Code of Ethics

As the airline, employer and investment of choice, SkyWest, Inc. understands the importance of ensuring the security of all stakeholders through an unwavering commitment to corporate integrity, no matter the environment. We also believe good governance is a source of competitive advantage. The SkyWest, Inc. Board of Directors is responsible for the control and direction of the company, and governed by a Code of Ethics, the Board represents and is accountable to our stakeholders. Our corporate governance policies are designed for not only compliance, but to drive effective use of the collective skills and experience of directors, officers and employees for ethical, responsible, and superior performance.

If you are aware of any suspected or known violations of this Code of Ethics, our corporate governance policies, or any state or federal law, you are encouraged to promptly report such concerns at any time through our Business Conduct address directorgovernmentlegalaffairs@skywest.com, SkyWest will handle all inquiries discreetly and make every effort to maintain, with the limits allowed by the law, the confidentiality of anyone requesting guidance or reporting a possible violation.

This Code of Ethics for Senior Executive Officers (the “Code”) of SkyWest, Inc. (the “Company”) contains the ethical principles by which the chief executive officer, president, chief operating officer, chief commercial officer, chief financial officer and principal accounting officer or controller of the Company (the “Senior Officers”) are expected to conduct themselves when carrying out their duties and responsibilities. This Code supplements, but does not replace, other codes handbooks or policies applicable to the Senior Officers, including, the Company’s Insider Trading Policy.

Ethical Principles

  • act ethically with honesty and integrity, including ethically handling actual or apparent conflicts of interest between personal and professional relationships;
  • promote full, fair, accurate, timely and understandable disclosure in reports and documents that the Company files with , or submits to, the United States Securities and Exchange Commission and in other public communications that the Company makes;
  • comply in all material respects with laws, rules and regulations of national, state, provincial and local governments and their agencies that affect the conduct of the Company’s business and the Company’s financial reporting;
  • comply in all material respects with the listing standards and rules and regulations applicable to listed companies for any national securities exchange or automated inter-dealer quotation system on which the Company’s securities are traded;
  • respect the confidentiality of information acquired in the course of the Senior Officer’s work except when authorized or otherwise legally obligated to disclose that information;
  • not use confidential information of the Company of the personal advantage of the Senior Officer or acquaintances, friends or relatives of the Senior Officer; and
  • promote honest and ethical behavior by others in the work environment.

Waivers

Waivers of any provision of this Code shall be made only by the Board of Directors, after consideration of the requested waiver by the Audit and Finance Committee of the Board of Directors. Persons seeking a waiver should be prepared to disclose to the Audit and Finance Committee all pertinent facts and circumstances, respond to inquiries for additional information, explain why the waiver is necessary, appropriate, or not adverse to the interests of the Company, and comply with any procedures that may be required by the Board of Directors to protect the Company in connection with a waiver. The Audit and Finance Committee will make non-binding recommendations to the Board of Directors regarding requested waivers. If a waiver of this Code is granted for any Senior Officer, appropriate disclosure will be made in accordance with legal requirements and applicable stock exchange regulations.

 

Compliance Procedures

Violations and reasonable suspicions of violations of this Code should be reported promptly to the Chairman of the Audit and Finance Committee (or through the use of the Company’s confidential and anonymous compliance procedures for reporting ethical violations, i.e., “Whistleblower Policy”). The reporting person should make full disclosure of all pertinent facts and circumstances. The Company does not permit retaliation of any kind for good faith reports of ethical violations. The Chairman of the Audit and Finance Committee will address the possible violation with the Audit and Finance Committee. If the reporting person has reason to believe that the Chairman of the Audit and Finance Committee is involved in the possible violation, the reporting person should report the possible violation to any other member of the Audit and Finance Committee.

Each Senior Officer shall be provided with a copy of this Code. This Code may also be provided to any other employee as any Senior Officer deems appropriate. Each Senior Officer shall sign a written affirmation acknowledging that the Senior Officer has received, read and understood this Code. Any Senior Officer, manager, executive officer or employee to whom this Code has been provided may be required, from time to time, to sign a written affirmation stating that the person (1) has received and read this Code and understands its contents, (2) has not violated this Code, and (3) has no knowledge of any violation of this Code that has not been communicated previously to the Chairman of the Audit and Finance Committee.

Violations

Each Senior Officer is accountable for his or her compliance with this Code. Violations of this Code may result in disciplinary action against the violator, including dismissal from employment when deemed appropriate. Each case will be judged by the Audit and Finance Committee on its own merits considering the duties of the person and the significance of the circumstances involved.

Amendment

Any amendment to this Code shall be made only by the Board of Directors or the appropriate committee thereof. If an amendment to this Code is made, appropriate disclosure will be made in accordance with legal requirements and applicable stock exchange regulations.

No Rights Created

This Code is a statement of certain fundamental principles, policies and procedures that govern the Senior Officers in the conduct of the Company’s business. It is not intended to and does not create any rights in any employee, customer, supplier, competitor, shareholder or other person or entity.