Just like trust, respect is earned.

You must show respect to earn respect.

1-RHG Code of Business Ethics 2022

 CODE OF BUSINESS ETHICS
July 2022

ethics.radissonhotels.com

Dear Colleague,

At Radisson Hotel Group (“RHG/Radisson”), we care deeply about doing the right thing.
Together, we have proven that we can succeed—providing value to our clients and
shareholders and opportunities for our people —while being a powerful force for good. Our
shared commitment to operating with the highest ethical standards and making a positive
difference in everything we do is what makes RHG special.

Respect is the key to all our actions. Just like trust, respect is earned. You must show respect
to earn respect. Our Code of Business Ethics (the “Code”) shows how we want to be perceived
as a company. RHG’s reputation and continued success as a global hospitality leader is
grounded in the RHG’s commitment to business integrity and in our application of consistently
high standards to everything we do. Around the world, all our stakeholders have the right to
expect that the Radisson, its hotels, its brands, and all its team members act and take positions
on key issues of business ethics with a single voice.

With the Code, we want to help our employees make ethical behavior a natural part of what we
do every day—with each other, our clients, our business partners, and our communities.
Because our business relies upon integrity and good judgment, this Code and related internal
policies have been developed to provide all members of the Radisson family with guidance on
not only what is legal but also what is right.

The Code is more than just a document-it’s what we believe, how we live and how we lead. It’s
embedded in all we do. It’s how we improve our business performance and build on Radisson’s
reputation in the marketplace. The Code builds on our core values by providing greater detail
about expected behaviors and drives our culture of compliance, ethical conduct and
accountability.

Please take the time to familiarize yourself with the Code, so that you can understand how to
best incorporate it your everyday actions at Radisson.

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Sincerely,

Federico J. González
President and CEO of Radisson Hotel Group

3-RHG Code of Business Ethics 2022

CONTENTS

INTRODUCTION..................................................................................................................................................... 5
GUIDING PRINCIPLES ..................................................................................................................................... 5
SCOPE- WHO DOES THE CODE APPLY TO? ............................................................................................ 5
BUILDING TRUST AND CREDIBILITY ........................................................................................................... 7
REPORTING AND PROCEDURAL NEXT STEPS ....................................................................................... 7
BUSINESS ETHICS: LEGAL INTEGRITY .......................................................................................................... 9
MAINTAINING FINANCIAL INTEGRITY ....................................................................................................... 10
RELATIONSHIP WITH THIRD PARTIES ..................................................................................................... 12
EMPLOYEE RELATIONS AND EXPECTATIONS ...................................................................................... 17
CONFLICT OF INTEREST .............................................................................................................................. 18
RESPONSIBLE BUSINESS ............................................................................................................................ 19
SUPPLIERS ....................................................................................................................................................... 20
CONFIDENTIALITY, DATA PROTECTION & PRIVACY ........................................................................... 20
COMPETITION/COMPETITIVE PRACTICES.............................................................................................. 21
PREVENTING BRIBERY AND CORRUPTION ........................................................................................... 22
ANTI-MONEY LAUNDERING AND FACILITATION OF TAX EVASION ................................................. 26
TRADE SANCTIONS ....................................................................................................................................... 27
REPORTING TO RHG AND COMPLIANCE CERTIFICATION .................................................................... 28
COMPLIANCE CERTIFICATE EXERCISE .................................................................................................. 30

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INTRODUCTION

GUIDING PRINCIPLES

RHG is committed to maintaining the highest standards of business ethics, honesty and integrity
in line with its Responsible Business program for social, ethical and environmental
responsibility. “The Code” – contains rules and guidelines for our business conduct and
responsibilities with regards to colleagues, customers, hotel owners, guests, suppliers, agents,
shareholders, authorities, media and the world at large.

All companies and employees of RHG must comply with the laws and agreements applicable
to operations and positions in the countries and jurisdictions where they operate. RHG will not
cause or allow any employee to take any action which would result in violation of applicable
laws or regulations. RHG will forego any business opportunity that requires a violation of the
rules of this policy. This means that each employee must be familiar with and comply with the
laws and regulations that govern their job tasks.

The Code in short encompasses the following:

1. We respect the law

2. We show respect for all persons in all situations
3. We think ethically
4. We act fairly
5. We do not discriminate against anyone for any reason
6. We are honest and transparent
7. We are loyal to our employer
8. We do not exploit company resources
9. We think of safety at all times
10. We take care of the Earth

SCOPE- WHO DOES THE CODE APPLY TO?

This Code applies to all officers, directors, employees and agents (third parties acting on RHG ’s
behalf) of RHG and of all its subsidiaries and associated companies. For avoidance of doubt,
the Code is applicable to all hotels owned, leased and managed by RHG. The management
teams must be role models for all points of contact with internal and external stakeholders.
Everyone, to whom this Code applies, is expected to understand and act in accordance with
both the Code and the spirit of this Code. The Code will be enforced promptly, consistently, and

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 effectively. Violations by an employee may result in individual disciplinary action, up to and
including termination of employment, and perhaps legal liability.

We recognize that some business cultures have practices that may violate our core values and
ethics, such that upholding them may be uncomfortable, even challenging. Doing the right thing
often requires courage. Saying no to these practices does not mean we disrespect those
cultures. Business opportunities do not take priority over our reputation or our Code.

The information in the Code cannot address every difficult situation that may confront
colleagues throughout the world. Nonetheless, the Code aims at serving its purpose for being
an important guide and providing an introduction to many of our key global policies, however it
may not cover everything that may be relevant to you. It is important to remember that there
may be other policies, procedures and requirements that apply to your role and which you must
comply with in addition to the Code.

If you have a question about the Code or, if you have a concern and the Code does not answer
your question or address your concern, please do not hesitate to raise your concern or question.
It is your responsibility to report any violations of our Code or applicable law and bring potential
problems to RHG’s in the manner set forth under the Code. No retaliation will be taken against
an employee for reporting a violation by others in good faith.

AS A TEAM MEMBER MY ROLE IS TO: AS A TEAM MANAGER I HAVE ADDITIONAL

RESPONSIBILITIES AND MY ROLE IS TO:
❖ Know and understand the Code; ❖ Lead by example and maintain, promote, and
❖ Act consistently with the Code, and if in act in accordance with the Code in my daily
doubt seek guidance from my team work;
manager, human resources manager, or the ❖ Ensure that the Code is alive within my team;
legal department; and ❖ Ensure that I am familiar with the Code, since
❖ Demonstrate and live our values, rules of my team members may come to me for
conduct and behavior, and principles of advice and guidance on certain issues listed
action. thereunder; and
❖ Identify compliance risks and make the
appropriate decisions regarding issues
relevant to my area of responsibility.

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BUILDING TRUST AND CREDIBILITY

The success of our business is dependent on the trust and confidence we earn from our
employees, customers and shareholders. Trust is the key to establishing an ethical organization
environment -- one that guides decisions and actions. Trust in business is the cornerstone of
relationships with customers, suppliers, employees, and others who have dealings with an
organization. Trust means to be reliable and carry through words with deeds. Trust is gained
when an employee follows through ethical intent with ethical action. Trust becomes pervasive
only if the organization’s values are followed and supported by top management. By modeling
the organization’s values, senior leaders provide a benchmark for all employees.

We gain credibility by adhering to our commitments, displaying honesty and integrity and
reaching company goals solely through honorable conduct. It is easy to say what we must do,
but the proof is in our actions. Everyone working for us must have and apply sound judgement
guided by the highest personal standards of honesty and integrity in all matters affecting our
company. This is a matter of responsibility, confidence and trust.

Operating in as many countries and cultures as we do, we acknowledge diversity as an asset.

Certain customs and moral codes vary quite dramatically in our markets. Sometimes laws and
regulations vary as well. It’s imperative that all our people abide by local and international
legislation. We recommend any team member with concerns or questions about the Code to
discuss these directly with their supervisor.

REPORTING AND PROCEDURAL NEXT STEPS

Reporting of Potential Breaches or Complaints

All of the RHG employees have an obligation to familiarize themselves with applicable laws
relating to their job responsibilities and all RHG policies. Breach of the Code, RHG policies or
the law may give rise to disciplinary action up to, and including, dismissal.

Infringements of laws or the Code as well as matters pertaining to an employee ’s rights,

obligations or working conditions are to be reported to one’s supervisor. If the supervisor is
involved, or will not act, such matters are to be reported to the highest supervisor responsible;
up to and including the applicable Area Senior Vice President, or the Executive Vice President.

RHG expects supervisors to treat such matters seriously and in compliance with the stated
policies and values. No one shall be discriminated against or punished for reporting actual or

7-RHG Code of Business Ethics 2022

suspected infringements in good faith. All reports will be handled in line with the below
procedure and will be treated confidentially.

Ethics Leadership Group and Ethics Hotline

RHG has established an Ethics Leadership Group to ensure compliance with the Code and
follow up on potential breaches and complaints. This group is represented by the Global Senior
Vice President, Responsible Business and Safety & Security; Executive Vice President &
Global Chief Resources Officer; and Vice President Internal Audit. The Ethical Leadership
Group members can be contacted in case of questions or clarifications. Any potential breach
or complaint should be reported to the Ethics Leadership Group.

In addition to the establishment of the Ethics Leadership Group, RHG has established an
agreement with an independently operated business ethics hotline to ensure that employees
can share information or complaints about concerns regarding malpractices and misconduct
they may have observed. These can be reported confidentially and anonymously by filling out
a report form at ethics.radissonhotels.com, in line with RHG’s Whistleblowing Policy. The
business ethics hotline can be used to report concerns and request advice or guidance about
actions or behaviors that are:

➢ Not aligned with our values, our Code, or related ethics and compliance policies; or
➢ Not in compliance with applicable laws; or
➢ That may significantly affect vital interests of RHG and its affiliates.

The independent supplier of this service will ensure that the concern is swiftly brought to the
attention of the appropriate person or persons in RHG and ensure that the report and follow-up
is documented. The reporting system ethics.radissonhotels.com is duly registered with
authorities where applicable. Data storage, handling and case management procedures,
including information and notification requirements, are specified in written guidance.

Process for Disciplinary Action

The principles of procedural fairness apply to managing and investigating the potential
breaches of the Code. These principles encapsulate an opportunity to be heard, the rule against
bias (decision-makers do not have a personal interest in the outcome) and the evidence rule
(decisions are based on evidence).

Investigations and subsequent actions are proportional to the extent of the potential breach of
the Code. Disciplinary actions will vary depending on the violation and may inter alia include

8-RHG Code of Business Ethics 2022

reprimand, suspension or termination for more serious offenses. RHG may take legal action in
cases of corruption, theft, embezzlement or other unlawful behavior.

Upon receipt of a complaint, either directly or through the ethics hotline, the Ethics Leadership
Group will decide how to proceed. If the complaint represents a potential breach of the Code,
then the process for action will continue to an assessment and investigation of the complaint.

The Ethics Leadership Group will conduct the assessments and investigations into potential
breaches of the Code on a case-by-case basis, taking into consideration the aspects such as
the establishment/hotel where the complaint was lodged, contractual arrangements, severity of
the offence, nature of events or frequency of the violation. As part of said process, the
assessment will be made based on the information submitted by the complainant and additional
information that is gathered during the investigation. The involved RHG employee will be
provided with an opportunity to respond to the allegation and relevant evidence, and to provide
additional evidence upon which the Ethics Leadership Group may rely.

On the basis of the facts and information presented, the Ethics Leadership Group will decide
whether the matter should be:
• dismissed;
• resolved locally with or without corrective actions;
• addressing any systemic issues that are identified; or
• Some matters may involve potentially corrupt conduct and/or potential criminal behavior.
These matters require referral to an appropriate agency, for example, the police or relevant
statutory body.

BUSINESS ETHICS: LEGAL INTEGRITY

As a global leader in hospitality and travel management, RHG has operations or contracted
partners in over 110 countries. RHG’s policy is to comply with all applicable laws and regulations
everywhere it does business, including (but not limited to) competition law, anti-bribery laws,
employee health and safety regulations, labor laws, data protection/ privacy laws, non-
discrimination laws, laws relating to trade sanctions and tax evasion, and anti-money laundering
laws. Certain laws extend beyond country borders. As a global company, RHG is regulated by
many different laws at the same time. If there is a conflict or question, please contact the Legal
department.

RHG employees shall not engage in any unlawful activity while conducting business or
performing their day-to-day RHG duties, nor instruct nor facilitate others to do so. Violations of
law can subject RHG and its employees to civil suits (damage awards or fines) and/or criminal

9-RHG Code of Business Ethics 2022

penalties (fines or jail sentences). RHG will not do business with partners, suppliers or other
third parties who do not require the same legal compliance from their employees.

RHG employees will work with the Legal department and be truthful and cooperative in
connection with inquiries and investigations by government officials and regulatory agencies.
When we work with governments as our clients, RHG employees will also comply with special
requirements associated with government transactions.

MAINTAINING FINANCIAL INTEGRITY

Every RHG employee is expected to conduct their business with integrity and high ethical
standards. This includes our commitment to truthfulness in billing, accounting and financial
reporting practices.

Accurately Document All Financial Transactions

Our financial records serve as the basis for managing our business and are important in meeting
our obligations to shareholders, clients, suppliers and other contracting parties. All records must
be clear, truthful, timely and accurate. These records are necessary for substantiating
compliance with tax, financial and other reporting requirements. In its financial reporting, RHG
shall ensure that all transactions are:

• Compliant with legal and regulatory requirements

• Reviewed as appropriate with financial advisors and auditors
• Properly authorized according to RHG’s policies

All accounting records, as well as reports produced from those reports, should accurately and
fairly reflect in reasonable detail RHG’s assets, liabilities, revenues and expenses. All
transactions should be supported by accurate documentation, in reasonable detail, and recorded
in the proper account and accounting period. All employees have a responsibility to avoid false
or intentionally misleading entries.

All funds, cash and other assets must be recorded and accounted for. Any variance from this
requirement is strictly prohibited. Accordingly, employees must pay attention to the accuracy of
information submitted by others that inter alia include Owners, Contractors, Vendors and other
associates.

Should you discover or suspect a false or misleading item in a financial report or entry, or in any
information provided to Enable’s auditors, you must report it immediately to your supervisor and

10-RHG Code of Business Ethics 2022

the [email protected].

Example:
Expense An associate submits an expense report to his manager for approval. A meal
Report expense on the report does not include an explanation of its business purpose,
Accuracy and the receipt amount and date do not match those stated on the expense
report. The manager does not carefully review the report and approves it for
reimbursement.

When approving transactions, managers have a duty to ensure expenses are

valid, are properly supported, and have a bona fide business purpose. In the
present scenario, the associate and his manager are both responsible for the
inaccuracy of the expense report.

I have lost my meal receipts from a recent work trip. Can I substitute some
personal receipts of similar value to reclaim my expenses?

No, it’s never acceptable to falsify records like this. You should talk to your
manager to work out a solution.

Accurately Disclose Financial Information

In addition, in connection with the preparation of the audited accounts, all employees should
cooperate with internal and external auditors at all times. Under no circumstances should any
employee manipulate, mislead or fraudulently influence internal or external auditors in such a
manner as to affect their opinion of the audited accounts. Inaccuracies in our financial
information may undermine the confidence of our customers, investors, and owners and harm
our reputation. Further, inaccurate financial records could result in RHG failing to satisfy legal,
regulatory, or fiduciary obligations.

RHG conducts its business operations with honesty, reliability and integrity. RHG must speak
with one voice to third parties (such as the media, investors and financial analysts). Only
employees designated by the Chief Executive Officer or the Chief Financial Officer are
authorized to make comments, disclosures or statements to third parties on RHG financial
policy, positions or reporting. Comments, disclosures or statements to third parties shall be
made in accordance with applicable information and communication policies within RHG.

11-RHG Code of Business Ethics 2022

While every effort is made to ensure that controls are in place to prevent fraud, RHG employees
must report all incidents of fraud to the Internal Audit department and Legal department of the
group.

If your job involves signing contracts or making other financial commitments, you must comply
with all contracting requirements and the principles set out in the Delegation of Authority
Policy – including who reviews and approves contracts, what types of provisions to include or
exclude, when to seek legal review and what recordkeeping obligations apply. Please refer the
updated Delegation of Authority policy on Hotelkit or the Intranet.

When in doubt, raise your concerns with a manager who has the authority to conduct further
inquiry.

RELATIONSHIP WITH THIRD PARTIES

Guest and Customer Relations

We are a company of diverse cultures serving diverse guests. We seek to understand our
unique global communities, and to create an environment of inclusiveness.

RHG’s goal is to create, develop and sustain strong and long-lasting relationships with our
guests, franchisees, partners, property owners, financial partners, suppliers and other third
parties by adhering to the Code and by striving to deliver a superior guest experience every
time.

Services and products should always be designed and delivered in line with agreed cost,
specifications and timescales. All statements and communications must be accurate. Customers
should be given what is promised and at the promised price.

RHG highly values the preservation of good relations with our guests and partners. Guest and
stakeholder satisfaction is fundamental to our future success. Misrepresentations about RHG’s
products and services may lead to costly legal action. A false claim, a small untruth, or even a
perception of dishonesty can jeopardize the loyalty and satisfaction of our customers

An employee’s interaction with a guest or potential guest will affect the guest’s experience and
perception of RHG, and all employees are expected to behave in a manner that projects a
positive image of RHG. This includes face-to-face personal interactions as well as interactions
by phone, email, social media and/or internet.

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Giving and offering gifts, entertainment and hospitality

Please note that there are specific rules relating to giving or offering Gifts, Hospitality or
Entertainment to government or political party officials; please refer to the section 'Prevention
of Bribery and Corruption'.

Principle
Employees should never attempt to bribe or improperly influence the employees, agents of, or
others who may be acting for, any external party – including, but not limited to customers,
owners of hotels or other enterprises with which we want to do or retain business – in an attempt
to obtain/retain business, to gain any other benefit for RHG or to induce or reward improper
behavior.

However, RHG also recognizes that gift-giving (including reasonable and infrequent meals and
appropriate entertainment) to non-governmental customers, franchisees, owners, media (to the
extent not state-owned or controlled) or their employees may be appropriate and acceptable
under limited circumstances and following hospitality industry practice.

Conditions
When giving gifts is an expected and widely recognized cultural norm, a modest gift (other than
cash or any cash-equivalent) may be provided if, and only if, the following conditions are
complied with:

(i) It directly relates to the promotion or demonstration of RHG's services and products
or to promote successful working relationship with individuals or entities with whom
RHG maintains a business relationship;
(ii) It is not lavish or extravagant - rather, it must be of reasonable and modest value;
(iii) legally permissible under local law and not prohibited under the policies applicable to
the recipient, to the extent it is not flagged by the recipient;
(iv) provided on an infrequent basis;
(v) not prohibited under the policies applicable to the recipient i.e. to the extent it is not
flagged by the recipient;
(vi) provided solely for the purpose of building generalized goodwill and not for the
purpose, or with the expectation of receiving anything in return and given without an
express or implied understanding that the recipient or any other person is in any way
obligated by acceptance of the gift;
(vii) reasonable and proportionate to the business activity being undertaken;
(viii) It is given or received in a manner that will not improperly influence a business
decision;

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 (ix) It is approved in accordance with the rules set out in below in respect of i) Non-
Governmental Individuals and Entities and ii) Government and Public Officials; and
(x) It is accurately and fully recorded on expenses reports and in accordance with the
RHG Gift and Entertainment policy.

Approval and Recordal Process

Anyone wishing to provide a gift that complies with the above, should follow the approval and
recordal process under the Gifts and Entertainment Policy available on HotelKit or the Intranet.

To the extent it relates to the giving of complimentary rooms, the above conditions need to be
complied with and such gift giving needs to be in line with the company policy.

Example:
Offering A doctor from the University Hospital helped organize several online
Complimentary educational sessions on vaccination against corona virus for RHG
Stay employees. As a token of appreciation, the RHG has offered the doctor
complimentary stay at any of the RHG leased properties in Belgium in line
with the company policy.

Is this allowed?

Yes, this is allowed, to the extent that the recipient doctor does not flag the
complimentary stay as going against his own code of business ethics.

A potential Client who is an Owner of a chain of hotel properties and with

whom RHG intends on building a business relationship with, is offered First
Class fight tickets for an in-person meeting to discuss business
opportunities with the expectation that such treatment would possibly be in
favor of creating an opportunity for business.

Is this allowed?

No, in line with the basic principles set out in the Code, such an offering is
not allowed since it indicates that it has been offered with an expectation
of receiving something in return.

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Receiving or being offered gifts, hospitality and entertainment

Principle
RHG recognizes that it is customary within the hospitality and travel industry for some suppliers
to offer to employees of RHG certain gifts or promotions.

Conditions

A. General Principle for Receiving Gifts or Promotions

RHG recognizes that employees may take advantage of gifts or promotions provided that the
following conditions apply:

(i) the gifts or promotions are legally permissible;

(ii) nothing specific can ever be expected in return;
(iii) it must be connected to a legitimate and generalized business promotional activity or
the performance of an existing contract and not from anyone who has or is seeking a
business relationship with RHG;
(iv) the gifts or promotions have been recorded and/or approved in line with the Gifts and
Entertainment Policy;
(v) the employee complies with any conditions set forth by the supplier;
(vi) the gifts or promotion is not in connection with or intended to create a commercial
advantage.

When a RHG employee receives a gift or promotion that is in compliance with the Code, it is
advisable for such employee to raffle it among department members.

B. Customary Gifts

RHG recognizes further that customary meals, entertainment, or other forms of hospitality from
someone who has a business relationship with RHG is allowed where appropriate as a business
courtesy or local tradition to the extent these are reasonable, which is determined as follows in
addition to the above conditions under A that apply:

(i) The customary gifts are reasonable in the context of the local economy in which the
meal or entertainment is to be provided;
(ii) it must be otherwise consistent with RHG’s policy including RHG Procurement Policy
which allows RHG employees to purchase at advantageous rates with 3rd Party
vendors; and

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 (iii) when evaluating the reasonableness of the customary gift, the frequency with which
meals and/or entertainment are provided for a particular person must be taken into
account, as modest goodwill offerings, frequently provided, can become lavish and
improper over time.

In line with the Gift and Entertainment Policy, such customary gifts will be recorded in line with
the policy with no requirement to list any estimated value of the gift as long as it is deemed in line
with the above.

Example:
Receiving Gifts A vendor offers an RHG employee floor-level seats to a popular sporting
event. The vendor explains that he does not want anything in return; he
cannot attend the event, and he does not want the seats to be wasted. The
value of the tickets are more than 1500 Euros.

The RHG employee should ensure that the gift was offered not with the
intention to gain any improper advantage but in light of an ongoing
business relationship. Furthermore, in line with the Gift and Entertainment
Policy, for this particular gift, the RHG employee should seek approval from
an Executive Committee member, and the gift should be recorded.

Receiving A potential franchisee partner invites an RHG employee to discuss

Hospitality business over dinner and insists on paying the entire bill.

Assuming the meal is not inappropriately lavish, the employee may accept
the meal.

GUIDING PRINCIPLE SUMMARY

RHG employees must use common sense in giving and accepting gifts in the context of
business relationships keeping in view the rationale that is generally acceptable in the
relevant jurisdiction. Accepting gifts that could compromise objectivity in making decisions for
RHG, that creates the appearance of impropriety, or that violates the law must be avoided
completely.

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 Employees must employ best judgment practice in cases where they cannot decline gifts
without offending the gift-giver. In case of doubt on the part of the RHG employee, ask a
supervisor.

In line with the Gift and Entertainment Policy such gifts are reported via
[email protected] or
[email protected] depending on the jurisdiction of
employment of the RHG employee

EMPLOYEE RELATIONS AND EXPECTATIONS

RHG seeks to maintain a culture that supports employee well-being and inclusion and is
committed to encouraging a positive working environment that meets and exceeds legal
requirements.

RHG expects employees to behave politely and respectfully in all interactions. This includes in-
person interaction as well as interactions by phone, email, social media or internet. All
employees should demonstrate integrity, professionalism and respect for those with whom they
work. We do not tolerate behavior that threatens the well-being of any colleague, customer or
other persons. RHG employees must never verbally or physically mistreat others or engage in
offensive behavior. This encompasses sexual or other harassment, abusive or intimidating
treatment, inappropriate language or gestures, discrimination and any other conduct that
interferes with an employee’s ability to do their job – regardless of whether or not the behavior
is illegal.

We recruit individuals without regard to race, gender, age, disability, marital status, sexual
preference, nationality, caste, affiliation with a political organization, national origin, veteran
status, religious or union organization, minority group or any other characteristic protected by
law.

RHG expects that every employee shall ensure that all our cultural beliefs are practiced and
will uphold the principles set forth in this Code.

Our cultural beliefs are:

• We deliver memorable moments every day, everywhere, every time.

• We enjoy serving with our “Yes I Can!” spirit.
• We grow talent, talent grows us.

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• We are many minds, with one mindset.
• We value open and direct interactions to build trust.
• We believe anything is possible.
• We have fun in all that we do.

CONFLICT OF INTEREST

As a general rule, RHG employees should never use or attempt to use their position within RHG
to obtain any improper personal benefit for themselves, their families or for any other person or
entity – including RHG itself.

RHG does not accept situations that could create a conflict, or the appearance of a conflict,
between RHG’s interest and the employee’s personal interests.

Employees of the central office (“CSO”) and area offices (“ASOs”), business units and hotels of
RHG may, however, encounter situations on the job or in their free time where their own
personal interest, or that of persons or companies in which they have ties or links (financial or
otherwise), may conflict with RHG’s interest and such conflicts may take many forms.

Although RHG recognizes and understands that its employees may take part in activities
outside their jobs and we respect our employees’ privacy when it comes to personal conduct
outside of work, employees may not ask for or receive any payment, other than for legitimate
business reasons, from actual or potential franchisees, partners, property owners, financial
partners, competitors or suppliers.

No employee may use RHG proprietary information or other confidential information entrusted
to RHG to obtain any improper personal benefit for themselves, their families or any other
person.

The following are examples of such conflicts of interest, which an RHG employee should not
get involved in:

(i) an individual deriving personal gain through RHG information or business;

(ii) owning (yourself, your spouse or a family member residing with you) a financial
interest in suppliers to or competitors of RHG (except for stock in publicly traded
companies, which may not exceed 1%);
(iii) in relation to suppliers of RHG, to the extent an RHG employee is involved or has
influence in the decision-making of RHG to appoint such supplier, such RHG
employee should not accept services from such supplier;

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 (iv) contracting a supplier, either directly by RHG or through a contracting party of RHG,
that is a related party of an RHG employee whereby the team contracting the work
with such supplier is in a direct reporting line to such RHG employee;
(v) accepting outside compensation for work already being paid for by RHG; and
(vi) serving as director, officer, employee or consultant of a supplier to or competitor of
RHG.
(vii) In the context of their professional activities, all RHG employees must act at all times
in the interest RHG. While respecting the personal life of its employees, RHG expects
them to proactively avoid any apparent or real conflicts of interest. Any RHG
employee who is a family member or relative of another RHG employee holding a
position of leadership and is in a direct reporting line to such RHG employee holding
said leadership position must disclose this immediately to the HR Department with
copy to Executive Vice President & Global Chief Resources Officer.

If there is any doubt as to whether there may be an actual or perceived conflict of interest, it
should be disclosed to a member of the Ethics Leadership Group to determine how the matter
should be resolved.

RESPONSIBLE BUSINESS

RHG is committed to assisting our guests in addressing environmental issues, as well as in

managing and reducing their environmental impact.

RHG expects its suppliers to be aware of and address environmental issues as well.

RHG is committed to ensuring that no modern slavery, human trafficking, or other human rights
violations exists in its business or supply chains. RHG has signed the United Nations Global
Compact (The Compact). The Compact asks companies to embrace, support and enact, within
their sphere of influence, a set of core values in the areas of human rights, labor standards, the
environment and anti-corruption. RHG has long supported the End Child Prostitution, Child
Pornography and Trafficking of Children for Sexual Purposes (ECPAT) Code of Conduct to
protect children against sexual exploitation in travel and tourism. All employees are expected
to abide by the Compact and the ECPAT Code.

Under no circumstances may RHG funds, property (including electronic devices and RHG-
supported technology) or personnel be used to further or support activities prohibited by the
Compact, ECPAT Code or this Code. RHG has no tolerance for human rights abuses, nor for
any form of modern slavery, either in our organization, or in our supply chains.

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SUPPLIERS

RHG relies on its suppliers to provide quality services and products to our guests. It is critical
that all RHG suppliers share our commitment to conducting business with high ethical
standards.

RHG employees should have an understanding of our supplier’s businesses and operations
and shall conduct business with suppliers in accordance with our contractual obligations. In
such interactions, employees are also expected to treat suppliers with respect and exhibit the
same level of ethical conduct that we expect of the supplier.

Employees who interact with suppliers shall ensure that suppliers are reputable and qualified.
They shall also articulate RHG’s supplier management process, procedures and timescales,
enabling suppliers to understand the expectations, requirements and criteria of RHG in
selecting a supplier during the bid process.

RHG Employees must exercise careful scrutiny over suppliers and service providers that may
be using the labor of people coerced into working by threat or intimidation; comply strictly with
the minimum legal working age in each host country; and exercise the utmost care and attention
in choosing suppliers and service providers.

Confidential information received from suppliers will be maintained in confidence.

CONFIDENTIALITY, DATA PROTECTION & PRIVACY

We protect the confidentiality of information to which we have access in the course of our
business in accordance with applicable law and contractual obligations. This information
includes but is not limited to, RHG trade secrets, financial data, products, personnel
information, business transactions and information entrusted to RHG in confidence by third
parties – as well as information concerning our employees, clients, guests, travelers,
suppliers and shareholders. We are all responsible for protecting this confidential information
regardless of the form in which it comes to us (in conversations, paper copy, electronically,
etc.).

We require written confidentiality agreements (also called non-disclosure agreements) with any
party to whom we will be disclosing confidential information.

Confidential information belonging to third parties obtained through previous employment or

unethical or unlawful means, must not be communicated to RHG. Likewise, RHG employees

20-RHG Code of Business Ethics 2022

may not divulge any confidential information to third parties, whether during or following
employment with one of RHG’s hotels or business units. When in doubt, you should treat
information as confidential and consult the Legal department for guidance.

In addition, RHG needs to collect and process personal data of individuals in order to effectively
run its businesses. We consider compliance with all applicable data protection laws to be crucial
to both RHG corporate values and the success of our business. RHG therefore undertakes to
comply with all applicable data protection and privacy laws with respect to guests, employees,
and other individuals’ personal data, including with regards to the international transfer of such
information and any laws related to specific types of data, such as medical or credit card
information. This requires all employees and other individuals working for RHG to ensure that
whenever they handle personal data in the context of their duties, they do so in accordance
with the relevant legal requirements and all relevant RHG policies and procedures, notably
including the General Radisson Personal Data Handling Policy and the Hotel Personal Data
Handling Policy which are available in the ‘GDPR’ section on the Intranet i.e. Rezportal.

RHG expects each employee to always personal data as follows:

(i) access and process personal data only to the extent necessary for the purposes for
which the data was collected, and only when directly related to his/her duties;
(ii) store personal data in a secure way; and
(iii) disclose and transfer personal data only with data processing agreements or
appropriate safeguards in place, where necessary, and in accordance with all
applicable RHG policies and procedures or with prior approval of the competent
person.

RHG employees must be careful when handling computers, software, data and e-mail messages
to ensure that no inadvertent access to sensitive information is allowed. For instance, computers
should be physically protected, and passwords should not be divulged.

COMPETITION/COMPETITIVE PRACTICES

RHG complies with the antitrust and competition laws of the many countries where we do
business. These laws strictly forbid exchanging sensitive competitive information (such as any
information relating to pricing, customers, or strategies) with competitors as well as entering
into agreements that restrict competition. As part of our efforts to ensure compliance with these
laws, we will have no agreements, understandings or plans with competitors that limit or restrict
competition – including price fixing, allocation of clients or geographic markets, agreements to
boycott or refuse to deal with certain customers or suppliers, or agreements to coordinate terms

21-RHG Code of Business Ethics 2022

or conditions for wages, benefits or other compensation. If you become aware at any time about
discussions on restricting competition, you must immediately inform the Legal department.

In addition to risks arising from dealings with competitors, you should also be mindful of the
risks associated with agreements with our business partners, suppliers and customers,
including clauses that set minimum prices, clauses that provide for exclusivity, or price parity
clauses.

These laws are often complex and global in reach, and you should seek the advice of the Legal
department before taking any action that could be considered anti-competitive.

Example:
Discussions A manager from a competing hotel tells me about an increase in the price
with of his rooms during the upcoming summer period. This is obviously
Competitors valuable information. Who can I talk to about it and what can I do with it?

Any exchange of sensitive information with competitors, especially about

pricing or discounting policy, is unlawful and may distort competition. Such
conversations must be ended immediately, and information received must
not be disclosed to anyone. Given the seriousness of such a situation, the
matter must be reported without delay to your manager and the Legal
Department

PREVENTING BRIBERY AND CORRUPTION

RHG has zero tolerance of bribery. Every employee must fully comply with the requirements of
this Code as well as applicable laws relating to bribery and corruption including without limitation
the US Foreign Corrupt Practices Act (FCPA) and UK Bribery Act (UKBA). All persons
conducting business on behalf of RHG, or for the benefit of RHG, must always act in a manner
consistent with RHG’s commitment to doing business with integrity, including by avoiding
bribery-related conduct or corruption of any kind.

RHG’s policy is to comply with all applicable laws and regulations, everywhere it does business.
This policy extends to all of RHG’s domestic and foreign operations, including operations
conducted by subsidiaries, consultants, agents, advisors, vendors, intermediaries, any majority
– owned or controlled affiliates – including joint ventures or any other parties with whom we
may partner, or which may act on our behalf. Any violation of anti-corruption laws is serious and

22-RHG Code of Business Ethics 2022

puts both RHG and the persons involved at risk of significant monetary fines, criminal penalties
(including prison time for individuals) and severe damage to RHG’s reputation.

No employee shall be involved, directly or indirectly, in giving, making, offering, receiving,

requesting, authorizing, allowing or facilitating bribes (involving money or anything else of value)
to any person to obtain or retain business for RHG or secure any other improper advantage.
This prohibition is very broad and covers: (i) cash payments; (ii) non-cash payments, benefits
and favors; and (iii) otherwise legitimate business expenditures, such as gifts, entertainment,
and hosted travel or training, if they do not meet the requirements of this policy. RHG prohibits
these payments and transfers of value whether they are made directly or indirectly through third
parties, such as consultants, agents, advisors, vendors, intermediaries, and joint venture
partners. No employee may assist, aid or facilitate third parties engaging in bribery.

In addition to prohibiting bribery, RHG requires that all RHG personnel, worldwide, ensure that
all transactions and dispositions of assets are consistent with management authorizations,
while maintaining books and records that fairly, timely, accurately, and in reasonable detail,
reflect the nature of all transactions undertaken by RHG and the disposition of all RHG ’s assets.

Each country in which RHG conducts business has anti-corruption laws and regulations. It is
important to understand the requirements of, and to comply with, each of those prohibitions on
bribery as well. For more information on the rules related to a particular country, contact the
Legal department.

Third parties

Third parties acting on RHG's behalf are also prohibited from offering, giving or receiving bribes.
Employees shall undertake good-faith efforts to ensure that no agents, consultants, joint
ventures, vendors and other contracted partners make any payments or provide any gifts or
anything else of value on our behalf, or for our benefit, that would not be permitted if we were
to make the payment or provide the gift directly.

RHG’s policy and applicable laws require RHG to satisfactorily complete rigorous anti-corruption
due diligence prior to entering into any binding agreements for transactions, such as third-party
and intermediary engagements, joint ventures, mergers, acquisitions, franchise agreements,
hotel management contracts and strategic investments. The Legal department must be involved
with other departments in such diligence and in the final assessment of the findings. Our zero-
tolerance approach to bribery and corruption must be communicated to all suppliers,
contractors and business partners at the outset of our business relationship with them – and as
appropriate thereafter.

23-RHG Code of Business Ethics 2022

In addition, no employee shall provide advice to a third party or other business associate on
how to engage in practices, which, if they were acts of RHG’s employees, would be inconsistent
with this policy or this Code.

Gifts, hospitality and entertainment

While gifts, hospitality, travel and entertainment can often be a legitimate part of conducting
business, they can also constitute, or be seen to constitute, bribes. Please refer to the sections
in this Code on Client, Customer and Guest Relations and on Conflict of Interest for further
guidance on when employees can give, offer and receive gifts, hospitality, travel and
entertainment to non-government officials.

Dealing with public officials

Particular care should be taken when dealing, directly or indirectly, with government and public
officials.

In line also with the Gift and Entertainment Policy, no employee may make payments to or offer
or give anything of value (including cash or gift cards, discounted or free food, beverages,
entertainment or use of hotel facilities) to government or political party officials without seeking
specific approval from the Executive Vice President & Chief Legal Officer, General Counsel.

Facilitation payments, which are small unofficial payments made to secure or expedite the
performance of a routine process an official is already under a duty to perform is a bribe
(regardless of size or local business practices) and are often illegal. Employees may not make
any such payments without seeking specific approval from the Executive Vice President & Chief
Legal Officer, General Counsel.

Government or political-party officials include anyone directly or indirectly employed by acting for
any government body or agency or anyone performing a public function. This should be
understood widely and includes, for example, anyone working for any national or local
government or public department, body or agency (e.g., police, fire, state-owned or controlled
media, health inspection officials and other government regulators), people holding a public
position, employees of state-owned or controlled enterprises, employees of public international
organizations, officials of a political party, candidates for political office and members of a royal
family, as well as the spouses and immediate family members of any of the above. It is not always
obvious that someone is such an official, so if you are in any doubt as to who you are dealing
with, consult with the Executive Vice President & Chief Legal Officer, General Counsel.

24-RHG Code of Business Ethics 2022

Political and charitable activity

RHG funds, property (including electronic devices and computer systems) and services may
not be used for political campaigns, political parties or to make contributions to any political
campaigns, political parties or charitable causes on behalf of, or for the benefit of, any
government official or political or party figure.

While employees may participate as individual citizens in the political process, decisions to do so
are entirely personal and voluntary. Employees engaging in political campaign activities are
expected to do so as private citizens and must at all times make clear that their views and actions
are their own, and not those of RHG. Employees must not use their position with RHG to coerce
or pressure other employees to make contributions to, or support or oppose any political
candidates, elections or ballot initiatives. Employees will not be reimbursed directly or through
compensation increases for personal political contributions or expenses, and RHG will not take
any action towards an employee based on their political contributions or lack thereof.

Example:
Bribery of Following a tax audit in a country, the General Manager of a leased hotel
Public Officials receives a reassessment notice. The basis for this reassessment appears
to be unjustified. This is what local tax inspectors sometimes do in the hope
of being offered cash compensation in exchange for withdrawing the
reassessment. The compensation is very small in value compared to the
reassessment.

By paying even a symbolic amount, the employee can expose

himself/herself and RHG to criminal prosecution. In addition, such an
employee is subject to disciplinary action that could result in his/her
dismissal

In such a situation, employees should immediately notify their manager,

and the Executive Vice President & Chief Legal Officer, General Counsel
who is equipped in assisting employee handle the situation appropriately.

Bribery of Third A company is planning to hold its annual convention in one of the managed
Parties hotel properties of RHG that needs to see an improvement in its occupancy
rate. The contract would involve accommodating three hundred people
over two days in the middle of the low season. To obtain this contract, the
General Manager in line with the Complimentary Stay policy available on
Hotelkit is inclined to provide a stay to convention organiser and his

25-RHG Code of Business Ethics 2022

 assistant for a week’s stay at the hotel with their respective families to
familiarize themselves with its advantages.

It may be appropriate to offer complimentary stay basis the Company

Policy to both the convention organizer and his assistant. However,
extending any undue benefits or extras such as an invitation to the family
to stay free of charge at the hotel would clearly be inappropriate or even
be considered as an act of private corruption. Consequently, this must be
avoided. It may be prudent to issue the convention organizer with full
documentation beforehand, clearly defining the amenities and services
included in your invitation and a suggested schedule of meetings, visits
and introductions to service providers, etc. is very much recommended.

ANTI-MONEY LAUNDERING AND FACILITATION OF TAX EVASION

RHG is committed to operating with the highest ethical standards and strictly prohibits any form
of crime, including any crime that inter alia involves obtaining an economic benefit through
illegal methods i.e. money laundering, tax evasion, embezzlement of funds and/or improper
payments.

Anti-money laundering laws impose significant penalties for acquiring, possessing, hiding, or
dealing with the proceeds of crime. RHG has a zero-tolerance approach when it comes to any
sort of violation of anti-money laundering laws.

RHG can also be held responsible for facilitating or enabling tax evasion by third parties,
including by all RHG agents, consultants, advisors and partners.

Non-compliance with such laws is serious and puts both RHG and the persons involved at risk
of significant monetary fines, criminal penalties (including prison time for individuals) and severe
damage to RHG’s reputation.

This applies to all RHG employees and directors as well as to agents, consultants, advisors,
partners and others performing services for or on RHG's behalf. We require that RHG
employees be vigilant at all times, analyze all relevant activities that may be performed in the
course of their association with RHG and promptly raise concerns and/or suspicions relating to
any financial crime or tax evasion in accordance with this policy.

26-RHG Code of Business Ethics 2022

Such suspicious situations may include without limitation the following:
• RHG being requested to receive or make payments to any entity that is not a party to
the transaction, it being noted however that RHG’s payment policy does not authorize
payments to be made to any entity other than the contracting entity (Please check the
policies applicable to payments on HotelKit for further details);
• Where money is transferred or routed through unrelated countries or bank accounts, in
particular countries or territories that are considered 'offshore' or which otherwise
represent an enhanced risk of financial crime;
• Requests to provide or receive payment at times unrelated to when services are
provided;
• Requests for overpayments or for refunds following an over-payment;
• False reporting such as misrepresenting prices, misdescribing goods or services, or
misdescribing taxes;
• Where payments are made or received in anonymous forms (such as cash, vouchers or
prepaid cards);
• Payments from multiple sources to satisfy a single invoice;
• Any other oddly structured transactions or arrangements.

Any such red flags should be immediately reported to the Executive Vice President & Chief
Legal Officer, General Counsel.

Receipt of A hotel owner intends on paying for the fees in lieu of services provided by
Payments RHG under the IMA from the bank account and company not agreed under
the contract.

This factual matrix does not comply with Group rules and presents a risk
of money laundering. RHG’s contracts its partners clearly identifies all
payment details in compliance with RHG policies. Such a situation must
immediately be brought to the attention of your manager and the legal
department.

TRADE SANCTIONS

RHG is committed to ensuring that it conducts business in compliance with all applicable
sanctions regimes and will not engage with any parties sanctioned under such measures. Trade
sanctions generally prohibit companies and individuals from engaging in business activities with
certain countries or with particular restricted persons or entities. Employees and anyone doing
business for or on behalf of RHG must therefore be clear who we are dealing with and of

27-RHG Code of Business Ethics 2022

transactions and jurisdictions that represent an enhanced sanctions risk. If you have any doubts
or concerns about the restrictions that may apply to your business activities on behalf of RHG,
please contact the Legal department.

Breaching sanctions carries serious penalties including significant fines and imprisonment, as
well as reputational harm. As such, RHG and all employees and representatives must exercise
caution as to whom:
• services are provided to/ we allow services to be provided to; and
• goods are purchased from.

RHG and all employees and representatives must never deal with any person or property in a
manner which contravenes applicable trade sanctions or restrictions, including without limitation
those adopted by the UK and EU.

REPORTING TO RHG AND COMPLIANCE CERTIFICATION

All General Managers of the Owned, Leased, and Managed hotels of RHG have to report in as
further described below for gifts, cash or cash equivalents received by any manager or staff
member in the hotel.

The same process is applicable to all Central, Area, Regional, Sales and Purchasing Offices
for any such gifts given or received by the management and any of the staff.

The Executive Committee, members of the Business Leadership Team and Head of
Departments have to report in the same manner.

In light of the above, each person that falls within the following categories must complete and
electronically submit a Compliance Certificate (to the Executive Vice President & Chief Legal
Officer, General Counsel) by 31 January of each year at the latest to confirm adherence with
this Code and any relevant policies that may be referred to herein for the previous calendar
year (an example of the compliance certificate is attached) on the platform used by RHG:

• The members of the Executive Committee

• The Heads of Departments (both at CSO and ASOs)
• Area Senior Vice Presidents
• Regional Directors and District Directors
• Hotel General Managers and Financial Controllers of Owned, Leased, and Managed
Hotels

28-RHG Code of Business Ethics 2022

 • Persons in sales and procurement (including at CSO and area/regional levels) that are
at manager level or above

A Statement of Exception should also be attached to the Compliance Certificate, if applicable.

29-RHG Code of Business Ethics 2022

COMPLIANCE CERTIFICATE EXERCISE

The Code will be available for employees to familiarize themselves with on Hotelkit.
It is advisable that employees read and understand the Code.

The Compliance exercise has been fully automated via Workday. The employees
required to conduct the exercise will find the task available in the inbox of their
respective Workday accounts on January 1 of every year for the compliance exercise.
This exercise must be completed before end of business day on January 31.

The task is divided in 2 sections as follows:

Task Description Explanation

Task 1 This section deals with the following If the statement in Task 1 is
statement: applicable to the employee
inasmuch as he/she in
By selecting ‘I Agree’, compliance with the Code,
he/she must select ‘I Agree’
You are confirming that: for both Task 1 and Task 2. In
1) you have read and understood this case, no document
the RHG Code of Business capturing any exceptions are
Ethics (the “Code”); required to be attached as
2) you understand the importance possible with Task 2.
of maintaining a high standard
of ethical conduct and will If the statements in Task 1 are
adhere in all respects to the not true and applicable for the
ethical standards described in employee i.e. he/she has an
the Code; incidence of exception to
3) you understand that any report, he/she should not
violation of the Code will subject select ‘I Agree’ for Task 1.
me to appropriate disciplinary Additionally, for Task 2 the
action, which may include option of ‘I Agree’ must be
demotion or discharge; selected and a document
explaining the incidence of
AND THAT exception to be reported must
be attached.
You are certifying that during the prior
calendar year i.e 2022, you and the The ‘I Agree’ options under
Unit(s)/Hotel(s) to which you are Task 1 and Task 2 should be
assigned: selected basis the situation
1) acted in accordance with all applicable to the employee as
competition rules; explained above.
2) were not engaged in any
conflict-of-interest activities; Finally, the employee to select
and the Submit Tab. This shall be

30-RHG Code of Business Ethics 2022

 3) were fully in compliance with the considered as electronic
Code. acceptance and signature on
Task 2 This section deals with the following behalf of the employee.
statement:
The employees are required
to check their Workday inbox
By selecting ‘I Agree’, you are on January 1 every year and
confirming that any exceptions to the are mandatorily required to
Code are being disclosed in an complete this task by January
attachment to this submission. By not 31. The employees who shall
attaching any document to this have not completed the
submission, you are confirming that exercise shall be considered
there are no exceptions to the Code. non-compliant to the Code.

31-RHG Code of Business Ethics 2022