UALUnited Airlines Holdings

Policy Statement Regarding Related Party Transactions

“(a) the aggregate amount involved exceeds or is reasonably expected to exceed $120,000;”

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Policy Statement Regarding Related Party Transactions

“The Board recognizes that transactions involving the Company and related parties present a heightened risk of conflicts of interest. To enable the Company to act in the best interests of its stockholders, it has a written Policy Statement Regarding Related Party Transactions (the “Related Party Transaction Policy”).”

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Policy Statement Regarding Related Party Transactions

“Except for a limited set of transactions previously reviewed and approved, a Related Party Transaction (as defined below) must be reviewed and approved or ratified by the Audit Committee or the Chair of the Audit Committee if approval by the entire committee is impractical. In reviewing a proposed transaction, the Audit Committee or the Chair of the Audit Committee must consider all the material information available to them regarding the proposed transaction or Related Party that would be material to investors in light of the circumstances of the transaction, which includes whether the transaction is fair to the Company and is not inconsistent with the best interests of the Company and its stockholders.”

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Policy Statement Regarding Related Party Transactions

“If the Company enters into a transaction that (i) the Company was not aware constituted a Related Party Transaction at the time it was entered into but which it subsequently determines is a Related Party Transaction or (ii) did not constitute a Related Party Transaction at the time such transaction was entered into but thereafter becomes a Related Party Transaction, then such transaction shall be presented for ratification by the Audit Committee or the Chair of the Audit Committee.”

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Policy Statement Regarding Related Party Transactions

“(b) a Related Party had, has or will have a direct or indirect material interest (other than solely as a result of being a director, limited partner or less than 10% beneficial owner (together with all other Related Parties) of another entity that is party to the transaction); and (c) the Company is a participant.”

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Policy Statement Regarding Related Party Transactions

“A “Related Party” is a director, director nominee or executive officer of the Company, beneficial owner of more than 5% of the Company’s voting securities or such person’s immediate family member.”

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Related Party Transactions Since January 1, 2025

“John Gebo, Senior Vice President, Treasury, Fleet & Fuel of United Airlines, Inc., is the spouse of Kate Gebo, Executive Vice President, Human Resources and Labor Relations, of the Company. For 2025, Mr. Gebo received compensation, including base salary, incentive compensation awards and other customary officer and employee benefits that were determined in the ordinary course consistent with the process used for determining compensation levels for other officers and employees of United. The 2025 cash compensation and equity award values for Mr. Gebo were approximately $2,019,000. Mr. Gebo and Ms. Gebo do not report to, or determine the compensation of, each other.”

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Related Party Transactions Since January 1, 2025

“The Related Party Transaction Policy operates in conjunction with other aspects of the Company’s compliance program, including the requirement in the Corporate Governance Guidelines that directors disclose any potential conflict of interest to the Chairman before any decision is made related to the matter. If the Chairman, in consultation with legal counsel, determines that a conflict exists, or that the perception of a conflict is likely to be significant, then the director is obligated to recuse himself or herself from any discussion or vote related to the matter.”

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Related Party Transactions Since January 1, 2025

“The Company has a code of ethics, the “Code of Ethics and Business Conduct,” (the “Code of Conduct”) for its directors, officers and employees. The Code of Conduct serves as a “Code of Ethics” as defined by SEC regulations and as a “Code of Conduct” under Nasdaq Listing Rule 5610. The Code of Conduct addresses conflicts of interest, including disclosure of any situations or activities that might be perceived as a conflict of interest. The Code of Conduct is available on the Company’s investor relations website at ir.united.com. Waivers granted to certain officers from compliance with or future amendments to the Code of Conduct will be disclosed on the Company’s investor relations website in accordance with Item 5.05 of Form 8-K.”

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Securities trading POLICY

“The Company has adopted a Securities Trading Policy that governs the purchase, sale and any other dispositions of the Company’s securities by the Company’s directors, officers and employees and by the Company itself. The Company believes that this policy is reasonably designed to promote compliance with insider trading laws, rules and regulations, as well as the Nasdaq listing standards. A copy or our Securities Trading Policy is filed as Exhibit 19 to our Annual Report on Form 10-K for the 2025 fiscal year.”

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