The Board of Directors of Gogo Inc. (“Gogo") sets high standards for Gogo’s employees, officers and directors. Implicit in this philosophy is the importance of sound corporate governance. To promote ethical conduct and compliance, the Board of Directors has adopted the ethics and compliance policies and corporate governance guidelines set forth below.

These policies are subject to modification from time to time as required by applicable laws and regulations or as is otherwise deemed advisable. In addition, the Board of Directors has approved the charters of the Audit Committee, Compensation Committee, and Nominating and Corporate Governance Committee, which outline the respective functions and responsibilities of those committees, as well as Gogo’s Certificate of Incorporation and Bylaws, all of which are provided below.