Trusted partners in aviation's future.

Our experienced Board of Directors sets the tone for ethical conduct and principles and provides strategic oversight ensuring that appropriate governance policies and procedures are in place and championed throughout the organization. The Executive and Leadership Teams are responsible for the day-to-day operations of SMBC Aviation Capital including overseeing the implementation and operation of our governance framework, core SMBC Aviation Capital policies and the highest standards of business integrity. 

Some of the fundamental elements of our governance framework are as outlined below.

• Due diligence of customers and other counterparties is undertaken to ensure appropriate legal and ethical standards in our business dealings.
• Our internal governance structures are robust, open and transparent. We conduct regular meetings of our boards and committees to consider strategic direction as well as transactions and governance matters.
• Timely financial information is provided to relevant authorities, and our investor base is kept appropriately informed in a transparent manner.
• We have a comprehensive compliance framework comprising policies covering a range of areas including anti-money laundering, counter-terrorist financing, sanctions compliance, anti-fraud, anti-bribery, data protection and whistleblowing. Our staff are trained on these policies, and they are reviewed and updated on a regular basis. Further details on these core compliance policies are outlined below.
• We maintain our information security policy, procedures and standards to protect our data, systems, and stakeholder interests. Our policies and controls are regularly reviewed to address evolving cyber risks and ensure compliance with applicable laws and best practices.

We are committed to protecting our business and wider society from risks such as money laundering, terrorist financing, and sanctions breaches. These activities pose serious threats to society and to our business, customers, shareholders, and employees. Our Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Compliance Policies and Procedures set the framework for managing these risks, establishing minimum compliance standards and ensuring vigilance wherever our services are provided.

SMBC Aviation Capital is committed to the highest standards of honesty, integrity, and transparency, with a strong focus on preventing fraud and financial crime. Fraud can harm society and cause severe financial loss, reputational damage, and operational disruption. The Anti-Fraud Policy sets minimum standards to ensure our staff understand fraud, recognize its forms, and know their responsibilities for prevention and reporting. It also outlines consequences for fraudulent conduct or failure to report, fostering an anti-fraud culture and protecting our business.

SMBC Aviation Capital enforces a zero-tolerance policy on bribery and corruption, requiring compliance from all directors, employees, agents, and contractors. Bribery and corruption undermine trust, fair trade, and economic development, and violations can lead to severe consequences, including reputational damage, criminal liability, imprisonment, and huge fines. We adhere to all relevant anti-bribery laws, including the Irish Criminal Justice (Corruption Offences) Act 2018 (as amended), the U.S. Foreign Corrupt Practices Act (FCPA), and the U.K. Bribery Act 2010, as well as applicable local laws where we operate. 

A key element of our anti-bribery framework is our Gifts & Entertainment Policy. Legitimate business activities may involve corporate entertainment including the provision of gifts and entertainment. This Policy sets our global standards for offering, accepting, approving, and recording such exchanges. Permitted gifts and entertainment must be reasonable, proportionate, and for a clear business purpose, such as fostering business relationships. 
 

Our Whistleblowing Policy promotes a culture of openness by encouraging staff to report any actual or potential illegal or unethical conduct encountered during work. It outlines our commitment to addressing concerns and protecting individuals who report wrongdoing in line with the Irish Protected Disclosures Act 2014 (as amended in 2022).

The Policy ensures staff can raise concerns without fear of victimisation, discrimination, dismissal, or other detriment. It provides clear reporting channels and ensures that disclosures are taken seriously and investigated appropriately. We aim to safeguard reporting individuals and meet all obligations under Irish law. 

SMBC Aviation Capital expects all staff to uphold the highest standards of honesty, integrity, and transparency while complying with all laws and regulations. Our Policy sets clear rules addressing insider dealing, market manipulation, and unlawful disclosure under EU Market Abuse Regulations.  These measures prevent conflicts of interest and protect both employees and SMBC Aviation Capital from reputational and regulatory risk.

Data protection safeguards individuals’ fundamental right to privacy and protection for their Personal Data. The relevant legislation in this regard is the General Data Protection Regulation (“GDPR”) as supplemented in Ireland by the Data Protection Act 2018. SMBC Aviation Capital has in place a Data Protection Policy which outlines measures and steps to ensure compliance with GDPR and the Irish Data Protection Acts, reinforcing our commitment to privacy and data security.

SMBC Aviation Capital is committed to the highest standards of Environmental, Social, and Governance (ESG) performance across its operations and supply chain. Suppliers of goods and services must comply with all applicable laws and regulations and adhere to our Supplier Code of Conduct in both letter and spirit. The Supplier Code of Conduct sets minimum conduct expectations when acting for, with, or on behalf of SMBC Aviation Capital.

SMBC Aviation Capital maintains a zero-tolerance approach to slavery and human trafficking and requires the same high standards from employees, customers, investors, suppliers, and stakeholders. We comply with all applicable laws in this area, including Ireland’s Criminal Law (Human Trafficking) Acts and the UK Modern Slavery Act 2015. Our Modern Slavery Statement outlines measures taken during the financial year to ensure slavery and human trafficking do not occur within our business or supply chain, reinforcing our responsibility and transparency.