United Airlines Holdings Inc

United's Disclosure Council and other appropriate United subject matter experts are involved in the preparation and review of United's filings with the SEC in a process designed to confirm United's compliance with Applicable Disclosure Requirements and United's disclosure of information that is material to investors in the context of SEC periodic reports. United's Disclosure Council meets on a quarterly basis to review United's prior and proposed new disclosures and discuss any changes that may be appropriate as a result of potentially material events, trends and risks identified in a process designed to ensure all material events, trends and risks, either quantitatively or qualitatively, to United's business, financial condition, liquidity and results of operations are appropriately disclosed in its SEC filings. [...] United's Disclosure Council and other appropriate United subject matter experts also review United's risk factor disclosures to identify potentially material risks for disclosure.

United has established the United Airlines, Inc. Political Action Committee (the "UAPAC") to encourage its employees to participate in the political process. The UAPAC is a voluntary unincorporated organization established pursuant to the Federal Election Campaign Act of 1971, as amended. In accordance with federal law, United's executives, administrative personnel and stockholders may make voluntary contributions to the UAPAC. Foreign nationals and represented employees may not contribute to the UAPAC. The UAPAC is governed by a board of directors (the "UAPAC Board of Directors"), which consists of senior leaders from across United. The UAPAC Board of Directors also oversees all of United's corporate political contributions and provides annual reports regarding United's corporate political contributions to the Public Responsibility Committee of the United Airlines Holdings, Inc. Board of Directors (the "UAL Board"). [...] United and its subsidiaries are committed to the highest ethical standards, and we have procedures and policies in place designed to ensure that our policy advocacy, political contributions, lobbying expenditures and related activities, are subject to appropriate oversight. We take diligent steps designed to ensure that we are in compliance with applicable rules, regulations and our Code of Ethics and Business Conduct, which is publicly available on our website at ir.united.com At least annually, the Public Responsibility Committee reviews this policy and recommends any revisions it deems necessary or appropriate to the UAL Board. [...] Our policy advocacy and lobbying activities are determined by senior management with oversight by the UAL Board, which has delegated this oversight responsibility to its Public Responsibility Committee. Our Government Affairs and Global Public Policy organization oversees and executes our policy advocacy, lobbying expenditures and related activities. Our Executive Vice President of Government Affairs and Global Public Policy also reports regularly to the UAL Board on our policy advocacy, lobbying expenditures and related activities, periodically reviewing with the Public Responsibility Committee the strategic priorities for United's lobbying activity. [...] The UAL Board has delegated oversight responsibility of our political contributions to its Public Responsibility Committee. Our Government Affairs and Global Public Policy organization makes recommendations on political contributions to the UAPAC Board of Directors, who, in turn, reviews and approves all UAPAC and corporate political contributions. Our Executive Vice President of Government Affairs and Global Public Policy provides the Public Responsibility Committee with an annual report on the political contributions of the Company and the UAPAC for the prior year.

### Accountability and oversight

United and its subsidiaries are committed to the highest ethical standards, and we have procedures and policies in place designed to ensure that our policy advocacy, political contributions, lobbying expenditures and related activities, are subject to appropriate oversight. We take diligent steps designed to ensure that we are in compliance with applicable rules, regulations and our Code of Ethics and Business Conduct, which is publicly available on our website at ir.united.com At least annually, the Public Responsibility Committee reviews this policy and recommends any revisions it deems necessary or appropriate to the UAL Board.

### Lobbying activity oversight

Our policy advocacy and lobbying activities are determined by senior management with oversight by the UAL Board, which has delegated this oversight responsibility to its Public Responsibility Committee. Our Government Affairs and Global Public Policy organization oversees and executes our policy advocacy, lobbying expenditures and related activities. Our Executive Vice President of Government Affairs and Global Public Policy also reports regularly to the UAL Board on our policy advocacy, lobbying expenditures and related activities, periodically reviewing with the Public Responsibility Committee the strategic priorities for United's lobbying activity.

### Political contributions oversight

The UAL Board has delegated oversight responsibility of our political contributions to its Public Responsibility Committee. Our Government Affairs and Global Public Policy organization makes recommendations on political contributions to the UAPAC Board of Directors, who, in turn, reviews and approves all UAPAC and corporate political contributions. Our Executive Vice President of Government Affairs and Global Public Policy provides the Public Responsibility Committee with an annual report on the political contributions of the Company and the UAPAC for the prior year.

United's public engagement on climate issues is coordinated through our International Regulatory Affairs and Government Affairs departments to ensure consistency across business divisions and geographies. Our environmental programs and policies, including environmental sustainability, are overseen by United's President and the Executive Vice President of Government Affairs and Global Public Policy. United's Managing Director of Global Environmental Affairs and Sustainability has day-to-day responsibility for environmental and sustainability matters and reports to the Executive Vice President of Government Affairs and Global Public Policy, allowing for greater synergy and alignment of our lobbying activities with our climate strategy.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]With policymakers, United has actively supported the Biden Administration's sustainable aviation fuel (SAF) Grand Challenge, and gone beyond to be a founding member of the Administration's First Movers Coalition. As part of this, United has committed to replacing at least 5% of its jet fuel with SAF that reduces GHG emissions by at least 85% by 2030.

At the international level, United was the only known airline whose CEO attended the 2021 UN Conference of the Parties (COP26) climate conference where the Sustainable Aviation Buyers Alliance, announced United as an airline founder of its new Aviators Group.

All of this engagement is not only to ensure the commercial scale of SAF in alignment with the goals of the Paris Agreement, but also to support inter-governmental and governmental commitments to the Paris Agreement.

United also sits on various working groups and engages through its trade associations, specifically the Environmental Sustainability Council and SAF Council at Airlines for America, its U.S. trade association, where it holds the co-chair position of the latter Council. United also sits on the IATA delegation to the International Civil Aviation Organization Committee on Aviation Environmental Protection for market-based measure working groups and the fuels task group.

United's engagement on environmental policy issues is coordinated with its International Regulatory Affairs and Government Affairs departments. At the senior executive level, environmental programs and policies, including climate change, are overseen by the President and the Senior Vice President of Government Affairs & Global International Policy. United's Chief Sustainability Officer & Managing Director of Global Environmental Affairs and Sustainability has day-to-day responsibility for environmental matters. The Public Responsibility Committee of the Board provides board oversight for United's policies and positioning with respect to social responsibility and public policy, including environmental responsibility. In addition to scheduled meetings, members of the committee meet with certain United officers to receive updates and discuss key issues directly. On an annual basis, the Public Responsibility Committee reviews United's environmental programs and policies, initiatives related to climate change, environmental regulations, and progress in fulfilling United's sustainability objectives and environmental commitments.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

Lobbying activity oversight

Our policy advocacy and lobbying activities are determined by senior management with oversight by the UAL Board, which has delegated this oversight responsibility to its Public Responsibility Committee. Our Government Affairs and Global Public Policy organization oversees and executes our policy advocacy, lobbying expenditures and related activities. Our Senior Vice President of Government Affairs and Global Public Policy also reports regularly to the UAL Board on our policy advocacy, lobbying expenditures and related activities, periodically reviewing with the Public Responsibility Committee the strategic priorities for United's lobbying activity.