This Code of Ethics set out our expectation on how our company’s employees or ou representatives will conduct business in accordance with the law, our policies, our values and our business-ethics principles.

We expect our customers, suppliers, vendors, contractors and partners to mirror and/or adapt ethics and compliance standards that are consistent with our values in all material respects.

This Code of Ethics automatically applies to any person preforming the Advisory & Educational Services on behalf of J. SUBILIA AVIALEGAL LLC.


At every level, experts providing services on behalf of J. SUBILIA AVIALEGAL LLC are expected to be honest, trustworthy, and straightforward in both personal and business dealings, in accordance with both the letter and the spirit of all applicable laws and regulations.


We will agree independently and in advance on the basis for our fees and expenses and will charge fees and expenses that we consider reasonable, legitimate, and commensurate with the services we deliver and the responsibility we accept.

Confidentiality and Data privacy

Safeguarding confidential information is fundamental to the services J. SUBILIA AVIALEGAL LLC provides. J. SUBILIA AVIALEGAL LLC is committed to protecting confidential and personal data including that of J. SUBILIA AVIALEGAL LLC clients and third parties, and to continually monitor legal requirements to support compliance. Client confidential information is all non-public information (regardless of whether confidential information is received verbally, on paper, in an email, or in any other form), including business plans and trade secrets, client names, the nature of our client services, our recommendations or advice, client data, and information we purchase at our clients’ expense. We keep client information and records of client engagements confidential and use proprietary client information only with the client’s permission. We only share client confidential information with colleagues who have a legitimate need to know, or those we know are authorised to access the information. Confidentiality will remain during but also after the completion of the Services. You will find further information on our privacy commitments in our Privacy policy.


We do not allow conflict of interest, or undue influence of others to override our objective professional or business judgments. Therefore, we check potential conflicts of interest before entering into new advisory services and we regularly monitor our client’s situation to make sure conflicts of interest are at all time avoided. We will not allow conflicts of interest which provide a competitive advantage to one client through our use of confidential information from another client who is a direct competitor without that competitor’s permission. We will immediately acknowledge any influences on our objectivity to our clients and will offer to withdraw from a consulting engagement when our objectivity or integrity may be impaired.


We are committed to delivering highest quality services to the best of our abilities to all our clients and we hold our experts accountable for that quality. We expect to oversee our work, ensure that the conditions for quality are in place, and to bring our best capabilities to every situation. We will accept only engagements for which we consider to be qualified by our experience and competence. We will assign staff to client engagements in accord with their experience, knowledge, and expertise. We partner with other highly qualified experts and engage individuals, including Senior Advisors, from outside J. SUBILIA AVIALEGAL LLC to bring the best to our clients. Although J. SUBILIA AVIALEGAL LLC cannot be hold responsible for third-party service providers, we make sure to identify third-party providers that meet the client’s highest expectations, based on experience and competence, and also share the same principles and values.

Social and environmental responsibility

We take into consideration the social and environmental impact of our activities in our corporate decisions. This strong commitment is part of J. SUBILIA AVIALEGAL LLC’s DNA and is reflected in J. SUBILIA AVIALEGAL LLC ’s Bylaws. We make sure to comply with all applicable Human rights laws and applicable anti-corruption and anti-bribery regulations. We make sure to address these key considerations in the advice and trainings we provide, to help our clients to always act in a manner that is consistent with relevant laws and regulations and also to be mindful of their social impact, to actively debate the impact of our recommendations on shareholder, employees, customer, and other stakeholders. By doing this, we strongly believe that we help our client to capitalise on new opportunities and assess and manage risk to deliver responsible growth.

Internal and external stakeholders can contact us to communicate any business ethics-related concerns or seek guidance on inquiries.


Nov. 2020