Accountable Executive
SMS Operations & Individual Responsibilities

Gold Aviation Services is a Part 135 on-demand air charter operator. Under 14 CFR Part 5, the FAA requires all Part 135 certificate holders to maintain an SMS. Our SMS is not just a compliance requirement; it is how we manage risk systematically, identify hazards before they become incidents, and continuously improve safety performance throughout our organization.

The SMS belongs to everyone in the organization.

Safety is a shared responsibility: every employee is expected to identify hazards, report safety concerns and all mandatory reportable events, and support the risk controls that keep our operation safe.

Key roles within the SMS:

• Accountable Executive (AE): Ultimate accountability for the SMS. Has authority over resources required to implement and maintain the system. Signs the safety policy [14 CFR §5.23, §5.25].
• Director of Safety (DOS): Day-to-day management of the SMS. Administers the voluntary reporting system, develops and tracks corrective actions through CAPA (Corrective Action / Preventive Action), conducts internal audits, facilitates external audits, administers the CASS program, maintains SMS records, the SDS/MSDS library, and safety training records.
• Director of Operations (DO) and Chief Pilot: Exercise operational control and oversee the integration of Operations department and Flight Operations department within the SMS.
• Director of Maintenance (DOM): Exercises operational control and oversees the integration of the Maintenance department within the SMS. Holds company authority for the maintenance program and ensures maintenance-related hazards are identified and addressed within the SMS.

• Safety Action Group (SAG): A cross-functional working group that executes review, analysis, and support tasks. Meets regularly to discuss hazards, learning outcomes, and policy changes while assessing risks and risk controls. The group reviews safety reports as needed and initiates action on identified issues.
• Safety Board: Chaired by the Accountable Executive. Meets quarterly to review safety performance data, SPI trends, audit results, and safety risk profile trends. Includes the Director of Safety, Director of Operations, Chief Pilot, Director of Maintenance, and leaders from other operating departments. Collaborates on organizational direction for safety priorities and resource allocation.

14 CFR §5.25 requires Gold Aviation Services to identify a single, specific person as Accountable Executive. This isn't a committee or a shared role; it must be one identifiable individual who, regardless of their other job functions, holds:

• Ultimate responsibility and accountability for implementation and maintenance of the SMS
• Final authority over operations conducted under Gold Aviation Services' Part 135 certificate
• Control of the financial resources required for those operations
• Control of the human resources required for those operations

The Gold Aviation voluntary safety reporting system is the primary mechanism for hazard identification. You can submit a report for any safety concern (near-miss, hazard observation, operational error, equipment issue, or unsafe condition) at any time.

Voluntary hazard and incident reporting: Anyone can submit a safety report at any time through FOS or by contacting the Director of Safety. The Director of Safety is your point of contact for all safety reports.

What to report:

• Any hazard you observe (in operations, maintenance, facilities, processes or other areas).
• Any unplanned event that could have resulted in injury, damage, or loss
• Errors you made or observed that could recur or could be learned from
• Organizational conditions (pressure, fatigue, communication failures) that create safety risk

What happens after you report:

1. The Director of Safety receives your report through FOS (or directly if submitting report directly to the DOS).
2. The Director of Safety reviews the report and classifies the hazard and risk level.
3. The Director of Safety facilitates collaboration and risk assessment with appropriate Subject Matter Experts (SMEs) as needed.
4. If corrective action is required, a CAPA is opened, assigned, and tracked to closure.
5. The Director of Safety may contact you for additional information or follow-up. This is part of the process, not an investigation of you or your actions.
6. The system notifies you when the report is closed.

The Flight Risk Assessment Tool (FRAT) is a pre-flight risk scoring tool that quantifies operational risk before each flight. It is completed by the Pilot in Command before every flight.

The FRAT evaluates risk factors across several categories including weather, crew experience, airport complexity, time of day, and duty time. Each factor is either present (1) or not applicable (0); the cumulative count determines the overall risk level.

• Low risk: operations may proceed. No additional review is required.
• Medium risk: the DOS is notified and coordinates with the Chief Pilot before a go/no-go decision is made. Mitigations and the decision must be documented before departure.
• High risk: the DOS is notified and coordinates with the Chief Pilot on the go/no-go determination; a mitigation plan and crew briefing are required. Do not depart until mitigations reduce risk to an acceptable level or the flight is cancelled. Formal approval from you, as Accountable Executive, is required before departure.

The FRAT is a proactive hazard identification tool, part of Gold Aviation Services' Safety Risk Management process. A High FRAT score is not a failure. It is the system working as intended.

FRAT scores directly inform operational decisions. Gold Aviation Services has made, and will continue to make, operational adjustments to trips when a FRAT score falls outside the company's risk tolerance. This is not a hypothetical control; it is an active part of how we manage risk on a day-to-day basis.

Just culture begins with you. The Accountable Executive's commitment to non-punitive reporting is not a policy statement; it is a behavioral standard that every employee in the organization observes and responds to.

Your just culture responsibilities as Accountable Executive:

• Protect reporters: if you learn that an employee faced adverse consequences for a good-faith safety report, that must be corrected immediately and visibly. Any tolerance of retaliation against reporters destroys reporting culture.
• Model transparency: when safety concerns are raised at the Safety Board level, engage with them openly. Avoiding uncomfortable safety data sends the wrong message.
• Distinguish mistakes from misconduct: in any safety-related personnel matter, ensure the just culture framework is applied before any disciplinary action is considered.
• Resource the fix: when the Director of Safety brings you a resource request to address a safety issue, responding with adequate resources is the most direct demonstration of your safety commitment.

The Accountable Executive has specific, non-delegable obligations under 14 CFR Part 5. These are not administrative tasks; they are the regulatory foundation of Gold Aviation Services' SMS:

• Signed safety policy: the safety policy must bear your signature and be communicated to all personnel. It establishes the organization's safety objectives, accountability framework, and commitment to non-punitive reporting.
• Resource authority: you must have control over the financial and human resources necessary to implement and maintain the SMS. When the Director of Safety identifies a resource need to address a safety risk, the decision to provide or withhold those resources rests with you.
• Safety Board participation: chair the quarterly Safety Board. Review safety performance data, SPI trends, audit findings, and corrective action status. Provide organizational direction on safety priorities.
• SMS compliance deadline: Gold Aviation Services must achieve full 14 CFR Part 5 compliance by May 28, 2027. This is your regulatory deadline, not the Director of Safety's.
• Training completion: complete all assigned SMS training modules. The Accountable Executive's training record is part of the compliance evidence package.

Understanding what happens after a report is submitted helps reinforce why reporting matters, and what to expect if you are involved in a follow-up.

Corrective Action / Preventive Action (CAPA) is the process Gold Aviation Services uses to document, track, and close corrective and preventive actions arising from safety reports, audit findings, and investigations. When a hazard is identified that requires action, a CAPA is opened.

The CAPA process:

1. Initiation: DOS opens a CAPA, assigns a number, and documents the hazard and risk level
2. Investigation: root cause is identified. Contributing factors are documented.
3. Corrective action: a specific action is assigned to a responsible party with a due date
4. Implementation: the assigned party completes the corrective action
5. Verification: DOS verifies the action was completed and effective
6. Closure: CAPA is closed with documentation.

You may be contacted by the DOS during the investigation phase for additional information. This is a normal part of the process; it is not an investigation of you personally, and it does not affect your just culture protections.

• The SMS is a shared responsibility, but as Accountable Executive, ultimate accountability rests with you.
• You control the resources the SMS needs; when the Director of Safety brings you a request, that decision is yours to make.
• Report protection is not optional. Any tolerance of retaliation against good-faith reporters undermines the entire reporting culture.

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