Modern Slavery Act Transparency Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes American Airlines Inc.’s Modern Slavery Act Transparency Statement for the financial year ending 2018.

Our commitment

American Airlines is committed to respecting human rights, including combating illegal human trafficking and child exploitation. As a prominent part of the worldwide travel industry, we conduct our business in a manner that protects human rights and the rights of children within our sphere of influence. We have adopted responsible workplace practices and endeavour to conduct our business operations free from complicity in human rights abuses.

Our policies

American’s commitment to human rights is outlined in our Standards of Business Conduct, which require all of American’s employees to uphold the human rights of all persons, including permanent and temporary employees both domestically and internationally. We do not knowingly conduct business with any individual or company that participates in the exploitation of children (including child labour), physical punishment, forced labour, or human trafficking.

As a U.S. federal government contractor, American is subject to the Trafficking Victims Protection Act of 2000 and implementing Federal Acquisition Regulation (FAR) 52.222-50, Combating Trafficking in Persons, enacted to combat all forms of human trafficking and forced labour. We have adopted both a Policy Prohibiting Trafficking in Persons and a Combating Trafficking in Persons Compliance Plan that serve as a guide to address and comply with these regulatory requirements. We also flow down FAR 52.222-50 as required to our government subcontractors and agents. Any violations of the FAR or American’s policy prohibiting trafficking in persons by employees, agents, or subcontractors may result in the agent’s or subcontractor's removal from the contract or termination of the contract or the employee’s reduction in benefits or termination of employment.

American’s policies and other information on human trafficking and modern slavery, including links to educational and training resources, are available to all employees on our employee website.

We also condemn all forms of exploitation of children. We don’t recruit child labour, and we support the elimination of exploitative child labour. We also support laws and initiatives to prevent and punish the sexual exploitation of children. In January 2018, American signed ECPAT-USA’s Tourism Child-Protection Code of Conduct. ECPAT-USA is the leading policy organization in the United States seeking to end the commercial, sexual exploitation of children and the Code, which represents a joint venture between the tourism private sector and ECPAT, is the only voluntary set of business principles travel and tour companies can implement to prevent child sex tourism and trafficking of children. American also recently participated in the Working Together to End Human Trafficking Summit in Washington D.C.

Supply chain and vendor management

American encourages its suppliers to share our commitment to combat modern slavery. Through our Standards of Business Conduct for Suppliers, we require suppliers to not use forced labor or traffic in persons. We are also adding a provision in our supplier agreements requiring that suppliers comply with applicable laws and regulations to prevent human trafficking and commercial sexual exploitation of children, including preventing the use of American’s premises or products for such exploitation.


American has provided initial and recurrent human trafficking awareness training to our flight attendants for several years. American also provides anti-trafficking training to employees with relevant purchasing responsibilities, including training employees who conduct on-site visits to American’s international suppliers on how to recognize signs of human trafficking and what action they should take if they suspect human trafficking. And in 2017 we implemented anti-trafficking training for our pilots and airport customer service team members. We now have trafficking awareness training in place for all of our frontline team members—nearly 60,000 people.

Internal accountability

Employees or agents have a responsibility to report, without fear of retaliation, any incidents of suspected human trafficking or other activity inconsistent with our Standards of Business Conduct. We have a 24/7 hotline (the EthicsPoint helpline) available to all employees. Employees can call the toll-free number or use an online, secure web portal to ask questions or report questionable conduct. The helpline is available system-wide to domestic and international employees, and employees can remain anonymous. American’s Business Ethics & Compliance Office and Legal Department also receive reports by telephone, mail, and email. The Global Human Trafficking Hotline is available to all employees and we inform our employees that they may report any activity inconsistent with the U.S. federal government’s policy or American’s policy by contacting the Hotline.

We will protect and interview all employees or agents suspected of being victims of or witnesses to prohibited activities. This will occur before the employees or agents return to their countries of origin if they are located outside their countries of origin when the incident was reported. We will also cooperate fully with any trafficking-related audits and investigations by the U.S. federal government, including providing reasonable access to our facilities and staff.

American has a zero-tolerance policy against retaliation. Any employee or agent who violates this policy will be subject to appropriate discipline, including reduction in benefits or termination of employment.

Stephen L. Johnson, Director

American Airlines, Inc.