ATSG Strengthened Compliance, Safety & Ethics Reporting

This case study reflects insights from ATSG’s Chief Legal Officer & Secretary, Josh Carter, who oversees FaceUp as part of his compliance responsibilities.

ATSG is a global provider of aircraft leasing, air cargo transportation, passenger charter services, and aviation support solutions. Founded in 1980, ATSG operates one of the world’s largest fleets of converted Boeing 767 freighters, with 148 aircraft supporting global aviation networks.

Through its subsidiaries, ATSG delivers integrated aviation services—including cargo airline operations, passenger charter flights, maintenance and engineering, training, cargo handling, and aircraft leasing—to customers across the ecommerce, government, and aviation sectors.

Safety, accountability, and operational discipline are central to ATSG’s culture and to the people who power its operations every day. In an industry where compliance and transparency are essential, trusted reporting channels play an important role in protecting employees and strengthening oversight. FaceUp helps ATSG maintain visibility into safety, compliance, and ethics matters across its global organization.

Modernizing a Legacy Hotline Model

Before FaceUp, ATSG relied on a 24/7 hotline answered by a live operator. While anonymous, the format had limitations.

Reports were delivered verbally through a live operator, resulting in varying levels of detail depending on who received the call. Many employees were likely uncomfortable discussing sensitive issues out loud with another person, and because calls were summarized rather than recorded in full, the information that was gathered varied, resulting in inconsistent documentation.

Critically, there was no way to follow up with anonymous reporters, limiting ATSG’s ability to clarify information, request additional details, or communicate outcomes to the individual who raised the concern.

"There was no way to follow up with anonymous reporters, which created limitations in our ability to clarify information or communicate outcomes. Overall, the process was outdated and lacked the centralized structure, consistency, and transparency expected in a large organization like ours."

Legal carried much of the administrative burden, with tracking handled manually. Compliance and leadership also recognized that the hotline model no longer scaled with organizational expectations. It was a single-channel system in a distributed, multi-entity workforce that had grown well beyond what the format could support.

Compliance and leadership lacked consolidated real-time visibility across subsidiaries.

The system no longer aligned with expectations for a modern enterprise compliance framework or the company’s continued growth.

Underreporting was also a concern. A single reporting channel didn’t reflect how employees prefer to communicate today, especially in a distributed, multi-entity workforce.

“By offering multiple reporting channels, multilingual access, and clear communication, FaceUp increased employee engagement while giving leadership structured case progression, consolidated oversight, and alignment across all subsidiaries.”

FaceUp also provides a customizable form feature that ATSG leveraged as a survey tool to measure employees’ understanding of how to use the reporting system. The survey results helped identify awareness levels across the organization, and ATSG plans to use this feature annually to monitor comprehension, strengthen training efforts, and proactively address any education gaps.

Meeting the Demands of a Highly Regulated Industry

Aviation operates under strict regulatory environments, where reports often involve safety, security, compliance, or ethical issues. These concerns can have serious operational consequences and must be handled promptly, consistently, and accurately.

Managing this complexity becomes even more challenging in a multi-subsidiary organization, where each unit has its own processes and priorities.

For ATSG, protecting employees from retaliation remains central. Employees must feel confident that concerns are handled confidentially and fairly.

Building a Reporting System People Trust

When evaluating solutions, ATSG had clear non-negotiables:

• True anonymity
• Two-way anonymous communication
• Structured case management workflow
• Clear, verifiable audit trails
• SOC 1 and SOC 2 compliance
• Multiple accessible reporting methods
• Multilanguage options
• Ease of use for employees and administrators

FaceUp met these requirements and introduced additional strengths, including reporting in 112 languages, ensuring every employee, regardless of location, can raise a concern in the language they're most comfortable with.

“FaceUp lets us assign cases instantly, track patterns across subsidiaries, and collaborate confidently, giving leadership clear oversight and actionable insights.”

The platform offers a customizable digital reporting form accessible via link or QR code, with tracking numbers for secure follow-up.

Dashboards and case trend visualizations give leadership real-time insight into patterns across business units.

SOC 1 and SOC 2 compliance ensures the data protection and audit assurance needed for sensitive safety and ethics information.

The CLO champions broader communication and awareness to ensure the platform supports as many employees as possible.

FaceUp also aligns with ATSG’s community engagement values: five anonymous ethics reporting services were donated to local schools, extending impact beyond the company.

How FaceUp Supports Daily Compliance Oversight

Incoming concerns are reviewed centrally, cases are assigned quickly, and investigations are coordinated across Legal, Compliance, HR, Safety, Security, and Operations.

Employees across ATSG's global operations can submit reports in their preferred language — with support for 112 languages, ensuring no barrier stands between a concern and the right people.

Structured workflows maintain consistency across subsidiaries, and all stakeholders work from the same real-time information, improving cross-functional collaboration.

“Two-way communication with anonymous reporters lets us clarify details, follow up securely, and conduct more effective investigations while maintaining confidentiality.”

The platform has improved accountability, clarified oversight, and strengthened documentation consistency.

Using Data to Guide Strategic Decisions

Today, ATSG monitors:

• Status and timeliness of corrective actions
• Category trends
• Business unit patterns
• Reporter engagement levels

These insights help identify emerging risks and areas needing additional training or operational support.

“FaceUp provides leadership and the board with transparent, data-driven insights that support strategic discussions, highlight trends, and reinforce ATSG’s commitment to ethics and continuous improvement.”

By centralizing data, leadership can focus on high-priority issues, allocate resources effectively, and address process gaps or cultural friction points early. This strengthens both compliance and operational resilience. 

A Leadership Commitment to Integrity

For ATSG, technology is only part of the equation. Trust is built through transparency, consistent handling, and visible follow-through. Employees need to see that concerns are taken seriously and addressed fairly.

“Offering multiple anonymous reporting channels has increased reporting, removed barriers to raising concerns, and strengthened a culture of integrity across the organization.”

Investing in a modern, centralized system expanded access, removed reporting barriers, and reinforced leadership’s commitment to protecting employees.

In a global aviation enterprise, FaceUp provides a structured, secure, and scalable foundation that supports lasting integrity and a trusted reporting environment.