# GCBA Code of Professional Conduct **Reference:** GCBA-CPC-001 **Version:** 1.0 **Status:** Public Draft **Published:** TBC **Next review:** TBC This document is a public draft of the Global Charter Brokers Association Code of Professional Conduct. It establishes the fundamental obligations accepted by GCBA broker members, covering transparency, lawful charter, operator due diligence, client care and professional integrity. GCBA is an industry association. It is not an aviation authority, aircraft operator, direct air carrier, government regulator or substitute for legal or aviation-safety advice. Membership of GCBA does not replace any licence, registration, authorisation or legal obligation applicable to a member. National and international laws always take precedence over this Code. This document should be reviewed by aviation counsel in the organisation's registration jurisdiction before it becomes a binding membership obligation. --- ## 1. Preamble Air charter brokers play an important role in connecting clients with appropriately authorised aircraft operators and coordinating complex private aviation requirements. Professional air charter brokerage depends on integrity, transparency, competence, responsible operator selection and clear communication between clients, brokers, operators and other parties. The Global Charter Brokers Association has adopted this Code of Professional Conduct to establish the fundamental behaviours expected of its members and to support greater trust, professionalism and collaboration throughout the international charter brokerage industry. Membership of GCBA does not replace any licence, registration, authorisation or legal obligation applicable to a member. National and international laws always take precedence over this Code. GCBA is an industry association. It is not an aviation authority, aircraft operator, direct air carrier or guarantor of any flight. ## 2. Purpose The purposes of this Code are to: - establish minimum professional expectations for GCBA members; - promote transparent and responsible air charter brokerage; - protect clients from misleading, unlawful or unprofessional practices; - encourage effective operator and flight due diligence; - improve cooperation among brokers, operators and other aviation professionals; - provide a foundation for GCBA membership, standards and disciplinary processes; and - strengthen public confidence in professional charter brokerage. ## 3. Application ### 3.1 Members covered This Code applies to: - Charter Broker Members; - Provisional Broker Members; - individual professional members engaged in brokerage; - directors and senior managers responsible for a member's brokerage activities; - employees, contractors and representatives acting on behalf of a member; and - other membership categories where the relevant obligation can reasonably apply. ### 3.2 Organisational responsibility Member companies must take reasonable steps to ensure that their employees, representatives and subcontractors understand and follow this Code. A member may not avoid responsibility by delegating an activity to an employee, affiliated company, subcontractor, technology platform or another broker. ### 3.3 Applicable law Members must comply with all laws, regulations, licensing requirements, sanctions, tax obligations and consumer-protection requirements applicable to their business and each transaction. Where this Code and applicable law impose different requirements, the stricter lawful requirement should normally be followed. ## 4. Integrity and Professional Conduct Members must: - Act honestly, fairly, responsibly and in good faith. - Conduct business with appropriate care, skill and professional judgement. - Not knowingly participate in fraud, misrepresentation, illegal charter activity, bribery, corruption or the evasion of regulatory requirements. - Honour contractual commitments and professional representations. - Correct material errors promptly after discovering them. - Not place commercial pressure on an operator, crew member, airport, handling agent or other party to act unlawfully or compromise safety. ## 5. Clear Identification of the Broker's Role ### 5.1 Broker identity Members must clearly identify themselves as air charter brokers when they are acting as brokers. Members must not represent themselves as aircraft operators, direct air carriers or aircraft owners unless that representation is accurate and legally supportable. ### 5.2 Role in each transaction Before a client enters into a charter commitment, the member must clearly explain the capacity in which it is acting, where relevant, including whether it acts: - as agent for the client; - as agent for the aircraft operator; - as a principal or indirect air carrier where legally permitted; - as an intermediary for another broker; or - in another legally recognised capacity. ### 5.3 Operational control Members must make clear that operational control of a flight remains with the appropriately authorised aircraft operator. A broker must not suggest that it controls operational matters reserved to the operator, including: - aircraft dispatch; - crew decisions; - operational safety; - weather acceptance; - fuel planning; - aircraft substitution for operational reasons; - flight-duty decisions; or - the final decision to operate, delay, divert or cancel a flight. ### 5.4 Marketing language Members must not use language, branding, aircraft imagery or other representations that create a materially misleading impression that the broker owns or operates an aircraft fleet. Statements such as "our fleet," "our aircraft" or "our pilots" should only be used when factually accurate and not misleading in context. ## 6. Authority, Agency and Conflicts of Interest ### 6.1 Client authority Members must act within the authority granted by the client or other appointing party. ### 6.2 Conflicts Members must identify, manage and, where material, disclose conflicts of interest that could reasonably affect their independence or recommendations. ### 6.3 Financial interests Members must not obtain a secret profit or undisclosed financial benefit in breach of: - applicable law; - the member's stated role; - an agency obligation; - an agreed pricing structure; or - the member's contract with the client or operator. ### 6.4 Related parties A material ownership, referral, commission or commercial relationship with a recommended operator, broker or service provider must be disclosed when required by law or where the relationship could reasonably influence the client's decision. ### 6.5 Multiple intermediaries Where another broker or intermediary is materially involved in arranging the flight, the member must not deliberately conceal that involvement where disclosure is required by law, contract or the legitimate interests of the client. ## 7. Operator Verification and Prevention of Illegal Charter ### 7.1 Due diligence Before arranging a flight, members must undertake reasonable and documented due diligence appropriate to: - the jurisdiction; - the aircraft; - the proposed operation; - the operator; - the client's requirements; and - the information reasonably available to the broker. ### 7.2 Operating authority Members must take reasonable steps to establish that the proposed flight will be operated by an appropriately licensed or authorised direct air carrier. Depending on the jurisdiction, relevant evidence may include: - an Air Operator Certificate; - operating specifications; - Part 135 authority; - commercial air transport permissions; - aircraft listings; - applicable foreign-carrier permissions; and - other regulatory documentation. ### 7.3 Insurance Members must take reasonable steps to establish that the operator maintains insurance appropriate to the proposed operation and applicable legal requirements. Members must not misrepresent the scope or amount of an operator's insurance. ### 7.4 Aircraft and operator identity Members should maintain records identifying the intended operator and aircraft or aircraft category, subject to legitimate operational substitutions. ### 7.5 Unresolved concerns A member must not knowingly arrange, promote or facilitate an unlawful or unauthorised commercial flight. Where a material concern regarding operating authority or legality cannot be resolved, the member must suspend or decline the arrangement. ### 7.6 Regulatory avoidance Members must not knowingly use or recommend sham leases, artificial structures, misleading cost-sharing arrangements or other mechanisms intended to disguise an unlawful commercial charter operation. ## 8. Operator and Flight Disclosure ### 8.1 Operator identity The identity of the operator exercising operational control must be communicated to the client before the charter contract is concluded where it is known and where disclosure is legally required. ### 8.2 Changes If the operator or another material aspect of the flight changes, the member must notify the client promptly and explain any material effect on: - price; - aircraft; - capacity; - schedule; - contractual rights; - safety representation; or - service level. ### 8.3 Aircraft substitutions Members must not represent an aircraft type, model, age, configuration or registration as guaranteed unless it is contractually guaranteed. ### 8.4 Safety representations Statements about operator safety audits, ratings, certifications or third-party assessments must be accurate, current and capable of substantiation. Membership of GCBA must not be presented as an aircraft safety certification. ## 9. Competence and Duty of Care ### 9.1 Professional knowledge Members must maintain knowledge appropriate to the services they provide, including relevant understanding of: - aircraft categories and capabilities; - airport limitations; - passenger and baggage requirements; - commercial charter regulations; - operator documentation; - charter contracts; - operational-control principles; - international flight requirements; - payment risks; and - client communication. ### 9.2 Aircraft suitability Members must use reasonable care when recommending an aircraft or charter solution. Relevant considerations may include: - passenger numbers; - baggage; - pets; - range; - runway performance; - airport access; - cabin requirements; - accessibility needs; - permits; - expected weather; - crew-duty limitations; and - schedule feasibility. ### 9.3 Specialist services Members arranging medical, dangerous-goods, cargo, government, high-risk or other specialist operations must use personnel and providers with suitable expertise. ### 9.4 No guarantee of operational outcome Members must not guarantee that a flight will operate where the decision depends on weather, safety, regulatory approval, airport availability or the operator's operational judgement. ## 10. Quotations, Pricing and Contracts ### 10.1 Clear quotations Quotations must be presented clearly and must not intentionally omit material charges that the member reasonably expects will apply. ### 10.2 Price assumptions Where relevant, the quotation or accompanying communication should explain: - taxes and fees; - positioning costs; - de-icing; - waiting time; - overnight costs; - airport charges; - parking; - catering; - ground transportation; - passenger taxes; - currency assumptions; and - other material exclusions or variable costs. ### 10.3 Contracting party The client must be able to understand which company it is contracting with and the role of each material party. ### 10.4 Terms before commitment Clients must be given a reasonable opportunity to review applicable terms before making a binding commitment or non-refundable payment. ### 10.5 Cancellation terms Cancellation, refund, substitution and additional-cost provisions must be communicated clearly and must not be deliberately hidden or presented in a misleading manner. ### 10.6 Changes in price Members must promptly communicate material price changes and must not impose charges that have no contractual or lawful basis. ## 11. Client Funds and Financial Accountability ### 11.1 Use of funds Client funds must be used and administered in accordance with: - the applicable contract; - the member's disclosed role; - applicable law; and - any representation made to the client. ### 11.2 Accurate descriptions Members must not describe funds as protected, segregated, held in escrow or held in trust unless that description is accurate and legally supportable. ### 11.3 Records Members must maintain complete and accurate records of material payments, refunds, credits and disbursements. ### 11.4 Refunds Refunds that are contractually or legally due must be processed without unreasonable delay. ### 11.5 Financial distress A member must not continue accepting client payments where it knows, or should reasonably know, that it cannot meet the resulting obligations without clearly disclosing the material risk and taking lawful protective measures. ### 11.6 Payment fraud Members must maintain reasonable controls intended to prevent payment diversion, invoice fraud and unauthorised changes to bank details. ## 12. Advertising, Communications and Digital Services ### 12.1 Accuracy Advertising, websites, social-media content, quotations and direct communications must be truthful, clear and not materially misleading. ### 12.2 Availability and pricing Members must not knowingly advertise aircraft, flights, empty legs or prices that are fictitious, materially outdated or unavailable solely to generate enquiries. Indicative prices must be identified as indicative. ### 12.3 Credentials Members must not claim licences, memberships, approvals, accreditations, partnerships, awards or certifications they do not hold. ### 12.4 Testimonials and reviews Testimonials, reviews and endorsements must not be fabricated or materially altered in a misleading manner. ### 12.5 Artificial intelligence Where artificial intelligence or automated systems materially contribute to a recommendation, quotation, aircraft match or client communication, the member remains responsible for the resulting service. Members must take reasonable steps to: - review material automated outputs; - prevent fabricated aircraft or operator information; - protect confidential data; - distinguish indicative results from confirmed availability; and - provide human review before a binding charter commitment. ### 12.6 Corrections Materially inaccurate public information must be corrected within a reasonable period after the member becomes aware of it. ## 13. Confidentiality, Privacy and Cybersecurity ### 13.1 Confidential information Members must protect confidential client, passenger, operator and commercial information. ### 13.2 Data protection Personal data must be collected, processed, retained and shared in accordance with applicable data-protection and privacy laws. ### 13.3 Data minimisation Members should collect only information reasonably required for the charter, legal compliance, security, service delivery or another legitimate business purpose. ### 13.4 Sensitive information Passenger identification, travel itineraries, medical information, payment data and security-related information must receive appropriate protection. ### 13.5 Security measures Members must maintain reasonable technical and organisational safeguards appropriate to the nature of the information they hold. ### 13.6 Data incidents Material data breaches or cybersecurity incidents must be handled promptly and reported where required by law. ## 14. Sanctions, Financial Crime and Anti-Corruption Members must: - Maintain risk-based procedures appropriate to their business for sanctions, fraud, money laundering and other financial-crime risks. - Not knowingly arrange transportation in violation of applicable sanctions, export controls or legal restrictions. - Not offer, request, accept or facilitate bribes, kickbacks or improper advantages. - Take reasonable steps to identify suspicious payment instructions, unusual intermediaries or attempts to conceal the identity of a contracting party where legally relevant. - Seek specialist advice or decline a transaction where a significant compliance concern cannot be resolved. ## 15. Relationships With Operators, Brokers and Other Professionals ### 15.1 Respect and fairness Members must treat operators, other brokers, employees, suppliers and professional partners fairly and respectfully. ### 15.2 Accurate representation Members must not knowingly make false or malicious statements about another industry participant. This does not prevent good-faith reporting of safety, legal, regulatory, ethical or contractual concerns. ### 15.3 Confidential proposals Members must respect confidential pricing, aircraft availability and commercial information received from operators and other brokers. ### 15.4 Circumvention Members must not intentionally circumvent another broker, operator or intermediary in violation of an enforceable agreement or through dishonest use of confidential information. ### 15.5 Competition law GCBA activities and member collaboration must comply with applicable competition and antitrust laws. Members must not use GCBA meetings, working groups or communication channels to: - fix prices or commissions; - allocate clients or markets; - coordinate bids; - restrict lawful competition; - collectively exclude competitors; or - exchange competitively sensitive information without a legitimate and lawful purpose. ## 16. Complaints and Corrective Action ### 16.1 Complaints procedure Members must maintain an accessible and proportionate process for receiving and reviewing complaints. ### 16.2 Timely response Complaints must be acknowledged and addressed fairly within a reasonable period. ### 16.3 Evidence Members must preserve relevant documentation and provide the complainant with a clear explanation of the outcome, subject to confidentiality and legal restrictions. ### 16.4 Corrections Where a member identifies an error, breach or service failure, it must take appropriate corrective action. ### 16.5 No retaliation Members must not retaliate against a person solely for submitting a complaint or raising a concern in good faith. ### 16.6 GCBA process Members must cooperate honestly with an authorised GCBA complaints, profile-review or disciplinary process. ## 17. Staff Competence and Supervision ### 17.1 Training Members must provide training appropriate to each employee's responsibilities. ### 17.2 Supervision Inexperienced employees must receive appropriate supervision before independently managing complex or high-risk charter transactions. ### 17.3 Continuing development Members should support continuing professional development in areas relevant to their services. ### 17.4 Incentives Compensation and sales incentives should not encourage employees to: - conceal material information; - recommend unsuitable aircraft; - disregard operator-verification concerns; - misrepresent availability; or - prioritise commission over lawful and responsible conduct. ## 18. Records and Evidence Members must maintain records sufficient to demonstrate the proper handling of material charter transactions. Depending on the transaction and applicable law, records may include: - client requirements; - quotations; - contracts; - operator confirmations; - operating-authority documentation; - insurance information; - material disclosures; - passenger communications; - payment records; - changes and cancellations; - complaints; and - compliance checks. Records must be retained securely for the period required by applicable law and the member's documented retention policy. ## 19. Use of GCBA Membership and Marks ### 19.1 Accurate status Members may only use the membership designation and GCBA marks authorised for their current membership status. ### 19.2 No safety guarantee Members must not represent GCBA membership as: - an operator licence; - a government approval; - a flight-safety guarantee; - an aircraft airworthiness certification; or - a substitute for client due diligence. ### 19.3 Suspension or termination A suspended, resigned or terminated member must stop using restricted GCBA marks and membership claims in accordance with GCBA rules. ### 19.4 Version transparency Where a member states that it has committed to this Code, the applicable version and status should be capable of verification through the GCBA website. ## 20. Reporting Material Matters to GCBA Members must inform GCBA promptly, in accordance with the Membership Rules, of matters that could materially affect membership eligibility or public confidence, including: - suspension or revocation of a relevant licence or registration; - a serious regulatory or criminal finding connected to the brokerage business; - insolvency or cessation of trading; - fraudulent use of a GCBA designation; - a material misstatement in the member's GCBA profile; or - another matter expressly required under GCBA membership rules. Reporting a matter does not automatically establish misconduct. GCBA must follow its published procedures before imposing a disciplinary measure. ## 21. Breaches and Enforcement An alleged breach of this Code will be considered under the GCBA Complaints and Disciplinary Procedure. Depending on seriousness, frequency, cooperation and corrective action, possible measures may include: - informal guidance; - required corrective action; - a formal warning; - mandatory training; - amendment of directory information; - temporary suspension; - restriction of membership privileges; - termination of membership; or - publication of a final sanction where permitted under GCBA policy and applicable law. GCBA must provide the member with: - notice of the material allegation; - a reasonable opportunity to respond; - an impartial review; - a reasoned decision; and - access to an appeal process. GCBA does not determine civil liability, award damages or replace courts, regulators, arbitration bodies or law-enforcement authorities. ## 22. Interpretation and Review ### 22.1 The GCBA Board or designated Standards Committee is responsible for the interpretation and periodic review of this Code. ### 22.2 Guidance notes may be published to support consistent application, but guidance must not silently amend the Code. ### 22.3 Material amendments must be: - assigned a new version number; - dated; - recorded in the public changelog; and - communicated to affected members. ### 22.4 Members will be given a reasonable period to implement material new requirements unless immediate action is required by law or to address a serious risk. ## 23. Member Declaration Each Charter Broker Member and Provisional Broker Member must make the following declaration: > We confirm that we have read and understood the GCBA Code of Professional Conduct. We agree to comply with the Code, maintain reasonable procedures to support compliance and cooperate with GCBA's published membership, review and disciplinary processes. We understand that GCBA membership does not constitute an operator licence, government approval or guarantee of flight safety. --- ## About this document The GCBA Code of Professional Conduct is an industry-association document setting out principles for professional air charter brokerage. It is not an independent certification, audit standard or regulatory approval. Detailed evidence requirements and audit criteria will be set out in separate GCBA Broker Standards. For the latest version, consultation status and change history, visit: https://brokers-association.com/standards/code-of-professional-conduct © Global Charter Brokers Association. All rights reserved.