Business Partners

JetBlue is a customer friendly, low-fare, low-cost airline committed to providing value and quality service and products to its customers. Our success is built on our values and ethical conduct. We strive to partner with Business Partners that share our commitment to ethical business practices.

Below, the JetBlue Business Partner Code of Conduct defines our own commitment and expectations of our Business Partners. We expect all our Business Partners to uphold the standards presented in this code.

JetBlue may change this Code of Conduct at any time by posting a revised Code of Conduct on this website. You should monitor the website regularly for changes to this Code of Conduct. We welcome potential Business Partners that can comply with this Code of Conduct, support our growth, share our values and help us provide the JetBlue experience our customers expect and enjoy.

If you are interested in becoming a JetBlue Business Partner, we encourage you to sign up and provide your company information. This will help us align your current products and services with our needs so that we can contact you when there is a business opportunity.

We thank you for your interest and look forward to learning more about your company!

JetBlue utilizes Ariba P2P for its indirect procurement activities. If your company is interested, sign up as a Business Partner on the Ariba Supplier Network.

Introduction

JetBlue’s foundation is built on our Values – Safety, Caring, Integrity, Passion, and Fun. We use our Values to guide our actions, distinguish us from our competitors, and help us deliver superior customer and crewmember experiences. Our Values are embedded in our culture, and our long-term success depends on our integrity. 

JetBlue’s Business Partner Code of Conduct (“Code”) describes JetBlue’s expectations of how its Business Partners should operate. Business Partners, their workers, agents, and subcontractors (collectively referred to as “Business Partners”) are expected to adhere to this Code while conducting business with or on behalf of JetBlue. This includes aligning and integrating guidelines, policies, and practices with this Code and communicating and enforcing the Code throughout their organization and across their supply chain. This Code should be prominently communicated in a language and in a method that is accessible and understandable. 

All Business Partners must act with integrity and are expected to demonstrate a commitment to legal, ethical, safe, fair, and responsible business practices. JetBlue promotes a diverse and inclusive work environment and expects its Business Partners to demonstrate a similar commitment to inclusive business practices, including respect for gender equality.

While we recognize that there are different legal and cultural environments in which our Business Partners operate, all Business Partners are required to comply with all relevant laws, rules, regulations, and standards in the countries in which they operate and meet the minimum requirements set forth in this Code. We encourage our Business Partners to go beyond legal compliance, aspiring to meet internationally recognized standards, in order to advance social and environmental responsibility, and business ethics. In instances where standards outlined in this Code differ from local laws, Business Partners must adhere to the more stringent standards.

The JetBlue Business Partner Code of Conduct supplements the standards and principles established in the JetBlue Code of Business Conduct, which serves as a master steering document for all JetBlue Crewmembers and anyone working on JetBlue’s behalf.

This Code consists of six sections, including standards on human rights, labor rights, and environmental and anti-corruption principles.

• Section 1: Human Rights and Labor Practices
• Section 2: Health and Safety
• Section 3: Diversity and Inclusion
• Section 4: Environmental Stewardship
• Section 5: Business Ethics and Regulatory Compliance
• Section 6: Management Systems

1. Human Rights and Labor Practices

Respecting human rights means treating people with dignity. JetBlue recognizes its responsibility to respect internationally recognized human rights and labor standards, including the Universal Declaration of Human Rights and the International Labor Organization’s Core Conventions. We expect our Business Partners to enact similar policies and practices covering the following topics that apply to their workers and business relationships, including contract workers.

a. Freely Chosen Employment

Business Partners must not engage in or support any form of slavery, forced or compulsory, bonded, prison, indentured labor, or human trafficking of involuntary labor through threat, force, fraudulent claims, or coercion. Business Partners must also not permit their subcontractors to engage in these practices. We expect our Business Partners to fully comply with the requirements of applicable slavery, forced labor, and human trafficking laws, including, but not limited to, the UK Modern Slavery Act.

Business Partners should be aware of the indicators of forced labor identified by the International Labour Organization, such as the withholding of wages, retention of identity documents, and restriction of movement. Business Partners should also implement measures to ensure that workers are not exploited by third-party labor providers, such as recruiters or agencies. Such measures include, but are not limited to, caps on or elimination of recruitment fees, provision of contracts to all workers in their native language or other language that they are able to understand, and elimination of deposits paid by workers to vendors or recruiters to secure jobs.

Business Partners are encouraged to implement due diligence measures to ensure that no human trafficking exists within their extended supply chains.

b. Child Labor

Business Partners must not employ child labor in the manufacturing or in the provision of services or supply of goods. The term “child” refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is higher. JetBlue only supports the development of legitimate workplace apprenticeship programs for the educational benefit of young people and will not do business with those who abuse such systems. Workers under the age of 18 shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. 

In addition, Business Partners should take the necessary preventive measures to ensure that they do not employ anyone under the applicable legal minimum age of employment. Examples of preventive measures include, but are not limited to, age verification systems, training for managers, and communicating with suppliers about child labor issues.

c. Wages and Benefits

Business Partners must ensure that their workers are paid lawful wages, including overtime, premium pay, equal pay for work, and legally mandated benefits. Compensation must be provided in a way that is prompt and easily understood. Conditional payments or disciplinary deductions are not tolerated.

d. Working Hours

Business Partners must ensure that working hours do not exceed the maximum set by local law. In addition, a workweek shall not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Employees must be allowed at least one day off every seven-day week.

e. Freedom of Association and Collective Bargaining

In addition to all local laws and regulations governing the legal rights of their employees, Business Partners must respect the rights of workers to join or not to join worker organizations including trade unions, without any form of physical or psychological violence, threats, intimidation, retaliation, harassment, or abuse. Employees must also have the right to collectively bargain if they choose not to be represented.  

f. Harassment, Discrimination, and Equal Employment Opportunity 

Business Partners must ensure that all people are provided with equal employment opportunities and are not harassed or discriminated against in any way. Business Partners should promote a workplace culture that supports women’s rights and ensure that needs specific to women, such as those related to pregnancy, are not used to undermine, cut, or diminish women’s employment opportunities.

All forms of violence and harassment, including physical, sexual, verbal, and psychological abuse, are prohibited. Sexual harassment, including unwelcome sexual advances, unwanted hugs and touches, suggestive or lewd remarks, requests for sexual favors, or the display of indecent, derogatory, or pornographic material, is prohibited. Forms of discrimination include but are not limited to discrimination on any basis prohibited by applicable law, including race, color, religion, sex, national origin, age, disability, pregnancy, veteran status, genetic information, citizenship status, marital status, sexual orientation, or gender identity or expression. Business Partners should ensure that all people are protected from retaliation for raising concerns related to violence and harassment.

2. Health and Safety

JetBlue recognizes the importance of conditions that are healthy and safe for all workers and requires its Business Partners to provide a working environment that minimizes health and safety risks, supports accident prevention and emergency plans and response procedures, and protects the health and safety of all people who may be affected by their activities. Our Business Partners must comply with health and safety laws and regulations in the geographies in which they operate, and must provide workers with health and safety information in a language and through a medium that is understandable. In addition, our Business Partners are expected to adhere to the following.

a. Occupational Safety

Business Partners should identify, assess, and control as appropriate any possibility of workers being exposed to potential safety hazards (e.g. chemical, electrical and other energy sources, fire, vehicles, and fall hazards). Where hazards cannot be adequately controlled by these means, Business Partners must provide workers with appropriate and well-maintained protective equipment at no cost, as well as educational materials about risks associated with these hazards to their health and safety. Workers must be encouraged to raise safety concerns.

Our Business Partners must also have in place procedures and systems to prevent, manage, track, and report occupational injury and illness.   

b. Physically Demanding Work

Our Business Partners should identify, evaluate, and control any worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks. 

c. Machine Safeguarding

Business Partners should evaluate safety hazards related to production and other machinery. Physical guards, interlocks, and barriers must be provided and properly maintained where machinery presents an injury hazard to workers.

d. Drugs and Alcohol

Our Business Partners must prohibit the use, manufacture, distribution, sale, or possession of narcotics, drugs, controlled substances, paraphernalia, and literature that promotes illegal drugs and substance use while on JetBlue-owned or JetBlue-leased premises.

Business Partners must also prohibit the use of alcohol and any other impairing substance (including those permitted by state or local law) that adversely affects their employees’ job performance or is within eight hours of an employee reporting for work, training, or other opportunities while engaging in work for or representing JetBlue.

3. Diversity and Inclusion

Respect is the foundation of an inclusive work environment and is key to JetBlue’s success, sustainability, and profitability. We expect our Business Partners to promote an inclusive work environment in their operations and across their supply chains. Business Partners are encouraged to establish diversity and inclusion strategies and goals, develop cross-functional diversity taskforces, and track key metrics such as diversity representation by level, attrition by gender, representation in external hires, representation in promotions, and representation on the board of directors.

Business Partners are encouraged to engage in supplier diversity by procuring goods and services from companies that are owned, operated, and controlled by underrepresented groups such as women and ethnic minorities. Similarly, Business Partners are encouraged to engage in impact sourcing, by outsourcing the procurement of goods and services to individuals in economically disadvantaged areas.  

4. Environmental Stewardship

Environmental responsibility is integral to the success of JetBlue’s business, because we rely on natural resources in order to operate. Our Business Partners must comply with all applicable environmental laws and regulations and should align with best practices locally and globally. Our Business Partners should maintain an effective environmental management system that helps to identify, track, manage, and mitigate the environmental impacts of their operations, including on the following topics. 

a. Energy and Emissions   

JetBlue has taken a leadership role in curbing our greenhouse gas emissions. We encourage our Business Partners to also seek to eliminate or minimize emissions, establish greenhouse gas emissions reduction targets, and select low greenhouse gas emissions products and services where possible.

b. Water and Natural Resource Conservation

JetBlue is committed to conserving our planet’s natural resources, as reflected by our company-wide recycling commitment. We encourage our Business Partners to adopt similar natural resource conservation practices in addition to recycling, such as modifying production, substituting materials where appropriate, and reducing use of and reusing water in their own operations.

c. Waste Management

We expect our Business Partners to take concrete steps to identify, manage, reduce, and responsibly dispose of waste (nonhazardous) across their operations and those of their suppliers. Business Partners should ensure that all materials posing a hazard to humans or the environment are properly identified, labelled, and managed to ensure their safe handling, movement, storage, use, recycling, or reuse and disposal.

5. Business Ethics and Regulatory Compliance

JetBlue conducts its business in accordance with the highest ethical standards and in compliance with all applicable laws, rules, and regulations. Our Business Partners must conduct business fairly, ethically, and in compliance with the applicable laws, rules, and regulations. Our Business Partners should have in place policies and processes as appropriate to ensure that all employees understand and adhere to these standards. 

a. Anti-Bribery

Business Partners must have a zero-tolerance policy for corruption and bribery in any form. Our Business Partners are required to comply with requirements of all applicable anti-corruption laws, including but not limited to the U.S. Foreign Corrupt Practices Act and the UK Bribery Act. In addition, our Business Partners must not directly or indirectly give, offer, or accept anything of value to obtain or retain business or favored treatment, to influence actions, or to obtain an improper advantage for JetBlue, itself, or a third party. This includes, but is not limited to, any benefit, fee, commission, dividend, gift, cash, gratuity, services, consideration, or inducements of any kind to any JetBlue employee. We expect our Business Partners to require the same of their affiliates, retained agents, subcontractors, intermediaries, or workers.

b. Antitrust

Business Partners must adhere to all antitrust and fair competition laws that govern the jurisdictions in which they operate. This includes not participating in any of the following: price fixing, volume/capacity agreements among Business Partners, collusive bidding, market/customer allocation, illegal price discrimination in products, tie-ins, attempts to monopolize any market, reciprocal dealing requirements, and theft or trade secrets.

c. Conflicts of Interest

Business Partners should avoid the appearance of or actual improprieties or conflicts of interest. JetBlue’s Business Partners must disclose promptly all information regarding financial and personal relationships, arrangements with JetBlue Crewmembers, representatives, or their close relatives that could appear to influence the negotiation process or the outcome of an agreement, or potentially create a conflict of interest. 

d. Insider Trading

Business Partners must not buy or sell JetBlue or another company’s securities when in possession of “material, non-public information” about JetBlue or another company that could influence an investor’s decision to buy or sell the security.

e. Press

Business Partners are prohibited from speaking to the press on behalf of JetBlue without written express authorization from JetBlue.

f. Business Records

Business Partners must honestly and accurately record and report all business information and dealings and comply with all applicable laws regarding their completion and accuracy. Our Business Partners are required to create, retain, and dispose of business records in full compliance with all applicable legal and regulatory requirements. The falsification of records and/or misrepresentation of conditions or practices in the supply chain is unacceptable.

g. Gifts

Business Partners are permitted to offer JetBlue Crewmembers business gifts or hospitalities as long as the gift or hospitality is customary in size, cost, frequency, or nature. JetBlue’s Gift Policy contains guidelines of acceptable and unacceptable gifts; specifies that gifts cannot be offered during an active RFP, contract renewal, or contract negotiations; and requires gifts valued at $250 or more to be disclosed, and gifts valued at $500 or more to be approved.

h. Intellectual Property

Business Partners must protect JetBlue’s intellectual property, including trademarks, patents, copyrights, business methodologies, and trade secrets. Business Partners may not use any of JetBlue’s intellectual property or confidential information except as provided in the Business Partner’s contract.

i. Privacy and Data Protection

Business Partners must have privacy and security programs in place to ensure the protection of personal information of everyone they conduct business with, including Business Partners, Crewmembers, Customers, and consumers. Business Partners must also comply with all privacy and security laws and regulatory requirements regarding the collection, storage, process, and transmission of personal information, such as the General Data Protection Regulation.

j. Responsible Sourcing of Minerals

Business Partners that supply products that include minerals sourced from conflict-affected and high-risk areas, including but not limited to cobalt, tantalum, tin, tungsten, or gold, must ensure that the sourcing of these minerals does not directly or indirectly finance or benefit armed groups or contribute to serious human rights abuses in Conflict-Affected and High-Risk Areas, as defined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Our Business Partners must exercise due diligence on the source and chain of custody of these minerals.

6. Management Systems

JetBlue expects its Business Partners to maintain an effective management system that allows the company to comply with applicable laws and regulations and adhere to this Code. The system should include a process for the identification and mitigation of risks related to this Code and allow the facilitation of continuous improvement of our Business Partners’ social and environmental performance. 

a. Audits

While we expect our Business Partners to self-monitor and demonstrate their compliance with the Code, JetBlue may audit a Business Partner or inspect a Business Partner’s facilities in order to confirm compliance. If requested by JetBlue, Business Partners are expected to provide details and data about their performance on the topics included in this Code.

b. Complaint Mechanism

Business Partners should have a process through which employees can raise workplace concerns without fear of retaliation. This complaint mechanism should be transparent and understandable to all employees and should recognize the sensitivities associated with lodging a concern, especially by employees who are women, minorities, or people with disabilities.

c. Noncompliance with Code

Business Partners are required to report to the Business Ethics and Compliance team or the JetBlue Business Integrity Hotline any actual or suspected violations of this Code, JetBlue’s policies and procedures, and/or federal, state, or local law. If a Business Partner is found to be in violation of this Code, we expect the Business Partner to inform us immediately, remedy any violation in a timely and sensitive manner, and participate in a Progressive Remediation Program as defined by JetBlue. JetBlue reserves the right to immediately terminate any Business Partner that behaves in a manner that is unlawful or inconsistent with this Code.

d. Progressive Remediation Program

A Progressive Remediation Program may be administered for violations of this Code. JetBlue reserves the right to deviate from or modify this program depending on the nature, severity, and circumstances of the violation. The following are potential program steps that can be used subject to modification at JetBlue’s sole discretion:

• Initial Guidance – This step is designed to identify, determine scale, and document the issue and ensure that all involved parties are aware of the situation and of expected performance standards.
• Continued Guidance – If a new issue arises or an existing issue persists after Initial Guidance, JetBlue may issue Continued Guidance to the Business Partner explaining our expectations.
• Final Guidance – If an issue is severe but does not warrant termination of the relevant agreement between JetBlue and the Business Partner, or if an issue persists after Initial and Continued Guidance, JetBlue may issue Final Guidance to notify the Business Partner of our intent to suspend or terminate an agreement until the issue is resolved within an acceptable timeframe.
• Suspension or Termination – If an issue is severe in nature or has not been corrected with previous Guidance, JetBlue reserves the right to terminate or suspend the relevant agreement with the Business Partner.

e. Reporting

JetBlue maintains a number of channels for Crewmembers, Business Partners, and the public to raise concerns without reprisal.

• For guidance on this Code of Conduct and questions concerning laws and acceptable business practices, contact JetBlue’s Legal department at 1-718-709-3005.
• To anonymously report concerns and potential or actual violations of this Code, contact our JetBlue Business Integrity Hotline at 1-866-318-7453 or visit www.jblu.alertline.com. Our hotline is operated by an independent third party and is available 24 hours a day, 7 days a week. Concerns will be routed to the appropriate JetBlue Leadership for investigation.  

JetBlue will maintain confidentiality to the extent possible and will not tolerate any form of retaliation against anyone who, in good faith, reports misconduct or noncompliance with this Code.

JetBlue will periodically review this Code to ensure that it continues to reflect the most important environmental, social, and governance issues that affect JetBlue, its Business Partners, and society.