Reporting Violations of the Code
Violations of this Code of Business Conduct cannot and will not be tolerated. Consequences for such violations may include disciplinary action up to and including termination of employment. Individuals who have willfully failed to report known violations will also be subject to disciplinary action. Any person who believes that provisions of this Code have been or will be violated should promptly report any such violation or possible violation by calling the Pinnacle Airlines Code of Business Conduct hotline at 1-877-778-5463 or logging on the Pinnacle Airlines web site, www.pncl.com, linking to the Code Business of Conduct page, and linking to the Pinnacle Airlines hotline web site. Persons may also report a violation via email to PinnacleHotline@report-it.com or mail correspondence directly to the hotline as follows:
Report It
C/O Pinnacle Airlines
P.O. Box 163
Oakdale, New York 11769
Employees reporting good faith concerns regarding questionable accounting, internal accounting controls or auditing matters are permitted to do so on a confidential and anonymous basis. When calling the above hotline telephone number or logging on the hotline web site, the caller will be provided a password and login identification where he/she can call back or login at a later date and respond anonymously to questions or other communications regarding the reported incident. Employees will be unable to establish this anonymous communication feedback channel if they
report violations via regular mail or electronic mail.
An employee may report any violation of the Code or applicable law directly to the Company’s Legal Counsel by writing to the Pinnacle Airlines Legal Counsel, c/o Baker, Donelson, Bearman, Caldwell & Berkowitz, 165 Madison Avenue, Suite 2000, Memphis, TN 38103 or email to schafetz@bakerdonelson.com. If employees wish to register any complaint to the Audit Committee of the Board of Directors regarding accounting, internal accounting controls or
auditing matters, or deliver an anonymous submission of such concerns, they may write to:
Chairman of the Audit Committee
1689 Nonconnah Blvd., Suite 111
Memphis, TN 38132
Employees are encouraged (but not required) to provide their names and contact information when communicating directly with the Corporate Legal Counsel or Chairman of the Audit Committee in case the concerns reported require further information. Good faith reporting of violations or possible violations of this Code or applicable law will not
result in adverse consequences to the person reporting them even if the perceived violations are ultimately proven not to have occurred. This Code is intended to provide guidance to employees. It is not intended to be, nor can it be, an exhaustive list of approved or non-approved conduct.
Should an ethical question arise with respect to any proposed conduct that cannot be resolved
with the help of this Code, discuss the question with your supervisor. If further guidance is
necessary, feel free to contact the Chief Compliance Officer. Remember that honesty, prudence
and fairness are the touchstones of good business conduct.
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