABX Air.
• Conduct the company’s business with integrity and in a manner that excludes any personal advantage or gain.
• While interacting with others on behalf of the company, conduct yourself in a strictly professional, business-like manner to avoid any potential or actual conflict of interest or favoritism.
• Maintain transparent, arms’ length business relationships.
• Respect segregation of duties, including removing yourself from any business transactions involving relatives as defined or implied by this policy.
• Employees may, with their vice president’s knowledge and approval, exchange gifts as customary in some foreign countries.
• Tell management immediately if you own or have significant interest in, or any member of your family owns or has significant interest in, any outside company which does business or seeks to do business with ABX or is a competitor.
• Tell management immediately if you become aware of any situation that may involve a conflict of interest for yourself or others.
• Please direct any questions related to this policy to your management or the Sr. VP Corporate General Counsel and Secretary, or Assistant General Counsel.

With regard to gifts, favors, and entertainment:

• Do not seek gifts, favors, or entertainment for yourself or for others.
• It is never permissible to accept a gift of cash or cash equivalent such as stocks or other forms of marketable securities of any amount.
• ANY gifts, favors, or entertainment offered MUST be approved in advance by the next level of management who will assist in deciding how the offers should be handled. In most cases, gifts that can be shared with co-workers should be shared.
• Examples of gifts, favors, or entertainment situations that commonly come up and are acceptable include, but are not limited to:
  1. Lunch and/or dinner with vendors, sometimes including spouses.
  2. Gifts of small value from vendors such as calendars, pens, pads, knives, etc.
  3. Tickets to events (such as sports, arts, etc.), or participation in sponsored events
  4. Overnight outings are acceptable under the condition that either individuals from other companies or the vendor also attend, and there is a potential business benefit to the event.
  5. Social drinks are acceptable within moderate limits; however receipt of gifts of alcoholic beverages is discouraged.
  6. Gifts of perishable items usually given during the holidays such as hams, cookies, nuts, etc., are acceptable. You are encouraged to share with co-workers if you receive them.
  7. Day outings such as golf, fishing, and hunting are acceptable if the vendor attends.
  8. Attendance of events at vendor facilities is acceptable, but use of vendor’s facilities (vacation homes, etc.) by employees or families for personal use is prohibited.

• Respond to employees’ concerns and provide guidance regarding potential or actual conflict of interest issues.
• Investigate immediately if you become aware of any situation that may involve a potential or actual conflict of interest and take appropriate action.
• Take time to examine situations involving an employee's relative(s) to see if the potential for conflict of interest exists and, if so, how it may affect the productivity of the employee and/or department. If a potential for conflict of interest exists, discuss the situation with your management, the business unit leaders, and/or Human Resources to evaluate the appropriate steps to take.
• Your department may establish procedures to provide additional guidance to you if business conditions routinely place you in a position to make financial decisions for ABX Air.
• Assist employees to understand, be respectful of, and participate in customs and unique operating conditions in foreign countries.
• Do not accept gifts valued at more than $20 from those under your supervision.