ADM POLICY AVIANCA BRASIL

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1 AVIANCA BRASIL Prepared by Distribution Department OceanAir Linhas Aéreas S/A

2 INDEX 1. OBJECTIVES GENERAL CONCEPTS WHAT IS A BOOKING? WHAT IS AN UNPRODUCTIVE BOOKING OR SEGMENT? UNPRODUCTIVE PRACTICES AUDITED BY AVIANCA BRASIL NON-CANCELLED SEGMENTS CHURNING DUPLICATES DUPLICATE PNRS DUPLICATE SEGMENTS PASSIVE SEGMENTS FAKE NAMES FAKE TICKETS WAITLIST MARRIED SEGMENTS ABUSE OVERBOOKING IN CLOSED CLASSES HIDDEN GROUPS FLOWN TICKET NOT BILLED TICKET CANCELLED AND USED IRREGULARITIES IN ISSUES WITH CREDIT CARD FARE RULES VIOLATION IRREGULAR COMMISSIONS AND INCENTIVES SPLIT PAYMENT TRAVEL AGENCY PRODUCTIVITY ANALYSIS REACTIVATION OF ACCESS TO AIRLINE INVENTORY DISPUTE PROCESS BSPLink ARC POLICY VALIDITY SUMMARY OF THE FEES Page 2 / 17 15/01/2019

3 REVIEW CONTROL DATE PAGES CHANGES DESCRIPTION 01 31/05/2016 All Document creation 02 20/06/2016 All Overall adjustments 03 23/05/ Split Payment added 04 23/05/ Summary revision 04 15/10/2018 All Overall adjustments / Hidden Groups rule added 05 14/01/2019 All Fee adjustments and general corrections Page 3 / 17 15/01/2019

4 1. OBJCTIVES Ensure the airlines inventory integrity through bookings and ticket sale audits. Maintain a close commercial relationship with travel agencies. Through this policy, Avianca Brasil provides the guidelines and good practices for travel agencies to avoid debit memos. Promote good practices in reservation systems, in order to promote an efficient sales process. 2. GENERAL CONCEPTS The present document provides the aspects that travel agencies should consider when requesting, changing and/or cancelling segments operated by Avianca Brasil, which are made through the airline agency portal, the GDS (Global Distribution System) or a webservice. This document also strengthens the topics of the fare rules to be followed when issuing Avianca Brazil s tickets through the GDS or any other channel. The incorrect use of the GDS or any other channel, and the violation of fare rules will result in costs that will be of responsibility of the travel agencies. An ADM document will be issued to correct any difference in fare calculation, issues in the wrong plate, incorrect and/or undue reissue, refunds, commissions and taxes, or for non-compliance of any item described in the policy. Memos will be issued in agency s invoice and can only be disputed through the proper channel defined by the market, within the terms determined by and in accordance with IATA Resolution 850m and 890 for chargeback cases. These memos will be issued against the ticket issuing agency and/or the responsible for the creation of the booking. For incorrect bookings and/or issues, reissues and refunds procedures by travel agencies with billing method other than through BSP or ARC, Avianca Brasil reserves the right to invoice the travel agency and/or to inhibit its access to the inventory. For each ADM issued, a BRL 60 administrative-fee will be charged for agencies in Brazil and USD 25 for agencies in other countries. Values indicated for the charge of each unproductive practice can be modified by the airline at any time and without notice. 3. WHAT IS BOOKING? It is the reservation of a segment that corresponds to an origin and destination made via GDS or the airline system. Example: Salvador/Brasília/Salvador composed of two bookings Booking 1: Salvador / Brasília Booking 2: Brasília / Salvador 3.1 WHAT IS AN UMPRODUCTIVE BOOKING OR SEGMENT? A booking that does not generate any revenue to the airline and, instead, generates an additional cost and/or blocked seats, compromising the quality of the inventory. Avianca Brasil will audit all these transactions, and after confirmation of noncompliance, it reserves the right to issue an ADM or invoice. Page 4 / 17 15/01/2019

5 4. UNPRODUCTIVE PRACTICES AUDITED BY AVIANCA BRASIL Avianca Brasil audits the following: 1. Non-cancelled segments 2. Churning 3. Duplicates 4. Passive segments 5. Fake names 6. Fake tickets 7. Waitlist 8. Married segments abuse 9. Overbooking in closed classes 10. Hidden Groups 11. Flown ticket not billed 12. Ticket cancelled and used 13. Irregularities in issues with credit card 14. Fare rules violations 15. Irregular commissions and incentives 5. NON-CANCELLED SEGMENTS Non-cancelled segments are those sent to a specific queue of the agency, with status UC, UN, US, NO or HX. These segments should be cancelled according to the present policy, in order to avoid the debit memo or consider this incidence as an improper practice. Some of the reasons why the airline cancels bookings are: Expiration of time limit for issuing tickets; Duplicate reservations or segments; Fictitious names or tickets; Married Segments Abuse; Speculative bookings. Travel agencies are responsible for reviewing the queues and cancelling all those segments in order to avoid debit memos. The applicable charge for non-cancelled segments is USD 25 per segment/passenger. This charge is not applied in cases where a ticket is issued within the PNR. This charge is only applied for reservations with no ticket number associated to the passenger. Segments received in the queues should be cancelled according to the following: All messages status UC, UN, US, NO, HX received in the queue during the month should be cancelled within the same month in which segments were received in the corresponding queue. In case flight date occurs during the current month, segments UC, UN, US, NO, HX should be cancelled at least 24 hours prior to the scheduled flight departure time. Page 5 / 17 15/01/2019

6 daily basis. To avoid charges, review the queues in the respective systems and cancel all segments on a The entries to cancel the pending segments and their queues according to the GDS are: cancel segments. Note: Check with your GDS the corresponding queue for each status and the entries to Example of non-cancelled segments: 6. CHURNING Churning refers to the process of repeatedly creating and cancelling a segment for the same passenger that meets the following characteristics: Same travel date(s) Same or different flight number Same or different reservation. It will be considered a churning when the travel agency makes four cancellations and the fifth confirmation for the same segment, with the same IATA number. Applicable charge will be USD 30 per segment/passenger, regardless of the existence of a ticket or if the passenger has travelled. Page 6 / 17 15/01/2019

7 Only make changes on a booking when requested by the passenger, without exceeding the maximum allowed (4 cancellations). Before ending the reservation or making changes on the classes, check the availability in order not to make unnecessary bookings. Ticket must be issued before the fifth cancellation. Do not avoid ticket time limit by cancelling and rebooking segments. Example of Churning: The following reservation contains 5 cancellations and 6 bookings made by the travel agency: 7. DUPLICATE Refers to two or more reservations for the same passenger and that are active in the system simultaneously, with identical, overlapped or non-flyable itineraries. Duplicates are classified in: 7.1 DUPLICATE PNRs Avianca Brasil will audit PNRs created by the same Office ID / PCC (Pseudo City Code), from the same passenger (first name and first last name), same passport number or frequent flyer program, same primary contact information and with identical, overlapped or non-flyable itineraries. The itinerary can be classified in three basic types: Identical: at least one segment of origin/destination is exactly the same as the other, in flight number and travel date. Example: Page 7 / 17 15/01/2019

8 Example: Overlap: the PNR itinerary is within the range of dates from another PNR itinerary dates. Non-Flyable: the itinerary dates do not overlap each other, however, the last flight date of the first PNR is within the 48 hours after the first flight of the second PNR. It would be impossible for the passenger to travel both dates. Example: Page 8 / 17 15/01/2019

9 7.2 DUPLICATE SEGMENTS Reservations with two or more active segments within the same PNR, whose origin/destination is the same, for the same or different flight number and date. Example 1: Duplicated segments within the same reservation: Example 2: Duplicated segments within the same reservation with different flight number and dates: dates: Duplicated segments within the same reservation with the same flight number and different The applicable charge for duplicated reservations or segments will be USD 20 per segment/passenger, regardless of the existence of a ticket or if the passenger has travelled. Avoid making multiple reservations for the same passenger. Avoid duplicating segments within the same reservation, even if the segment has a different flight number or date. Avoid creating multiple reservations for the same passenger with different itineraries, and/or overlapped or non-flyable dates. In case of father and son with the same name and last name, it is recommended to include as main contact, a different contact associated to each passenger or the frequent flyer number of each passenger. Include the passenger contact details, and not only the agency information in order to distinguish reservations of homonyms passengers created at the same PCC (Pseudo Code City), IATA number or Office ID. It is recommended to use the following entries per GDS to check if there are reservations with Page 9 / 17 15/01/2019

10 the same information: AMADEUS GALILEO SABRE WORLDSPAN RT LR641/25JAN-SOBRENOME *LR641/25JAN- SOBRENOME *LR641/25JANSJO- SOBRENOME *LR641/25JANSJO- SOBRENOME Note: Check the entries with your GDS 8. PASSIVE SEGMENTS Avianca Brasil only allows reservations with this type of segments to IATA or ARC agents, for ticket issuing purposes. Passive segments cannot be used for others purposes, such as to reach productivity levels required in agreement between the agency and the GDS, and circumvent fare rules. Passive segments that are not used under the proposal described will be charged USD 10 per segment/passenger. Once the tickets are issued, any passive segments should be removed up to 24 hours prior to departure. 9. FAKE NAMES It is considered as fake, names entered incomplete or incorrectly, or with a high probability of not referring to a real passenger, for example: AAA/BBB ABCD/EFGH A/CRIS Any name that includes: NULL, NAME, PAX, PASSENGER, TEST, PRUEBA, MOUSE or similar. Airlines at worldwide level require that their passengers first and last name are complete and entered correctly. The applicable charge for reservations with fake names is of USD 30 per segment/passenger. time. Enter passenger s complete name according to the ID document to be presented at boarding Do not create speculative reservations just to price or deliver an itinerary to a passenger. For training purposes, use GDS test/training environment. Save supporting documents of passengers with names that can be considered as fake. 10. FAKE TICKETS Reservations with different numeration than a real ticket, included in the ticket field. It is considered as fake tickets those issued with the followings characteristics: Page 10 / 17 15/01/2019

11 Fake ticket number; Real ticket number used previously for another reservation; Ticket issued in a different route than booked; Ticket issued in name of a different person than booked; Cancelled tickets (VOID); Tickets with invalid check digit; MCO or any other accounting format used as fake ticket; Ticket number entered incorrectly. Bookings with fictitious ticket identified by Avianca Brasil before or after the departure date will be charged USD 50 per segment/passenger. Do not use invalid ticket numeration. When voiding a ticket, immediately cancel the booking in order to avoid blocking seats. Otherwise, the reservation will be subject to audit and applicable charges. 11. WAITLIST It is a segment pending confirmation according to availability and priority. Avianca Brasil does not use waitlist segments, thus this type of segment is not allowed. If identified any waitlist segments created in the GDS, it will be charged USD 10 per passenger/segment. Do not request segments on classes already closed or with no availability (0). 12. MARRIED SEGMENTS ABUSE Married segments are flight segments of an origin-destination (O&D) sold together and that cannot be separated, under no circumstance. They can be identified by a single availability display from the point of origin to the destination point. Abusive practices of travel agencies for married segments are: Manipulation in reservations of married segments in order to brake the Origin-Destination logic; Partial cancellation of itineraries; Flights reservations to a fictitious destination in order to find flight availability in a lower class. The applicable charge will be USD 175 per segment/passenger, regardless of the existence of a ticket or if the passenger has travelled. Book Origin-Destination based on current availability display, maintaining the married segments. When rebooking or changing the original booking, cancel all connecting flight segments. Page 11 / 17 15/01/2019

12 lower fare not available. Do not circumvent the logic of Origin-Destination looking for a space in a closed class or for a 13. OVERBOOKING IN CLOSED CLASSES Overbooking in closed classes refer to reservations made on classes not available for sale and confirmed by the travel agency in a forced manner, by imposing entries that confuse system logic. Below is an example of how this overbooking appears in the airline s host system: As shown, overbooked flight is AV0965 on February 5 th. The indicator OBLK confirms the forced overbooking in the system. Avianca Brasil will audit forced overbooked segments and will issue an ADM of USD 175 per segment/passenger, regardless of the existence of a ticket or if the passenger has travelled. Book segments based on availability information and only in available classes. Do not circumvent the logic of the system by using entries to force a space in a class that is not available for sale. It is important to know that forced overbooking is only identified in Avianca Brasil host system, since there is no register of these transactions in the GDS historic files. 14. HIDDEN GROUPS It is considered as hidden group multiple individual reservations that when combined characterize a group, i.e. 10 or more passengers, with the same origin-destination, the same flight date and created by the same agency. Reservations with issued ticket will not be charged. Avianca Brasil will perform a monthly audit for hidden groups and if identified, will cancel these PNRs and charge USD 20 per segment/passenger. Group bookings (10 or more passengers) should be requested according to Avianca Brasil group procedure. Do not create speculative reservations that block space in airline inventory. All reservations with the characteristics mentioned above and that were not created according to the airline group policy will be audit. Page 12 / 17 15/01/2019

13 15. FLOWN TICKET NOT BILLED When the ticket is used, however not paid, the airline will issue an ADM for the sale amount. 16. TICKET CANCELLED AND USED ADM for the sale amount. When ticket is reported as cancelled in sale/bsp report and is used, the airline will issue an 17. IRREGULARITIES IN ISSUES WITH CREDIT CARD It is considered as credit card irregularities the following: a) Error in indicating details of the form of payment when using credit card to issue the ticket (invalid installment plan, incorrect installment amount, non-existing number of installments, etc.). b) Chargeback. 18. FARE RULES VIOLATION ADMs may be issued whenever the travel agent fails to follow the rules of the fare or makes an error when issuing, reissuing or refunding the ticket, such as: Change of original fare; Fare difference not collected; Penalties not collected; Taxes not collected or incorrectly collected; Differences of class and fare basis; Booking class different than issuing class; Irregularly settled commissions; Change of name; Unauthorized revalidation; Incorrect use of form of payment; Incorrect valuation of coupons in reissues. 19. IRREGULAR COMMISSIONS AND INCENTIVES When commission and incentives are incorrectly or improperly applied, the airline will issue an ADM to charge the correct amount. 20. SPLIT PAYMENT Split Payment is a process within MY ARC only for agencies from the US and that allows the use of two forms of payment (cash + credit card). For one of these two forms of payment a MCO is generated with the amount of the form of payment (cash or credit card) + paid amount and form described. Page 13 / 17 15/01/2019

14 Since January 2018, the Split Payment process was initiated as well as the audit of tickets issued in the US with 02 forms of payment. This audit purpose is to ensure that all MCOs issued as a form of payment have a ticket associated to it and to check if the forms of payment are in accordance with the fare amount for each ticket. For each irregularity identified, an ADM will be generated to the IATA number of the issuing agency with the document (MCO without e-ticket) amount + service fee of BRL 60 for agencies in Brazil and USD 25 for agencies in other countries. 21. TRAVEL AGENCY PRODUCTIVITY ANALYSIS It refers to the comparison of the costs generated by one travel agency in relation to its sales in a determined period. The costs accounted to measure a travel agency productivity are the following: Request of flight availability Bookings creation, changes and cancellation Tickets issued Credit card Commissions and incentives. Cases to be evaluated: Case 1. Travel agency whose costs generated exceeds 10% of its sales. Case 2. Travel agency that only generates costs and does not generate sales. Actions that may be taken by the airline depending on inefficiency are: Disable access to interactive availability (seamless availability request); Disable full or partial access to inventory; Change the commercial relationship; Send a warning letter. This policy applies to both IATA/ARC agencies and non-iata/arc travel agencies. 22. REACTIVATION OF ACCESS TO AIRLINE INVENTORY Avianca Brasil reserves the right to suspend or disable access to inventory in case of unproductive practices such as: Unproductivity; Incorrect practices in the airline inventory; Fraud; IATA/ARC default status; Payment irregularities with the airline; Voluntary deactivation. Page 14 / 17 15/01/2019

15 be a charge of USD 300. If the travel agency was disabled and wishes to reactivate access to airline inventory, there will In order to reactivate access to the airline inventory the following steps should be performed: The travel agency should request the reactivation to the local GSA or International Sales Department of Avianca Brasil; Avianca Brasil will analyze the request in order to determine if it is feasible to reinstate the access to airline inventory; The airline sends an ADM* or invoice** with a charge of USD 300 for the reactivation; Once payment has been received, Avianca Brasil will reactivate the access to the airline inventory. *ADM (Agency Debit Memo) is applied only to IATA travel agencies. **The invoice is applied to non-iata/non-arc agencies. 23. DISPUTE PROCESS Travel agencies may dispute ADMs received through the following options: 23.1 BSPLink Within 14 days after receiving the ADM, the agency can dispute in active option in BSPLink, insert comments and attach supports to dispute ARC There is no determined period for the agency to request a dispute. Instead of a defined period, the company provides the agencies with 3 attempts to dispute a debit memo Agencies with billing method other than through BSP or ARC may send their disputes to the following addresses: distribuicao@avianca.com.br and disputa.adm@avianca.com.br. The disputes must have the complete reservation history (that may be requested to the GDS) and any other supports for analysis and verification that the audited practice was improper. Otherwise, the dispute request will be rejected. According to IATA practices, Avianca Brasil has up to 60 days, after receiving the dispute, to answer the travel agency. Page 15 / 17 15/01/2019

16 24. POLICY VALIDITY The present document is valid from date of publication. Avianca Brasil reserves the right to change at any time and without previous notice, the guidelines and general conditions of the Distribution Policy, which aims to promote a proper use of Distribution Systems. Page 16 / 17 15/01/2019

17 25. SUMMARY OF THE FEES Reason Non-cancelled segments status UC, UN, NO, US, HX Churning repeatedly creating and canceling the same segment, for the same flight date and same or different flight number and reservation. Up to 4 cancellations are allowed Duplicated PNR and Segment duplicated reservation, with the same characteristics of another reservation, with the same passengers, flights, segments, contact data, agency, office ID or PCC and/or overlapped or non-flyable dates Passive Segments status AK, BK, GK, GL, MK, PK, PL, DS, QK, YK Fictitious Name name incorrectly entered or with a high probability of not being the name of a real passenger Fictitious Tickets tickets with invalid numeration Waitlist practice not allowed by Avianca Brasil Married Segments Abuse sale availability should always be requested as origin/destination Charge Amount O6 (Avianca Brasil) Per segment and passenger USD 25 Per segment and passenger USD 30 Per segment and passenger USD 20 Per segment and passenger USD 10 Per segment and passenger USD 30 Per segment and passenger USD 50 Per segment and passenger USD 10 Per segment and passenger USD 175 Overbooking in closed classes reservations in classes not available for sale Hidden Groups groups (10 or more passengers) booked as multiple individual reservations Split payment Per segment and passenger USD 175 Per segment and passenger USD 20 Per document Document amount + Adm Fee Reactivation of access to airline Inventory Per access USD 300 Service Fee per ADM issued for travel agencies in Brazil Service Fee per ADM issued for travel agencies in other countries Per ADM BRL 60 Per ADM USD 25 To access Avianca Holding ADM Policy, use the following link: Page 17 / 17 15/01/2019

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