Ethics & Compliance
Our Commitment
As a subsidiary of Universal Weather and Aviation LLC., Air Culinaire Worldwide conducts 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.
Our dedicated Compliance Department maintains a comprehensive program aligned with U.S. Sentencing Guidelines, reinforcing our commitment to legal and ethical standards.
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
Risk-Based Due Diligence
Our third-party management program includes:
- 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 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:
- See Our Data Privacy Policy
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
Key Resources
- Code of Business Conduct and Ethics (available on request)
- Anti-Slavery and Human Trafficking Statement
- Data Privacy Policy