Exhibit 14.1

CODE OF ETHICS APPLICABLE TO THE CHIEF EXECUTIVE OFFICER,

SENIOR FINANCIAL OFFICERS AND MEMBERS OF THE BOARD OF DIRECTORS

GENERAL

Atlas Air Worldwide Holdings, Inc. (“Atlas” or the “Company”) maintains an Employee Handbook and Code of Conduct (the “Handbook”) that is applicable to all of the Company’s officers and employees, as well as to individuals and entities who seek to provide goods and services to Atlas, and in certain circumstances to the non-employee members of the Company’s Board of Directors (“Non-Employee Directors”). The Company’s Chief Executive Officer, senior financial officers and its Board of Directors (collectively, the “Covered Persons”) play an important and elevated role in corporate governance at the Company. Each Covered Person shall therefore comply not only with the provisions of the Handbook (which sets forth standards for both business conduct and ethics) (except that the Company’s non-employee members of the Board of Directors shall comply with the Handbook only to the extent explicitly set forth in the Handbook and in this Code of Ethics as applicable to Non-Employee Directors), but also with the provisions of this Code of Ethics. If any conflict should arise between the terms of this Code of Ethics and the Handbook, the terms of this Code of Ethics shall govern.

For the purpose of this Code of Ethics, the senior financial officers of Atlas shall include the Chief Financial Officer, Treasurer and the Corporate Controller, or persons performing similar functions.

This Code of Ethics is intended to be a codification of standards that is reasonably designed to deter wrongdoing and to promote:

HONEST AND ETHICAL CONDUCT

Each Covered Person shall act with honesty and integrity, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships. The Covered Persons are expected to act in accordance with the highest of standards, thereby setting an example for other officers and employees of the Company. Each Covered Person shall comply with each provision of the Handbook (except that the Company’s non-employee members of the Board of Directors shall comply with the Handbook only to the extent explicitly set forth in the Handbook and in this Code of Ethics as applicable to Non-Employee Directors).

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AVOIDANCE OF CONFLICTS OF INTEREST

Covered Persons shall be free from the influence of any conflicting interest between personal interests and the interest of the Company. They are expected to deal with suppliers, customers, contractors and all others doing business with Atlas on the sole basis of what is in the best interest of Atlas, without favor or preference to third parties based on personal considerations. Each Covered Person shall comply with the provisions under the heading “Conflict of Interest and Outside Activities” in the Handbook. In addition, the following guidelines should be followed:

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PUBLIC DISCLOSURES

Each Covered Person shall act to promote full, fair, accurate, timely and understandable disclosure in reports and documents that Atlas files with, or submits to, the SEC and in other public communications made by Atlas. Each Covered Person shall comply with the provisions under the headings “Financial Controls” and “Kickback, Rebates and Improper or Illegal Payments” (and any such related sections) in the Handbook. Additionally, each Covered Person should promptly bring to the attention of the Audit Committee any information concerning: (1) significant deficiencies or material control weaknesses in the design or operation of Atlas’ internal control over financial reporting; or (2) any fraud, whether or not material, that involves management or other employees who have a significant role in Atlas’ internal control over financial reporting.

COMPLIANCE WITH LAWS, RULES AND REGULATIONS

It is the Company’s policy to comply with all applicable laws, rules and regulations. Each Covered Person shall comply with all governmental laws, rules and regulations that are applicable to Atlas and to each such Covered Person (in his or her capacity as an employee or member of the Board of Directors, as applicable, of Atlas). Such compliance shall be more than following the letter of the law; compliance with the spirit of the law shall be each Covered Person’s goal. In connection with issues concerning such compliance, each Covered Person may consult with appropriate legal counsel or other outside advisors (such as the Company’s independent auditors) on such questions as he or she deems appropriate.

REPORTING OF VIOLATIONS OF THE CODE

Each Covered Person shall comply with the following guidelines, including promptly reporting any violations of this Code of Ethics in accordance with the procedures set forth below:

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ACCOUNTABILITY FOR ADHERENCE TO THE CODE

Atlas and its Board of Directors expect that each of the Covered Persons will comply with all of the terms of this Code of Ethics. The Board of Directors shall determine what, if any, consequences should result from a violation of this Code of Ethics by any Covered Person. Such consequences may include a reduction in compensation, a reassignment of responsibilities, a loss of such Covered Person’s current office or dismissal from the Company. In making its determination, the Board of Directors may take into account all relevant factors, including the type and severity of violation.

AMENDMENTS AND WAIVERS OF THE CODE

Amendments and waivers of this Code of Ethics shall be subject to the following guidelines:

(Amended as of September 15, 2016)

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