Exhibit 19 - JBLU Insider Trading Policy

Exhibit 19

Insider Trading Policy (ITP)

2024-12-12

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Insider Trading Policy (ITP)

Table of Contents

Table of Contents ...................................................................................................TOC-1


Chapter 1	General....................................................................................................	1-1
1.1	Purpose .................................................................................................	1-1
1.2	Scope.....................................................................................................	1-1
1.3	Potential Consequences........................................................................	1-3
Chapter 2	FAQs........................................................................................................	2-1
2.1	Insiders ..................................................................................................	2-1
Chapter 3	Blackout and Preclearance Procedures.............................................................................................	3-1
3.1	Trades....................................................................................................	3-1
Chapter 4	Prohibited Transactions ........................................................................	4-1
4.1	Policy .....................................................................................................	4-1
4.2	Disclosure of Material Information to Third Parties................................	4-2
4.3	Exceptions .............................................................................................	4-2
Chapter 5	Possible Additional Restrictions..........................................................	5-1
5.1	Note .......................................................................................................	5-1
Chapter 6	Related Policies and Certification........................................................	6-1
6.1	Compliance ............................................................................................	6-1
Chapter 7	Interpretation and Amendment.............................................................	7-1
7.1	Updates .................................................................................................	7-1
Chapter 8	Questions ...............................................................................................	8-1
8.1	Contacts.................................................................................................	8-1

1 For purposes of this policy, “officers” refer to those individuals who meet the definition of “officer” under Section 16 of the Securities

Exchange Act of 1934 (as amended, the “Exchange Act”).

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Insider Trading Policy (ITP)

General

1.1 Purpose

JetBlue seeks to promote a culture that encourages ethical conduct and a commitment

to compliance with the law. We require our Directors and Crewmembers (including

officers1) to comply at all times with applicable federal and state laws and regulations

governing insider trading. This policy sets forth procedures designed to help comply

with these laws and regulations.

1.2 Scope

All Directors and Crewmembers, regardless of their title or position, are prohibited from

trading in JetBlue securities, including stocks, bonds, notes, debentures, options,

warrants, equity, and other convertible securities, as well as derivative instruments,

while they possess material information about JetBlue that has not been fully disclosed

to the public, and from providing this information to others who may trade, in breach of a

duty of trust or confidence.

This policy applies to your family members who reside with you, anyone else who lives

in your household, and any family members that do not live in your home but whose

transactions in our securities are directed by you or are subject to your influence or

control. You are responsible for the transactions of these other people and should make

them aware of the requirement to confer with you before they trade in JetBlue

securities. This policy also applies to any entities that you control, including any

corporations, limited liability companies, partnerships or trusts, and transactions by

these entities should be treated for the purposes of this policy as if they were for your

own account.

JetBlue may determine that this policy applies to additional persons with access to

material nonpublic information, such as contractors or consultants. Directors, officers

and other Crewmembers, together with any other person designated as being subject to

this policy by the General Counsel or his or her designee (the “Compliance Officer”)

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Insider Trading Policy (ITP)

General

(with their controlled entities and affiliated individuals subject to this policy), are referred

to collectively as “Covered Persons.”

Deemed Insiders

A Deemed Insider is a Covered Person who has, or is likely to have, access to the

company’s financial information in advance of public disclosure or to other material

nonpublic information. The Legal Department determines who is a “Deemed Insider”

and are responsible for periodically reviewing and updating the list of Deemed Insiders.

Members of our Board of Directors, JetBlue’s senior leadership team, including SLT

Crewleaders, and other JetBlue officers are considered Deemed Insiders at all times.

Other Crewmembers may be Deemed Insiders due to information they routinely access

as a part of their job. Individuals may become Deemed Insiders from time to time as a

result of special projects or initiatives.

•

Example

If you attend an Officer and Director call in which material, nonpublic information is

disclosed, you should not trade in JetBlue securities until one business day after that

information is made public.

You may be provided with material nonpublic information in emails (such as

information concerning financial performance). In such an instance, you should not

trade in JetBlue securities until one business day after that information is made public.

Even if you receive clearance from the Legal Department to trade, the obligation to

ensure you are not in possession of material nonpublic information lies with you. If

you trade while in possession of material nonpublic information, you risk civil and

criminal penalties on an individual basis.

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Insider Trading Policy (ITP)

General

Business Partners and Other Third Parties

You should not purchase, sell, gift or otherwise transfer any security of any other

company, including economically-linked companies, such as a competitor or another

peer company in JetBlue’s industry, while in possession of material nonpublic

information if such information was obtained in connection with your employment by

or service to JetBlue (to the extent there is a reasonable likelihood that such

information would be considered important to an investor in making an investment

decision in such other company).

1.3 Potential Consequences

We require our personnel to comply at all times with federal laws and regulations

governing insider trading. Failure to follow the procedures in this policy could result in a

serious violation of the securities laws by you and/or JetBlue. Violating federal and state

laws regarding insider trading can undermine investor trust, harm the reputation and

integrity of JetBlue, and result in dismissal from the company or even serious criminal

and civil charges against the individual and the company. JetBlue reserves the right to

take whatever disciplinary or other measure(s) it determines in its sole discretion to be

appropriate in any particular situation, including disclosure of wrongdoing to

governmental authorities.

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Insider Trading Policy (ITP)

FAQs

2.1Insiders

An “insider” is a person who possesses, or has access to, material information

concerning JetBlue that is not public (see below for a definition of “material information”

and “public”). Insiders may be subject to criminal prosecution and/or civil liability for

trading in JetBlue stock or other securities or providing this information to others who

may trade when they know material information concerning JetBlue that has not been

fully disclosed to the public.

What is “Material” Information?

It is not possible to define all categories of material information. In general, information

should be regarded as “material” if there is a reasonable likelihood that it would be

considered important by an investor in making a decision to buy, hold or sell securities.

Any information that could be expected to affect JetBlue’s stock price, whether it is

positive or negative, should be regarded as material.

When is Information “Public”?

If you are aware of material nonpublic information, you may not trade until the information

has been widely disseminated to the general public so that investors have been able to

factor the information into the market price of the security.

Generally a full trading day following release of information to the public is regarded as

sufficient time for public dissemination and absorption of material information.

The Compliance Officer will have sole discretion to decide whether information is public

for purposes of this policy.

What Qualifies as a Trade?

“Trades” include any “purchase” or “sale” of securities, which are defined broadly under

the federal securities law. “Purchase” includes not only the actual purchase of a security,

but also any contract to purchase or otherwise acquire a security. “Sale” includes not

only the actual sale of a security, but also any contract to sell or otherwise dispose of a

security. These definitions extend to a broad range of transactions, including

conventional cash-for-stock transactions, conversions, the exercise of stock options,

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Insider Trading Policy (ITP)

FAQs

transfers, gifts, and acquisitions and exercises of warrants or puts, calls, pledging and

margin loans, or other derivative securities.

What if I Leave JetBlue?

With the exception of the preclearance requirement, this policy continues to apply to

transactions in JetBlue’s securities even after termination of service to the Company. If

you are in possession of material nonpublic information when your service terminates,

you may not trade in JetBlue’s securities until the later of the completion of the first full

trading day after the public release of quarterly earnings data following your termination

of service with JetBlue or the time when that information has otherwise become public.

If you are exposed to material nonpublic information after termination of services to the

company in connection with the position you previously held in JetBlue, you may not trade

in JetBlue’s securities until that information has become public or is no longer material.

In addition, if your service terminated during a blackout period, the restrictions on trading

applicable during the blackout period will continue to apply until the lapse of such period.

What if I Learn Material Nonpublic Information After I Have Decided to Trade

JetBlue Securities but Before I Have Executed the Trade?

If you learn of material nonpublic information after you have already decided to buy or

sell JetBlue securities but have not yet completed the transaction, you may not proceed.

Trading while in possession of material nonpublic information is prohibited even if that

information was not your underlying motive for the trade.

My Trade Was for a Small Amount of Securities – Does That Matter?

No. There are no limits on the size of a transaction that could trigger insider trading

liability; relatively small trades have in the past occasioned SEC investigations and

lawsuits.

Can I Move My JetBlue Common Stock to a Brokerage Account Outside Fidelity?

From time to time, Crewmembers have requested the ability to move their JetBlue

equity from the company’s broker to a broker of their own choice. In order to do so,

they must ensure the outside broker is aware of and complies with our insider trading

windows and policies. Merely requesting approval to trade and moving the shares is not

sufficient.

Can I Trade or Hold Positions in Other Airline Stocks?

Covered Persons are prohibited from trading in any company’s securities while in

possession of material nonpublic information (to the extent there is a reasonable

likelihood that such information would be considered important to an investor in making

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Insider Trading Policy (ITP)

FAQs

an investment decision in such other company) if that information was learned during

your employment with JetBlue. You may not trade in the other company’s securities

until the information becomes public or is no longer material.

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Insider Trading Policy (ITP)

Blackout and Preclearance Procedures

Blackout and Preclearance

Procedures

3.1Trades

Deemed Insiders, and any other persons designated by the Legal Department (with

their controlled entities and affiliated individuals subject to this policy) must not

purchase, sell, gift or otherwise transfer any security of the company during any

blackout period, except as otherwise permitted by this policy.

Quarterly Blackout Periods

JetBlue’s quarterly blackout period begins 10 business days before quarter-end; and

ends after completion of one trading day after the earnings release for that quarter.

A “trading day” is a day on which U.S. national stock exchanges are open for trading. If,

for example, JetBlue were to release earnings on Monday prior to 9:30 a.m. Eastern

Time, then the blackout period would terminate after the close of trading on Monday. If

JetBlue were to release earnings on Monday after 9:30 a.m. Eastern Time, then the

blackout period would terminate after the close of trading on Tuesday. Any question as

to whether information is publicly available shall be directed to the Compliance Officer.

Additional Blackout Periods

From time to time, the Compliance Officer or the Board of Directors, in its discretion,

may determine that an additional blackout period is appropriate. Persons subject to an

additional blackout period (with their controlled entities and affiliated individuals subject

to this policy) must not purchase, sell, gift or otherwise transfer any security of JetBlue,

except as otherwise permitted by this policy, and must not disclose that an additional

blackout period is in effect.

Preclearance

All transactions in the company’s securities by Deemed Insiders with their controlled

entities and affiliated individuals subject to this policy (including, without limitation,

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Insider Trading Policy (ITP)

Blackout and Preclearance Procedures

acquisitions and dispositions of company stock, gifts, the exercise of stock options

and the sale of company stock issued upon exercise of stock options) must be

precleared by the Legal Department.

If you are subject to preclearance, you must submit a trade request to the Legal

Department in advance of trading, in accordance with the procedures established by

the Legal Department.

While members of JetBlue’s Legal Department make an effort to respond to every

request to trade promptly, please note that it may take up to five (5) business days to

receive a response to a trade request. Please plan accordingly. In addition, please note

that the Legal Department cannot take personal circumstances into consideration when

determining if you may have material nonpublic information.

The Legal Department has sole discretion to decide whether to clear any contemplated

transaction, and clearance of a transaction should not be understood to represent legal

advice by the company that a proposed transaction complies with applicable law. None

of the company, the Compliance Officer, members of the Legal Department, or other

Crewmembers will have any liability for any delay in reviewing, or refusal of, a trade

request.

All trades that are precleared must be effected within five (5) business days of receipt of

the preclearance. A precleared trade (or any portion of a precleared trade) that has not

been effected during the five (5) business day period must be submitted for preclearance

determination again prior to execution. Notwithstanding receipt of preclearance, if you

become aware of material nonpublic information, or become subject to a blackout period

before the transaction is effected, the transaction may not be completed.

Transactions under a previously established Trading Plan (as defined below) that has

been preapproved in accordance with this policy are not subject to further preclearance.

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Insider Trading Policy (ITP)

Prohibited Transactions

4.1Policy

JetBlue has determined that there is a heightened legal risk and the appearance of

improper or inappropriate conduct if Covered Persons engage in certain types of

transactions. Therefore, Covered Persons must comply with the following policies with

respect to certain transactions in JetBlue’s securities.

Short Sales

No Covered Person may enter into short sales of JetBlue’s securities. Short sales, or

sales of shares that the insider does not own at the time of sale, or sales of shares

against which the insider does not deliver the shares within twenty (20) days after the

sale, evidence an expectation on the part of the seller that the securities will decline in

value, and, therefore, signal to the market that the seller has no confidence in the

company or its short-term prospects.

Options

No Covered Person may enter into transactions in puts, calls, or other derivative

securities involving JetBlue’s equity securities, on an exchange, on an over-the-counter

market, or in any other organized market. A transaction in options is, in effect, a

bet on the short-term movement of the company’s shares and, therefore, creates the

appearance that a Covered Person is trading based on material nonpublic information.

Transactions in options, whether traded on an exchange, on an over-the-counter

market, or any other organized market, also may focus a Covered Person’s attention on

short-term performance at the expense of the company’s long-term objectives.

Hedging Transactions

No Covered Person may enter into derivative transactions to hedge their economic

exposure to JetBlue’s common stock, such as prepaid variable forward contracts,

equity swaps, collars and exchange funds, or other transactions that hedge or offset,

or are designed to hedge or offset, any decrease in the market value of JetBlue’s

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Insider Trading Policy (ITP)

Prohibited Transactions

equity securities. Such transactions allow the Covered Person to continue to own the

covered securities, but without the full risks and rewards of ownership. When that

occurs, the Covered Person may no longer have the same objectives as JetBlue’s

other shareholders.

Margin Accounts and Pledging

Covered Persons are prohibited from pledging JetBlue stock as collateral for a loan,

purchasing Company securities on margin (i.e., borrowing money to purchase the

securities), or placing Company securities in a margin account. This prohibition does

not apply to cashless exercises of share options under JetBlue’s equity plans, nor to

situations approved in advance by the Compliance Officer.

Partnership Distributions

Nothing in this policy is intended to limit the ability of an investment fund, venture

capital partnership or other similar entity with which a Director is affiliated to distribute

JetBlue securities to its partners, members, or other similar persons. It is the

responsibility of each affected Director and the affiliated entity, in consultation with

their own counsel (as appropriate), to determine the timing of any distributions, based

on all relevant facts and circumstances, and applicable securities laws.

4.2Exceptions

There are several types of transactions in which Covered Persons may engage even if

they are in possession of material nonpublic information about JetBlue.

Transactions with the Company

This policy’s trading restrictions generally do not apply to transactions directly with the

company.

Stock Option Exercises and “Sell to Cover” Transactions

This policy’s trading restrictions generally do not apply to the exercise of a stock option

(unless the stock option exercised has a reload feature) or to the exercise of a tax

withholding right pursuant to which you elect to have JetBlue withhold common shares

subject to a stock option to satisfy tax withholding requirements. The trading restrictions

do apply, however, to any sale of the underlying common stock or to a cashless exercise

of the stock option through a broker, as this entails an open market sale of a portion of

the underlying common stock to cover the costs of exercise.

This policy’s trading restrictions also generally do not apply to “sell-to-cover”

transactions pursuant to any non-discretionary policy adopted by the company that is

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Insider Trading Policy (ITP)

Prohibited Transactions

intended to facilitate the payment of withholding taxes associated with vesting of equity

awards (other than stock options).

Crewmember Stock Purchase Program

This policy’s trading restrictions do not apply to purchases of our common stock in

the Crewmember Stock Purchase Program (“CSPP”) resulting from your periodic

payroll contributions to the CSPP pursuant to the election you made at the time of

your enrollment in the CSPP. The trading restrictions do apply, however, to your sales

of JetBlue common stock purchased pursuant to the CSPP.

Gifts

This policy’s trading restrictions generally do not apply to gift transactions for family or

estate planning purposes, where securities are gifted to a person or entity subject to this

policy, except that gift transactions involving Company securities are subject to

preclearance.

Trading Plans and Trading Arrangements

The restrictions in this policy, other than restrictions on those transactions described

under in “Prohibited Transactions,” Chapter 4.1, do not apply to transactions under a

trading plan (a “Trading Plan”) that satisfies either:

•the conditions of Rule 10b5-1; or

•the elements of a non-Rule 10b5-1 trading arrangement as defined in Item 408(c)

of Regulation S-K; and

•the Compliance Officer has pre-approved.

The Compliance Officer may impose such other conditions on the implementation and

operation of a Trading Plan as the Compliance Officer deems necessary or advisable.

An individual may only modify a Trading Plan outside of a blackout period and, in any

event, when the individual does not possess material nonpublic information.

Modifications to and early terminations of a Trading Plan are subject to pre-approval by

the Legal Department.

The company also reserves the right from time to time to suspend, discontinue, or

otherwise prohibit transactions under a Trading Plan if the Legal Department,

Compliance Officer or the Board of Directors, in its discretion, determines that such

suspension, discontinuation, or other prohibition is in the best interests of the company.

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Insider Trading Policy (ITP)

Prohibited Transactions

Compliance of a Trading Plan with the terms of Rule 10b5-1 and the execution of

transactions pursuant to the Trading Plan are the sole responsibility of the person

initiating the Trading Plan, and none of the company, the Compliance Officer, members

of the Legal Department, or other Crewmembers assumes any liability for any delay in

reviewing and/or refusing to approve a Trading Plan submitted for approval, nor the

legality or consequences relating to a person entering into, informing the company of, or

trading under, a Trading Plan.

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Insider Trading Policy (ITP)

Possible Additional Restrictions

5.1Note

In addition to the general policies and procedures set forth in this policy, our General

Counsel has the authority to impose additional restrictions from time to time on Directors,

individual Crewmembers, certain groups of Crewmembers, or all Crewmembers. In such

event, the Directors and/or affected Crewmembers will be informed of those additional

restrictions.

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Insider Trading Policy (ITP)

Related Policies and Certification

6.1Compliance

This Insider Trading Policy should be read in conjunction with the Code of Business

Conduct and the Crewmember Blue Book.

All Covered Persons may be asked periodically to certify their compliance with the

terms and provisions of this policy.

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Insider Trading Policy (ITP)

Interpretation and Amendment

7.1Updates

The General Counsel shall have the authority to interpret and update this policy and all

related policies and procedures. In particular, such interpretations and updates of this

policy, as authorized by the General Counsel, may include amendments to or departures

from the terms of this policy, to the extent consistent with the general purpose of this

policy and applicable securities laws.

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Insider Trading Policy (ITP)

Questions

8.1Contacts

Any person who has a question about this policy or its application to any proposed

transaction may obtain additional guidance from:

Eileen McCarthy

General Counsel and Corporate Secretary

eileen.mcCarthy@jetblue.com

and

Shannon Collins

Director, Securities and Corporate Governance

shannon.collins@jetblue.com

If you have a question as to whether something may be material nonpublic information,

please reach out. With trade-related questions, please reach out to all individuals listed

above. If you wish to discuss a trade request and the window is scheduled to close in

five (5) business days or less, please do not rely on leaving a voicemail message or, if

someone’s out of office message indicates they are traveling, an email.

Ultimately, the responsibility for adhering to this policy and avoiding unlawful

transactions rests with each of you. Actions taken by the company, the

Compliance Officer, other members of the Legal Department or any other

Crewmembers do not constitute legal advice, nor do they insulate you from the

consequences of noncompliance with this policy or with securities laws.

If you have questions about JetBlue’s broker, Fidelity, please reach out to

StockAdmin@JetBlue.com.

If you have questions about our Compliance programs at JetBlue, please reach out to

BlueEthicsandCompliance@JetBlue.com.

www.jetblue.com

JetBlue Airways

27-01 Queens Plaza North

Long Island City, New York 11101

1-800-JETBLUE