ALASKA AIR GROUP, INC.

The Company has adopted a Code of Conduct and Ethics, which applies to all company employees, officers and the Board of Directors, and has appointed a Chief Ethics and Compliance Officer. All employees and officers are required to participate annually in training about the Code of Conduct and Ethics, and directors individually certify their familiarity with the Code of Conduct and Ethics each year.

The Code of Conduct and Ethics may be found on the Company’s website at www.alaskaair.com under About Alaska/Investor Relations. Information on the Company’s website, however, does not form a part of and is not incorporated by reference to this Proxy Statement. The Company discloses on its website any amendments (other than technical, administrative or non-substantive amendments) to, and any waivers from, provisions of the Code of Conduct and Ethics granted to directors or executive officers to the extent required by applicable NYSE listing standards and SEC rules.