WE LIVE OUR VALUES

CODE OF CONDUCT AND ETHICS

MESSAGE FROM OUR GROUP
CHIEF EXECUTIVE OFFICER
JOSÉ SILVA

Today, Jumeirah Group is well-established luxury hotel company, which has had a distinct impact on the global hospitality market for the past two
decades. Jumeirah is a Dubai national champion and an acclaimed luxury hospitality leader, and we can be proud to have transformed the way luxury
is defined, as exemplified by our flagship hotel, Burj Al Arab Jumeirah.
Success and achieving our vision is a reflection of our unyielding dedication to excellence and would not be possible without the strong foundation
of Jumeirah values – our Hallmarks and Guiding Principles.
Our Hallmarks help define our culture and are at the core of our philosophy for Extraordinary Service. Jumeirah colleagues, inspired by our Guiding
Principles, are the foundation of our achievements and are at the heart of everything we do.
Strong ethics and good business go hand in hand and the values, reinforced in our Code of Conduct and Ethics, demonstrate our commitment to
those high standards and to ensuring that all colleagues act accordingly.
Jumeirah provides an environment where colleagues can shine. This Code applies equally to all colleagues and to all grades across all properties and
business units. This Code provides you with the principles you need to be empowered and to empower others to do the right thing. Please make sure
you not only read and familiarise yourself with the Code, but also take the time to remind yourself of your responsibilities. This Code provides you
with guidance if you are ever unsure of the correct path to take, however it cannot cover every situation. Any individual queries or concerns should
be raised in accordance with the procedures outlined in the following pages.
As a valued colleague, we trust you to live our values and this will ensure we remain trusted by our guests, colleagues, stakeholders and business
associates. We are proud to have you as an engaged and energised colleague and together we will work to ensure the continued success of Jumeirah.

Thank you.

José Silva
Jumeirah Group Chief Executive Officer
TABLE OF
CONTENTS
1 OUR CULTURE 4
1.1 Our vision and values 5
1.2 Using the Code of Conduct and Ethics 6
1.3 Getting help and advice 7
1.4 Speak up 8
1.5 Our expectations 10
2 OUR COLLEAGUES 11
2.1 Your personal commitment 12
2.2 Creating equal employment opportunities 13
2.3 Providing a safe and healthy workplace 14
2.4 Ensuring a respectful and harassment-free workplace 15
3 OUR INTEGRITY 16
3.1 Competing fairly 17
3.2 Managing conflicts of interest 18
3.3 Giving and receiving gifts and entertainment 19
3.4 Preventing bribery, corruption and fraud 20
3.5 Political activity 21
3.6 Preventing insider trading 22
4 OUR GUESTS AND ASSETS 23
4.1 Looking after our guests 24
4.2 Respecting guest and colleague privacy 25
4.3 Safeguarding our assets and managing confidential information 26
4.4 Communicating with the media and online 27
4.5 Keeping accurate and complete records, reports and documents 28
5 OUR COMMUNITY AND ENVIRONMENT 29
5.1 Managing sustainable operations 30
5.2 Engaging with our community 31
5.3 Supporting human rights 32
5.4 Partnering with Jumeirah 33
6 DECLARATION OF INTEREST 34
6.1 Declaration of Interest Form 35
1 OUR
CULTURE
1.1 OUR VISION AND VALUES Page 5 of 36

OUR VISION OUR GUIDING PRINCIPLES

Our vision, as Jumeirah Group LLC, together with our subsidiaries and affiliates worldwide INTEGRITY
(“Jumeirah”) is to be a world class luxury international hospitality company, committed to being We act with honesty and sincerity in everything we do. We say what we mean, do what we say
the industry leader in all of our activities. and build confidence in our team.

Our values, being our Hallmarks and Guiding Principles, help each of us to fulfill our vision by TEAMWORK
setting forth the high standards we expect of one another. These form the backbone of our culture We work towards common goals through open communication, mutual support and win-win
at Jumeirah and through them, we strive to create a workplace that brings out the best of everyone attitudes. We respect our differences and build upon our strengths.
and a guest experience that truly is exceptional. RECOGNITION
The benefits of following these guidelines positively impact our colleagues, guests, shareholders We ensure that people’s individual needs and successes are supported and recognised.
and other important stakeholders. We encourage you to memorise and uphold them at all times. INNOVATION
We are open minded, challenging conventional thinking, improving our processes and
OUR VALUES implementing new ideas faster than our competitors.
OUR HALLMARKS CONTINUOUS GROWTH
I will always smile and greet our guests before they greet me. We provide an environment where our colleagues and our business can flourish and grow.
PEOPLE FOCUS
My first response to a guest request will never be no.
We focus on our colleagues, customers and business associates and they acknowledge us as
I will treat all colleagues with respect and integrity. preferred partners.

Our success and sustainability is achieved through:

• Making guests our first priority and striving constantly to exceed their expectations.
• Applying our Hallmarks, Guiding Principles and core standards in our day-to-day activities.
• Leading by example and role-modeling a culture of excellence in everything we do.
• Providing consistently superior and innovative services.

1 OUR CULTURE JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS

1.2 USING THE CODE OF CONDUCT AND ETHICS Page 6 of 36

Our Code of Conduct and Ethics (the “Code”) demonstrates our commitment to integrity and how we embrace the laws, rules,
customs and regulations in the countries where we do business. We operate globally and this Code applies to all colleagues,
officers and directors of Jumeirah, including temporary staff, referred to in this Code as ‘colleagues’. This Code also applies to
suppliers and other service providers, with respect to their dealings with Jumeirah, referred to in this Code as ‘business associates’.
Each of us is responsible for understanding and complying with this Code. It is designed to help each of us to act ethically and to
conduct ourselves in a manner that protects Jumeirah’s reputation. It will help you understand our commitment to good business
practices at Jumeirah and to build awareness of ethical and legal issues you may face when doing your job. As a colleague, you
can also refer to your employment contract which outlines the terms within which we expect you to operate. If you are a business
associate, you can also refer to your relevant contract with Jumeirah which outlines the terms within which we expect you to per-
form. You should familiarise yourself with this Code and comply with our business practices. For further information, please see
section 5.4 of this Code, Partnering with Jumeirah.
This Code and your contract cannot cover everything, so you must use common sense and exercise good judgment and if in
doubt, always ask.

COMPLYING WITH OUR CODE

Your actions affect Jumeirah’s reputation and integrity. It is essential that you take the time to read this Code and develop
a working knowledge of it. You are required to complete periodically a Compliance Certification when requested
by Jumeirah and participate in company activities (eg training, team meetings, surveys) which ensure we live our
values. You should declare any conflicts of interest by completing the Declaration of Interest form. If your circum-
stances change and new conflicts of interest arise, you will need to submit an updated Declaration of Interest form.
IMPORTANT: This Code is in line with the Dubai Holding LLC Global Code of Conduct and in the event of any inconsist-
ency, the Dubai Holding LLC Global Code of Conduct will prevail.
This Code offers general guidelines only and is subject to local law. Your department may issue its own policies and pro-
cedures. You must follow those policies and procedures in addition to those described in this Code, as well as Jumeirah’s
more detailed policies. In the event that there is a conflict between this Code and any other policies, this Code will prevail.

1 OUR CULTURE JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS

1.3 GET TING HELP AND ADVICE Page 7 of 36

We have all been in challenging situations or been asked questions to which we do not know the answers. This can be particularly true when it comes to legal or ethical issues. If you are ever unsure about any
situation, feel uncomfortable about what you are being asked to do or have any questions about this Code or applicable laws or regulations, do not be afraid to ask for advice and guidance. If you do not know
who to ask, the best place to start is your line manager.
At Jumeirah we live and breathe our Hallmarks and Guiding Principles and these are the cornerstone of our success. Integrity is an important element of our culture and our commitment to this value means
we address all legal and ethical issues. We must never ignore or keep silent about things we know are wrong.

SEEK ADVICE IF YOU ARE GET HELP IF YOU FIND

UNSURE OF THE ANSWER TO YOURSELF IN ANY OF THE WHO CAN I ASK FOR
ANY OF THE FOLLOWING FOLLOWING SITUATIONS AND HELP OR ADVICE?
QUESTIONS DO NOT KNOW WHAT TO DO

Is it legal?
You do not understand the Code.
Is it ethical?
The laws, rules and regulations are As a Colleague If you want to report a possible breach of company’s
Could it harm the environment?
complicated and difficult to interpret. Code of Conduct and Ethics
Is it safe?
You do not have the experience to deal
Does it comply with Jumeirah’s Code of with the situation. 1. You can either email or talk to your Supervisor / Manager / Senior Manager /
Conduct and Ethics? Hotel Manager / General Manager
There are lots of different opinions
Would you be embarrassed to tell your about the appropriate course of action. 2. You can either email or talk to people in Human Resources / Security /
friends and family about it? Internal Audit / Legal
You feel uncomfortable with the
Would it damage Jumeirah’s reputation proposed actions or decisions.
if it appeared in a newspaper or online? 3. You can contact Careline by:
• emailing to careline@jumeirah.com
* Please refer to section 1.4 of this Code for further details
• submitting a report on the Careline website via mercury
If you wish to report anonymously, you can email careline@jumeirah.com
ETHICS CHECKLIST
As a Supervisor / Manager / Senior Manager / Hotel Manager / General Manager, you can
respond to concerns reported by colleagues
When making a decision or following a directive ask yourself
1. Firstly, you need to complete the Whistleblower Form, which is available in the
Is my behaviour consistent with our Hallmarks and Guiding Principles?
Whistleblower Policy on the Jumeirah Know How Legal site
Am I doing the right thing?
2. Secondly, you need to escalate the colleague’s concern by sending the completed form to
Does my action comply with the spirit and letter of this Code and applicable law? your Senior Manager and to careline@jumeirah.com
Would I feel confident explaining my decision if it were made public?
Are there any restrictions or conflicts which I should raise and which may prevent me from
being involved in the decision process or transaction?

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1.4 SPEAK UP Page 8 of 36

If you suspect or are aware of a situation or conduct that is in violation of this Code, the law or other Jumeirah policies, you should speak up as soon as possible.
Raising concerns helps protect us, our community, colleagues, business associates and stakeholders; only by speaking up when we suspect potential violations of law or policy can we address these issues. All
concerns raised are treated seriously and investigated discreetly, fairly and promptly.
Jumeirah forbids any form of retaliation against anyone for raising in good faith, or helping to address, an ethical concern. If you suspect that you or someone you know has received retaliation for raising an
ethical concern, contact Careline if you are a colleague or ethicsline if you are a business associate.

YOU MUST RAISE CONCERNS

WHAT DOES IN GOOD
IF THE SITUATION YOU MUST NEVER
FAITH MEAN?
OR CONDUCT

Breaks, or you suspect it breaks, the law or this Code. In “good faith” means that you
Make false allegations or claims knowing them to be untrue. If
Is dishonest, fraudulent or corrupt. you do this you may face disciplinary action or other appropriate
sincerely believe that when you
Is misleading or deceptive. consequences. raise concerns, you are doing
Poses a risk to somebody’s health and safety. Use the confidential reporting lines with the intention of personal gain so for right and just reason.
Would harm the environment. or malicious intent. We trust you to be honest
Poses a risk to the assets or reputation of Jumeirah. Ignore or disregard any information you become aware of that and truthful when you speak
breaches this Code. up regarding misconduct,
Is unethical, disrespectful or abusive.
Be afraid to speak up. suspected violations or any
Would discriminate against others.
other matter you think should
be reported. You must never
make false reports or speak
WHO DO I CONTACT? up about things you know are
IF I AM A BUSINESS untrue.
IF I AM A COLLEAGUE ASSOCIATE?

Email or speak to your line manager or senior manager;

Email the Group Chief Security Officer or the Chief Internal Audit Officer if you are concerned Concerns can be raised
about bribery or fraud; or anonymously (ie on a no name
Email: ethicsline@jumeirah.com
Contact Careline: basis) on either Careline or
• Email: careline@jumeirah.com
ethicsline
• Via Mercury, by clicking on Careline or typing https://careline into your browser

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1.4 SPEAK UP Continued... Page 9 of 36

I reported something because I thought it was suspicious, but it turns out nothing is wrong.
Will I get into trouble?

No, you will not get into trouble, providing the concern was raised in good faith and you
genuinely believed it was wrong. However, if you deliberately reported something knowing
it was false, with the intention of getting someone else into trouble you may find yourself
facing disciplinary action or other appropriate consequences.

I work as a waiter. My supervisor asked me to inaccurately record inventory. I know that if I

do this, I will be going against company policy, but I don’t want to get into trouble. If I don’t
do what he says and if I report it, I’ll also get into trouble for speaking out. What do I do?

If you are asked to do something that you know is wrong, it is your duty and responsibility to
report it. You have options outside of your department to report it or you can call Careline.
If you report it there will be no retaliation, but if you carry out their instruction, you could
be in as much trouble as them.

For more information please refer to our Social Media policy

1 OUR CULTURE JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS

1.5 OUR EXPECTATIONS Page 10 of 36

We expect you to uphold this Code and to live our values. We treat violations seriously and below are some examples of conduct that may result in disciplinary action or other appropriate consequences:
Breaching law, regulation and/or professional standards or this Code. Retaliating against others for reporting a concern or breach.
Directing or encouraging others to breach laws or this Code. Falsely reporting when you know it is untrue.
Failing to report known or suspected breaches of law or Jumeirah policies or procedures. Committing any acts of theft, fraud or other corrupt behaviour.
Interfering with or being uncooperative during an investigation.

EXPECTATIONS OF OUR COLLEAGUES ADDITIONAL EXPECTATIONS OF OUR MANAGERS

Follow this Code.

Represent Jumeirah with the highest standard of conduct
and ethics.
Ask questions and seek advice if you do not know the
right thing to do.
Report any suspicions, incidents or concerns as soon as
you become aware of them.
Satisfy yourself that you would be comfortable with your
conduct, if it ever became public.
Set an example by acting with the highest integrity.
Build a culture where colleagues understand that following this Code is of utmost importance.
Ensure your team is trained on this Code and discuss the content regularly to ensure it is familiar.
Create an environment where colleagues feel comfortable and safe voicing their concerns.
Protect anyone reporting incidents or suspicions in good faith, from any kind of retaliation.
Understand and be familiar with the laws, rules and regulations that apply to your role.
Escalate any violations of this Code.

If you are a manager you will be held accountable for the misconduct of the people you supervise in the following
circumstances:
You knew or should have known that fraud, harassment or any other misconduct was occurring.
You directed or pressured others to violate this Code in order to meet business objectives.
You failed to ensure that colleagues received sufficient information, tools and training to comply with this Code.
You failed to set a positive example, acted without integrity or had a history of permitting breaches of this Code.

1 OUR CULTURE JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS

2 OUR
COLLEAGUES
2.1 YOUR PERSONAL COMMITMENT
As a Jumeirah colleague you have a responsibility to understand and comply with this Code. We also encourage our business associates to take the time to read and understand it.
Follow the Code
Know who to ask if you are unsure of the right thing to do
You are personally responsible for following the legal, professional and ethical standards
that apply to your role and level of responsibility. In order to help you to act with integrity at
all times, you should:
Stay Informed: You are expected to be familiar with applicable law, regulation and/or relevant
professional standards that apply to your specific job and level of responsibility. This includes
participating in appropriate training sessions, taking the time to read communications, seeking
further information through Jumeirah resources and consulting with others when necessary.
Stand Firm: No matter how strong the pressure from internal or external sources to perform
and meet goals, you should never compromise Jumeirah’s values or standards to meet those
goals.
Take Ownership: Our reputation for integrity can be damaged by anyone. This means that you
should incorporate the principles of this Code into your daily activities and act with care and
diligence. Adherence to this Code is endorsed and monitored by management.
Surface the Issues: Speak up if something does not seem right. Direct your concerns to the
appropriate resource and offer suggestions for improvement.
Consult with Others: There are numerous resources to answer questions in relation to policies
and ethical issues.
2 OUR COLLEAGUES JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS
Page 12 of 36
Get help if you need it
Speak up if you have a concern
Be a positive role model: Demonstrate to your colleagues what it means to act with integrity.
Ensure that others have the knowledge, resources and appropriate authority that they need
to adhere to Jumeirah’s standards.
Set clear, measurable and challenging goals that promote ethical behaviour.
Enforce Jumeirah’s standards consistently and fairly and promote compliance with those you
lead.
Respond appropriately to those who raise questions and concerns in good faith.
With respect to integrity, be prepared to be held personally accountable for your own
shortcomings as well as those of the people you lead.
Ensure that personal business dealings or those of immediate family members are not put
ahead of the best interests of Jumeirah.
Raise any potential conflicts of interest related to specific transactions or business operations
with senior management as soon as a potential conflict of interest arises.
Ensure that all work processes and procedures are in place to encourage adherence to this
Code.
2.2 CREATING EQUAL EMPLOYMENT OPPORTUNITIES Page 13 of 36

At Jumeirah we treat all colleagues equally and with dignity. We are proud of our diverse and
international workforce, which consists of over 13,500 colleagues from over 100 different countries. YOU MUST YOU MUST NOT
Our colleagues are encouraged to value each other and to maintain an environment that is inclusive
and supports individual differences.
We strive to act in a socially responsible way in the communities where we live and work. We comply Recruit, select, and promote Make decisions that negatively
with all applicable laws, regulations and relevant professional standards. colleagues solely on their impact our colleagues, based on
suitability for the job (eg ability and anything other than merit and ability.
Our colleagues are recruited, selected, developed and promoted based on merit and ability, qualifications) and fit within the
irrespective of age, gender, colour, national origin, ethnicity, religion, disability, family status, sexual Refuse to work with a colleague
company culture.
orientation or other characteristics protected by law. because of religious, racial, gender or
Ensure opportunities are given on an other differences.
equal basis.
Value colleagues as unique
individuals, with different
perspectives, and background.

Recently, there was an opening for a Team Leader role in the restaurant
where I work. The job advert states that the ideal candidate will be aged
21–30. I do not think this is fair but I’m not sure what I should do.
You have a valid concern, which you should address with your line manager
or Human Resources department. We hire, select and promote solely on
suitability for the job.
I am a Housekeeping Manager. One of our attendants has a strong accent.
Most team members refuse to be scheduled on the same shift with this
colleague as they find her accent difficult to understand. She has complained
that she feels isolated. Is she over-reacting?
At Jumeirah, we value individual differences and promote inclusiveness. If
her strong accent affects the guest experience and communication with
other colleagues, you should help her to seek assistance from the Learning
and Development team. It is not our culture to isolate others. Refusing to
work with another colleague due to discrimination is unacceptable.

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2.3 PROVIDING A SAFE AND HEALTHY WORKPLACE Page 14 of 36

Jumeirah is committed to providing a safe environment for all our stakeholders including guests, colleagues and business associates. We employ competent people, provide training and a solid infrastructure
to ensure that we operate in a safe and responsible way.
We embrace all applicable Health, Safety and Environment (“HSE”) laws and regulations and have appropriate company standards in place.
Jumeirah encourages colleagues to have both healthy minds and healthy bodies and participate in activities and events that are regularly promoted across the organisation.

YOU MUST YOU MUST NOT

Complete all relevant safety training for your role.
Familiarise yourself and follow all HSE laws, regulations,
standards, policies and procedures applicable to your
job.
Consider the impact of your actions or the actions of
others on the environment around you.
Ensure you are familiar with and follow crisis and
emergency procedures.
Ensure you handle and dispose of hazardous materials
properly and safely, as your role requires.
Promote a safety culture and encourage colleagues to
do the same.
Alert your line manager and follow Jumeirah
procedures for making a report on any hazardous or
unsafe situation, injury, near miss or breach of HSE laws
and requirements.
Work when you are medically unfit.
Report to work when your performance could be impaired
by alcohol, drugs or other substances.
Undertake work for which you are not competent or
properly trained.
Block fire or emergency exits.
Operate equipment you know is damaged or unsafe.

I work in the kitchen and I noticed that the plug on one of the ovens is faulty I had minor back surgery and my doctor told me not to operate any
and some wires are frayed. I know this could be dangerous, so I tried to fix the machinery for four weeks. I am worried I will lose my job, so I didn’t tell my
plug myself, but I got a small electric shock. What did I do wrong? manager and worked as normal as a duty driver.

If you notice something like this, please contact someone qualified or your
line manager. You attempted to fix this problem yourself when you should
have called an engineer who is appropriately trained. You could have been
seriously hurt or worse and we have specialist engineers who are qualified
for this work.
You must inform your line manager of your issue and follow the medical
practitioner’s instructions. This can help prevent future accidents. You
should also check your sick leave entitlement with your Human Resources
department.

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2.4 ENSURING A RESPECTFUL AND HARASSMENT-FREE WORKPLACE Page 15 of 36

At Jumeirah, our Hallmarks and Guiding Principles set the precedent for our behaviour. We treat each other with respect and integrity and our performance is better when we work together, as one team.
Colleagues are entitled to work in an environment which is free from harassment, bullying, intimidation and abuse. Jumeirah will not tolerate any behaviour, communication or conduct that creates a hostile
work environment.
All colleagues are responsible for ensuring that their conduct fosters a positive, professional and respectful work environment, free from harassment.

YOU MUST YOU MUST NOT

Treat your colleagues with respect and
integrity.
Speak out regarding instances of harassment
or bullying and report them to your line
manager or Human Resources manager.
Use bad language, make remarks or gestures which could be
considered intimidating, offensive, malicious or discriminatory.
Use social media or any other means of communication to
humiliate, threaten or abuse others.
Make verbal or practical jokes that embarrass or insult others.
Engage in harassment, unwelcome advances, inappropriate
physical contact, request sexual favours, or make unwelcome
suggestions with a colleague, guest or business associate.
Use Jumeirah property, computers or other equipment to obtain
or view pornographic, racist, sexist or other offensive material.

EXAMPLES OF
HARASSMENT

Verbal
Insulting or inappropriate jokes.
Commenting about a person’s appearance.
Making sexually demeaning remarks.
Non-Verbal
Staring or making offensive gestures.
Displaying suggestive or degrading images.
Giving sexually suggestive “gifts”.
Physical
Inappropriate touching, hugging, kissing or
patting.
Brushing against a person’s body.
Blocking a person’s movement.
My colleagues often make jokes about my weight. They make me
feel very embarrassed and insecure. I told them that I do not like
the jokes, but they think I’m over-reacting. What advice can you
give me?
You are not over-reacting. Your colleagues are making unwelcome
jokes that create a hostile work environment for you. You should
speak to your line manager or Human Resources to address
your concern. They will help your colleagues understand our
commitment to a harassment-free work environment in a
manner that will not affect your relationship with them.
During our briefings, our supervisor openly criticises one
colleague in particular. He often raises his voice and makes
comments that are personal leaving the colleague feeling upset. I
feel uncomfortable when it happens but do not want to challenge
the supervisor in case he starts bullying me. What should I do?
Our colleagues should be treated with respect and integrity.
Constant criticism can also be a form of bullying. If you suspect that
your colleague is the subject of bullying, you should either speak
with your supervisor, or if you do not feel comfortable doing so,
speak to his line manager or Human Resources about how you are
feeling.
My manager has asked me out on a date; I am not interested and
have refused once before. She keeps asking me to come to her
office for meetings, but often ends up asking me very personal
questions. I feel uncomfortable and I don’t know what to do.
This is a form of harassment as your manager has made you
feel uncomfortable through unwelcome advances. Harassment
usually occurs in private and may get worse if unreported. You
should get help from your Human Resources Manager.

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3 OUR
INTEGRITY
3.1 COMPETING FAIRLY Page 17 of 36

At Jumeirah, we take pride in our ability to compete on the basis of our superior level of innovative service and luxury. We embrace open competition and do not pursue unfair competitive advantage.
Competition and anti-trust laws are complex, have global reach and are designed to ensure that competition remains vigorous and free from collusion. These laws regulate the behaviour of companies and
help to prevent transactions which would substantially reduce competition.
Failure to comply with competition law can lead to significant monetary and criminal penalties as well as damage to a company’s reputation.

YOU MUST YOU MUST NOT

Ensure, where your role requires it, that you are familiar
with applicable competition law.
Obtain any competitor information legally and fairly.
Ensure any advertising is fair, accurate and lawful.
Report any attempt by a competitor to violate
competition law.
Collude with our competition. Enter into agreements with competitors to allocate
markets, lower, raise or stabilise prices, or otherwise restrict
Propose or enter into any formal or informal agreement
competition.
with a competitor regarding any aspect of competition.
Enter into agreements that restrict a guest’s choice in using
Share non-public, price or occupancy related information.
a Jumeirah service.
Enter into agreements with suppliers or customers that
Offer prices to certain guests that are not supported by
restrict competition.
legitimate business conditions.

EXAMPLES OF
ANTI-COMPETITIVE CONDUCT

My friend works for another high profile hospitality brand

Examples of anti-competitive conduct include price
in the same city. We both look after room rates at our hotels
WHAT IS COLLUSION? fixing, colluding with another company to refuse to deal
and the global economic crisis is impacting occupancy
with a supplier, exchanging company information with
and room rates. Can I call him to agree that we keep our
competitors, and dividing up guests.
prices the same so that neither of us suffer in these difficult
market conditions?
No. It is illegal to collude with a competitor regarding pricing
Collusion is a secret agreement or of any services or products. This would violate competition
cooperation, especially for fraudulent, law and could lead to prosecution and penalties. Please do
illegal or deceitful purposes. not discuss room and occupancy rates with any competitor
For more information, please refer to our Competition and
as sharing this information is also illegal.
Anti-Trust Law Compliance policy

3 OUR INTEGRITY JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS

3.2 MANAGING CONFLICTS OF INTEREST Page 18 of 36

A conflict of interest arises when your personal interests interfere or conflict with your duty to Jumeirah. Business decisions must be made in the best interests of Jumeirah and not motivated by your personal
interests or relationships.
Decisions that are not made objectively can hurt our business and reputation even when no wrong doing is intended. Even the appearance of a conflict can be damaging.
Jumeirah expects colleagues and business associates to disclose any conflicts of interest immediately so they can be managed properly and fairly. You have an obligation to disclose all outside activities,
financial interests or relationships that you have, which could present or appear to present a conflict of interest. This obligation also applies to disclosing any conflicts of interest regarding your family members
or other persons with whom you have a close personal relationship.

YOU MUST YOU MUST NOT

Always act in the best interests of Jumeirah and
wherever possible avoid any conflict of interest.
Watch out for a possible or actual conflict of interest and
notify your line manager.
Seek agreement or approval from your line manager
as to how the conflict will be managed or resolved.
Many conflicts of interest can be resolved in a mutually
acceptable way, but they must be addressed.
Use the Declaration of Interest form in section 6.2 of this
Code to disclose any potential or perceived conflicts of
interest.
Update the information you have provided on the
Declaration of Interest form if there have been any
material changes.
Declare any financial investment or other interest in
a company that does business with or competes with
Jumeirah.
Hire, promote, directly supervise or make other
employment or compensation decisions about a family
member or someone with whom you have a close
personal relationship.
Take outside employment or activities that may interfere
with your work at Jumeirah.
Use Jumeirah’s time or resources for matters that do not
relate to your role or benefit the company.

A conflict of interest in business usually refers to a situation in which an individual’s personal interests conflict with the professional interests owed to his employer. For example, a conflict of interest
arises if a colleague chooses personal gain over their duties to Jumeirah.

You are a manager and one of your direct reports has just resigned. Your sister-
in-law is well qualified and is looking for a new opportunity in the hospitality
industry. You hire your sister-in-law as a direct report without disclosing the
conflict of interest and consulting your supervisor. Am I permitted to do this?
You are not permitted to hire or directly supervise a family member. Immediate
family members include spouses/domestic partners, parents (as well as the
parents of spouses/domestic partners), siblings, children and in-laws. Your
sister-in-law can apply for other jobs within Jumeirah.
My father has a kitchen equipment company which supplies hotels around
the world. I know the hotel is looking for a new supplier and that my father’s
company would be a good choice. Can I recommend him to the hotel?
You can recommend your father’s business but you should be transparent and
disclose your relationship. Ensure you are not involved in any negotiations or
have any part in the ongoing management of the relationship if your father’s
company is hired. This will ensure you avoid any conflict of interest.

3 OUR INTEGRITY JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS

3.3 GIVING AND RECEIVING GIF TS AND ENTERTAINMENT Page 19 of 36

Our business is built on hospitality. Giving and receiving gifts and business entertainment is generally acceptable if they are infrequent, modest in value and contribute to good business relationships. You need
to exercise caution in giving and receiving gifts and business entertainment because they should not influence, or be perceived to influence transactions or company decisions.
At Jumeirah we strive to ensure that all gifts and entertainment are appropriate and within acceptable limits. If we cross this line, our integrity may be compromised and it could suggest that business dealings
are not above board.
If you would be embarrassed to talk about a gift or business entertainment then it is probably not acceptable to offer or receive it.

YOU MUST YOU MUST NOT

Follow the Gifts and Hospitality Policy and the approval
matrix.
Accurately record and register all gifts and business
entertainment given or received over the stated
thresholds.
Check the gift is appropriate and consistent with local
laws and customs.
Offer or accept a gift or entertainment from a government
official as this may constitute a criminal offence.
Receive hospitality or a gift from a third party participating
in an active tender for company business.
Engage in inappropriate business entertainment.
Accept discounts or payments from suppliers, guests or
competitors that the public or other colleagues do not
receive.
Ask for a tip from guests or make a gesture asking for a
guest to make a tip.

Ask yourself the following questions when giving or receiving a gift or entertainment:
1. WHY are you giving or receiving this gift or business 3. Could its TIMING be perceived to be capable of
entertainment? influencing business decision making?
For more information please refer to our Gifts and
2. Is this gift of hospitality PROPORTIONATE in the 4. Is there TRANSPARENCY around its giving or receipt?
context of its offering? Hospitality policy

I was tipped AED 1000 by a very wealthy guest. I want to keep the money
because I worked hard and feel I deserve it. Is this ok?
You must follow the Gifts and Hospitality Policy and the approval matrix which
explains the process and limits for giving and receiving gifts. Please refer to this
and for further clarification contact your Human Resources manager.
I had a meeting with an important supplier with whom we need to maintain a
good relationship. I want to offer them a complimentary hotel stay in order to
secure the deal. Is this ok?
No. This is a form of bribery and you should not influence decisions through
offering gifts and hospitality. If in doubt, speak with your line manager, and
please refer to the Gifts and Hospitality policy and approval matrix, to identify
what options are available to you for managing this business deal in a more
appropriate way.

3 OUR INTEGRITY JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS

3.4 PREVENTING BRIBERY, CORRUPTION AND FRAUD Page 20 of 36

At Jumeirah, one of our Guiding Principles is to act with honesty and sincerity in everything we do. This means doing business with integrity.
We are committed to conducting our business in compliance with all laws and regulations prohibiting bribery, fraud and other corrupt practices.

YOU MUST YOU MUST NOT

Use and encourage others to use Careline or ethicsline
as appropriate, to report any suspicions of bribery,
corruption or fraud.
Contact your line manager if you are offered a bribe or
what you think might be a bribe.
Commit any acts of theft, embezzlement or fraud.
Offer, make or accept a bribe, unlawful payment or
facilitation payment to anyone, even if such payments are
nominal in amount.
Engage in any form of corrupt behaviour.
Request consultants or other service providers to make
corrupt payments on behalf of Jumeirah.
Investigate unusual matters yourself.

I’m choosing a new supplier for our hotel’s heating system.
I received a phone call from a potential supplier who
WHAT IS A BRIBE? offered me money to tell him about the proposals that
other suppliers have submitted. What should I do?
You should not accept the payment as it is not permitted
under Jumeirah policy and UK anti-bribery laws. You
A bribe is money, gift or favour given should report the attempted bribe to your line manager
or promised in order to influence the and to Careline.
judgment or conduct of a person in a
position of trust.
I want to take my friends to use the beach facilities at one
of our hotels. I am not entitled to use them, but I know the
security guard on the gate who will let me in. Every now
and again this is ok, right?
No. It is not acceptable to gain access to facilities to which
you are not entitled because of personal relationships,
bribery or through any other means.

3 OUR INTEGRITY JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS

3.5 POLITICAL ACTIVITY Page 21 of 36

You have the right and are encouraged to hold your own political views and opinions. However, your participation in any political activities or process must be done voluntarily and in your own time.
Jumeirah as a company does not hold any political opinions and does not make any political contributions whether in cash or kind, anywhere in the world. As such you are not permitted to engage in any
political activities on Jumeirah’s behalf.

YOU MUST YOU MUST NOT

Ensure it is clear that your political activities and
opinions are yours and not those of Jumeirah.
Respect the political views of others at all times.
Direct any politically motivated questions to the
Corporate Communications department.
Make payments to any political party or candidate on Ask colleagues, guests or suppliers to make contributions
behalf of Jumeirah. or support any political party or candidate.
Lobby on behalf of Jumeirah. Make use of any Jumeirah property, services or
equipment to support any political party, initiative or
candidate.

One of my relatives is running for a post in the local government elections. Am I allowed to give I am an active member and supporter of a political party and spend my free time working with
flyers and promotional material to my friends and colleagues in the staff cafeteria? them on a voluntary basis. Is this ok?
No. You are not allowed to undertake any form of promotion of any political party or candidate Yes. You can take part in political activities as long as it is on a voluntary basis and you represent
on Jumeirah property. your own views and not those of Jumeirah.

3 OUR INTEGRITY JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS

3.6 PREVENTING INSIDER TRADING Page 22 of 36

Whilst working with Jumeirah, you may learn of material information about Jumeirah or other Material non-public information may include:
companies before it is made public. This information could be communicated to you directly or Key financial metrics
indirectly, for example, you may overhear it in a hallway, elevator or other public space.
Information communicated to you in morning briefings
Using material, non-public information for your benefit or communicating this information to
Significant contracts or other changes in Jumeirah and/or Dubai Holding assets
others violates this Code and may be illegal. This includes buying or selling shares of any company
about which you have material non-public information, and giving this information to anyone else Changes to brands, products or business plans
who might make trading decisions based on it. This is called insider trading and it is illegal. Financing or other significant transactions involving corporate debt
Changes in management control in Jumeirah and/or Dubai Holding
Legal or regulatory matters

YOU MUST YOU MUST NOT

Speak up in the event of an unintentional
disclosure of material non-public
information.
Check with your line manager if you are
not sure whether information you have
learned is material or not.
Obtain written consent before disclosing
any material non-public information.
Maintain confidentiality of information
even after you stop working at Jumeirah.
Disclose to any other person or entity any
material information related to Jumeirah
and/or Dubai Holding and its entities.
Spread rumours about developments at WHAT IS INSIDER TRADING?
Jumeirah.
Buy or sell shares because you hear or learn
of information at work about a company
that you think will make its share price go Insider trading is the illegal practice of sharing
up or down once the information has been material non-public information or trading on the stock
publicly announced. exchange to one’s own advantage with knowledge of
Discuss confidential Jumeirah business with any such information.
family and friends.

I heard we are about to start partnering with a prominent jewellery brand. I
told my friend as he has shares in that company and their value will probably
increase. Is this ok?
No. This is inside information and must not be shared. It is illegal and could
result in legal prosecution. If you learn of information through your job at
Jumeirah, you must not share it until it is public.
I was on a train when I overheard an executive discussing a joint venture
between two companies. I would make a lot of money if I bought shares in
these companies. Is that ok?
No. Using non-public information you overhear that could impact the price
of shares, is illegal. You could go to prison. You should not use or share this
information.

3 OUR INTEGRITY JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS

4 OUR
GUESTS AND ASSETS
4.1 LOOKING AF TER OUR GUESTS Page 24 of 36

We are successful only if we respond to our guests needs with ultimate professionalism and provide guests with an experience that is imaginative and exhilarating, culturally connected, and thoughtful and
generous. Through heart touching initiatives we work to exceed their expectations in every way and to ensure our relationship with them is based on mutual respect and integrity.
We want our guests to be loyal to us and understand that this loyalty could be threatened by any perception of dishonesty or disrespect.

YOU MUST YOU MUST NOT

Accommodate a guest’s legitimate requests
irrespective of their age, gender, colour, ethnicity,
religion, disability, or other characteristics.
Handle any unreasonable or unethical guest request
in a firm and professional manner.
Enable our guests to discover and enjoy unique cultural
experiences in the host destination.
Speak truthfully about our products, prices, service and
contractual terms and conditions.
Double check if you are unsure of a guest request.
Make racist, sexual or ethnic comments, jokes or gestures
towards guests.
Make or accept sexual advances to or from a guest.
Discriminate against any guest.
Act in an intimidating, insulting or malicious manner
towards guests.

A guest asked me to show his friends to
his suite without showing their ID, when
they arrive at the hotel. What should I
do?
You should politely inform the guest that
they must register all visitors at the front
desk, prior to them going to the room
for safety and security purposes. The
number of guests must be within hotel
policy limits.
I work in the Front Office department
and sometimes get invited by hotel
guests for drinks after work. May I accept
their invitation?
For more information please refer to our
Whilst we aim to build strong rapport Notification of Legal Claims and Commencing
with our guests, we need to keep the and Defending a Claim policy
relationship professional. You should
politely explain to the guests that it is
not our company policy to socialise
with guests after work hours. If the guest
insists, consult with your line manager.
They will be able to advise you on a
course of action.

4 OUR GUESTS AND ASSETS JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS
4.2 RESPECTING GUEST AND COLLEAGUE PRIVACY Page 25 of 36

We have access and are privy to confidential information relating to our guests, our colleagues, our business associates and anyone who does business with us. We must protect personal information that we
are entrusted with, during the course of our work and ensure all data is kept secure and private.
We are committed to complying with all applicable data privacy laws regulating the collection and use of personal data (such as names, contact information and other data that could identify a person) that
we hold in any of our systems.
As part of the service we provide our guests, we are trusted to ensure that both their security and their right to privacy are not compromised.

YOU MUST YOU MUST NOT

Keep guests’, colleagues’ and other personal data
secure and confidential.
Only use personal data for the purpose for which it was
collected.
Destroy all copies of documents with guest data that
you may have, when they are no longer required.
Limit access to personal information to those who are
authorised and have a business need for the data.
Comply with Jumeirah’s Data Protection Policy.
Maintain confidentiality of information, even after you
stop working for Jumeirah.
Comply with all local data privacy laws and company
policies.
Only transfer personal data between countries in
compliance with applicable legal, regulatory or
procedural requirements.
Share confidential data or information with anyone
unless you are required by law and have received prior
authorisation from your manager.
Request access or retain data if you are not authorised.
Hold personal information for longer than permitted
under local data privacy laws.
Re-use paper that contains guest, colleague or other
personal data.

Recently, a world famous celebrity stayed
at our property. My friend knew that I
worked as a butler and suggested that I
should post a photo of the celebrity on my
personal Facebook page. Is this allowed?
No, that would violate our guests’ privacy.
The fact that the celebrity was staying
with us should also be protected and not
shared publicly.
Can I forward or share guest credit card/
passport/driver’s license information or
other sensitive information via email?
No. Protection of customer personal
information and guest data is of
paramount importance and should never
be disclosed. The privacy statement on
our website provides information on how
we manage personal data.
I was working at reception when a guest
approached me and asked me for the
room number of another guest. I think
they are friends. Am I allowed to give out
their room number?
For more information please
No. We never share the room numbers of refer to our Social Media policy
our guests. You may call the guest directly
and let them know that their friend is
enquiring about them. You can pass the
phone over for the guests to handle their
own confidential information.

4 OUR GUESTS AND ASSETS JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS
4.3 SAFEGUARDING OUR ASSETS AND MANAGING Page 26 of 36
CONFIDENTIAL INFORMATION

Jumeirah’s business information is one of our most valuable assets. We trust you to keep confidential all non-public information relating to Jumeirah, guests, owners and business associates.
All our colleagues and business associates are responsible for safeguarding Jumeirah assets to ensure they are only used for business purposes and incidental personal use, and not abused or wasted.
Assets include buildings, vehicles, equipment, materials and company funds, as well as intangible assets such as company information, employee time and Jumeirah’s brands and trademarks.

YOU MUST YOU MUST NOT

Maintain all physical assets and ensure they are
protected and used efficiently.
Watch out for inappropriate use or theft of intellectual
property, such as patents, copyrights or trade secrets.
Follow Jumeirah policies, applicable laws and
regulations regarding both physical and intellectual
property.
Adhere to requirements around securing Jumeirah’s
guest and third party data (including third party hotel
owners and business associates).
Use Jumeirah assets, data or information for personal gain.
Access chatrooms or download unlicensed software on
your work computer.
Use work email to send offensive messages.
Disclose any sensitive data or confidential information,
even after leaving Jumeirah.

I heard that we are looking to expand to a new country.
I’m so excited because my family is from there. Can I call
to tell them?
No. Development and expansion discussions are
strictly confidential and often change. Please do not
communicate to anyone regarding our expansion plans
until they have been formally communicated to the
media.
Can I share my system password or access card with one
of my associates?
No. Passwords and Jumeirah access cards should never
be shared and this would violate the Jumeirah IT Security
For more information please refer to our
Policy. Jumeirah IT Security policy
I am hiring a consultant for some design work at one of
our properties. Do I need to worry about intellectual
property?
Yes. It is important that the written agreement states that
Jumeirah will own the rights to any intellectual property
created by the external consultant.

4 OUR GUESTS AND ASSETS JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS
4.4 COMMUNICATING WITH THE MEDIA AND ONLINE Page 27 of 36

Our reputation depends on our integrity and honesty. We strive to ensure all our communications are accurate and truthful. Everything we publish must be carefully checked to ensure that it is correct to the
best of our knowledge.
We are responsible for what we say and how it comes across. As our brand representatives, how you conduct yourself can positively or negatively affect the image of Jumeirah. Please consider this when
communicating about anything to do with the company in person or online.
To ensure confidential information is not disclosed inappropriately, only people designated by Jumeirah may speak to media representatives on behalf of the company or share information about Jumeirah
on social media or through any other electronic communication.

YOU MUST YOU MUST NOT

Make sure you comply with our social media policy. Get authorisation from the Corporate Represent Jumeirah with the media, on social media or in
Communications department before sharing online conversations, without the written consent of the
Only share information you know to be correct,
information regarding Jumeirah’s performance, plans, or Corporate Communications department.
complete and truthful.
any of our marketing and sales activities.
Discuss or share confidential company or guest
Be careful with what you discuss, forward or put
information with friends, relatives or on social media.
in writing regarding Jumeirah. It may result in legal
consequences or cause reputational issues.

A local media representative asked to interview me
about Jumeirah’s competitive information including
pricing, occupancy rates and strategy. Can I share this
information?
No. You should refer the media representative to
Jumeirah Corporate Communications who will deal
with the query.
I stayed at a Jumeirah property over the weekend on the
colleague rate. Although I have previously experienced
great service at this hotel, this time I was disappointed
with some of the service. Although I work for the
company, I’m still a paying customer and want to write For more information please refer to our Social
about my experience on Facebook. Media policy
Please do not do this. You are a brand representative
of Jumeirah and comments made on social media can
damage our reputation. If you have any comments or
suggestions about the service, please contact the Hotel
Manager or an appropriate colleague within the property
and give them your feedback.

4 OUR GUESTS AND ASSETS JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS
4.5 KEEPING ACCURATE AND COMPLETE RECORDS, Page 28 of 36
REPORTS AND DOCUMENTS

We must ensure our recording and reporting of all information is honest and accurate. This is critical to our shareholders, owners and management. It is also fundamental to ensuring high standards of
corporate governance and for upholding our legal and regulatory responsibilities.
We rely on both our financial and non-financial information to make responsible business decisions. We depend on the accuracy of our accounting records so we can produce objective reports for our
management team, owners, government agencies, creditors and others.
False, incomplete, inaccurate or misleading information may result in serious legal risk for colleagues, business associates and Jumeirah.

YOU MUST YOU MUST NOT

Provide current, complete and accurate information to
all concerned government agencies.
Co-operate with internal, external and government
auditors.
Ensure all business activities are appropriately
authorised and accurately and fully recorded.
Record data accurately and in a timely manner. Falsify any financial or non-financial record or create or use
misleading information in any situation.
Ensure judgments and accounting estimates are
reasonable and prudent. Destroy any document (including electronic files) other
than in accordance with our Record Management policy.
Comply with internal policies and applicable external
requirements regarding reporting information.

You have been asked to change an
email address for a guest in the Property
Management System as your manager
expects they will give a negative review for
their stay. Is this ok?
No. You must never alter records with
misleading information.
I was submitting an expense claim, but I My friend was running late and she asked
lost some of the receipts. I made a guess me to swipe in for her so that she wouldn’t
about the approximate amount and get in trouble. Is this ok?
submitted the form including it. Is this ok?
No. This is a type of fraud and you must
No. You must keep all receipts for any not swipe in for anybody else. In addition, For more information please
claims you make. We keep an accurate it’s important that we keep an accurate refer to our Record Management
accounting record of all of our financial record of colleagues’ working hours. policy
transactions and must have receipts to
back these up. You will not be refunded
against things for which you do not have
a receipt.

4 OUR GUESTS AND ASSETS JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS
5 OUR
COMMUNITY AND ENVIRONMENT
5.1 MANAGING SUSTAINABLE OPERATIONS Page 30 of 36

Jumeirah endeavours to conserve and protect its ecological surroundings by committing to operate sustainably and responsibly.
Through our respect for the local environment and our ongoing process of sustainable growth, we seek out innovative solutions to reduce the amount of waste and consumption and we recycle and reuse
materials to minimise environmental impact. We actively participate in projects that support and protect our environment, such as beach clean-ups and turtle rehabilitation (see also section 5.2 of this Code,
Engaging with our Community) and encourage our colleagues to take a part in our contribution to preserve the natural environment.

YOU MUST YOU MUST NOT

Consider the impact of your actions and the actions of
others, on the environment.
Work in a way that is environmentally responsible
without compromising Jumeirah’s standards.
Be vigilant and notify your line manager of any activities
or issues that could damage the environment.
Strive to reduce waste, recycle and promote efficiency. Disregard environmental regulations and procedures.
Encourage environmentally innovative solutions to do Be deliberately wasteful.
things in a more efficient and productive way.
Identify and support local initiatives which promote
sustainability and protect the environment.

At Jumeirah we are committed to making positive

contributions to people and planet.

My colleagues always leave their lights and monitors My shift is over and one of the jet skis is leaking oil. Can I
switched on when they finish work. Should we turn them just leave it until tomorrow and I can report it then?
off?
No. You should report the leak to your line manager
Yes. It’s important to conserve energy and not be wasteful. immediately so that the jet ski can be fixed as soon as
One of our highest costs is energy consumption. Actions possible to protect the local environment.
that are perceived as small have a direct impact on our
ability to maintain our Green Globe status and to reduce
our impact on the environment.

5 OUR COMMUNITY AND ENVIRONMENT JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS
5.2 ENGAGING WITH OUR COMMUNITY Page 31 of 36

Each one of our hotels plays an important role in its local community. We recognise our responsibility to create shared value and make every effort to respect and to have a positive impact on the communities
within which we operate. We appreciate the importance of local communities and recognise they are a source of our talented colleagues and esteemed guests.
Through our STAY DIFFERENT brand promise, we work hard to ensure our guests enjoy exhilarating and unique experiences, enriched with the culture of the local destination. Jumeirah encourages
TM

colleagues to volunteer and participate in support of local community initiatives, including education, health and protection of wildlife and the environment.

YOU MUST YOU MUST NOT

Support and care for the local communities, especially in times of natural disaster. Disregard community concerns of which you become aware.
Respect the customs and culture of the local community, except for when they conflict Donate to charitable organisations on behalf of Jumeirah without prior authorisation.
with this Code.
Get involved in practices that might be unlawful and that might harm the environment.
Preserve the natural surroundings and ensure the unique travel experiences are protected
for our guests.

My daughter’s school is holding a charity event next week. Can I make a donation on behalf of
Jumeirah and claim it back?
WHAT IS CORPORATE SOCIAL RESPONSIBILITY?
No. You should approach the Corporate Responsibility team to ask for support. Nothing
hinders you from making a contribution in your personal capacity.
I witnessed a guest dropping some rubbish into the turtle sanctuary lagoon. I know it’s wrong
to do this, but I didn’t want to say anything because I didn’t want them to complain.
It is your responsibility to try to protect our natural environment. Politely explain to the guests Corporate Social Responsibility (“CSR”) is a business approach
that the turtles are being rehabilitated and need to be cared for. Refer them to the signs placed that contributes to sustainable development by delivering
near the lagoon. Report the incident to your line manager so that they can ensure the rubbish economic, social and environmental benefits for all stakeholders.
is retrieved and doesn’t harm the turtles.
CSR is a concept with many definitions and practices and each
I want to get involved in CSR activities, but I don’t know how to go about this?
What should I do?
organisation identifies and establishes their own contribution to
Speak to the Corporate Responsibility team about some of the activities that are on-going
their environment and community.
within the properties. We have regular turtle releases, health and fitness campaigns and
education drives that all take place across the Group.

5 OUR COMMUNITY AND ENVIRONMENT JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS
5.3 SUPPORTING HUMAN RIGHTS Page 32 of 36

Jumeirah works to support and safeguard the fundamental human rights of our colleagues and guests Jumeirah strives to work with reputable business associates and other suppliers who commit to these
in every country and region in which we operate. We condemn all forms of slavery, forced labour, same principles. Jumeirah expects its business associates to ensure that their goods, materials and
human trafficking and the exploitation of children. labour-related supply chains are:
Jumeirah is committed to responsible workplace practices and compliance with the applicable laws compliant with applicable laws and regulations;
and regulations. transparent, accountable and auditable; and
free from ethical ambiguities.

YOU MUST YOU MUST NOT

Comply with the applicable laws and
regulations regarding human rights.
Report any suspicions of human
trafficking, or forced labour to your
manager, so that appropriate actions can
be taken.
Respect the lawful human rights of our
colleagues (eg freedom of association).
Comply with the provisions of your
employment contract and applicable
policies if you are a colleague.
Comply with the provisions of your
respective contracts with Jumeirah and
any Jumeirah policies incorporated by
reference in such contracts, if you are a
business associate.
Hire individuals who are under the
lawful age of employment.
Allow any of our properties and services
to be used in any manner that supports
or enables any form of forced labour,
human trafficking and the exploitation
of children.
Engage or endorse physical punishment
or abuse of our colleagues.
Set up a roster that requires colleagues
to work in shifts longer than the legal
maximum.

WHAT IS HUMAN WHAT IS FREEDOM

TRAFFICKING? OF ASSOCIATION?

Our hotel outsources the cleaning services. Some of the cleaning attendants look very young and I suspect Human trafficking is
that they are minors forced into the workplace. Their manager is very controlling and always stops me from organised criminal activity Freedom of association is
interacting with them directly. I am very concerned, but unsure what to do? in which human beings are the right to join or leave
We expect our business associates to uphold fundamental human rights. You should report your concern to treated as possessions to groups of a person’s own
your line manager or your Human Resources team. If we confirm that the outsourced company uses child be controlled or exploited, choosing, and for the
labour, we will need to terminate our contract with them and may need to report this to relevant authorities. most commonly for the group to take collective
I would like to participate in the Vegan Society which promotes the exclusion of exploitation and cruelty to purpose of sexual slavery action to pursue the
animals for food, clothing or other purposes. Do I need inform my line manager? or forced labour for the interests of members.
You have the right of freedom of association, as long as it is legal. You do not need to inform your manager, trafficker or others.
provided that you do not create an impression that you represent Jumeirah.

52. OUR
OURCOMMUNITY
COLLEAGUES AND ENVIRONMENT JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS
5.4 PARTNERING WITH JUMEIRAH Page 33 of 36

As a valued business associate of Jumeirah you are expected to familiarise yourself with this Code and reflect our values and culture in how you and your business/employer behave when dealing with
Jumeirah and its colleagues. You are responsible for ensuring that your conduct fosters a positive, professional and respectful relationship and work environment, and you can expect the same from Jumeirah.

YOU MUST YOU MUST NOT

Familiarise yourself with this Code.
Conduct yourself in a way that aligns with Jumeirah
values and culture.
Disclose any financial interests or relationships that
you have, which could present or appear to present a
conflict of interest.
Safeguard Jumeirah assets and ensure they are not Bully, harass or discriminate against our colleagues.
abused or wasted.
Share proprietary information that you learn through your
Maintain accurate and complete records to ensure all interaction with Jumeirah.
dealings with Jumeirah are accounted for.
Report unethical behaviour or anything you are
not comfortable with to your Jumeirah contact or
ethicsline@jumeirah.com.

Who do I contact if I have concerns?

As a business associate you can speak to your Jumeirah contact if you have any concerns about unethical behaviour or if you have any questions about this Code.
Should you want to report something confidentially you should email ethicsline@jumeirah.com

5 OUR COMMUNITY AND ENVIRONMENT JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS
6 DECLARATION OF INTEREST
6.1 DECLARATION OF INTEREST FORM Page 35 of 36

Jumeirah Group LLC, together with its subsidiaries and affiliates worldwide (“Jumeirah”) follows best international practice in relation to matters of corporate governance, one aspect of which is to ensure
that any conflicts of interest are declared.
All colleagues must declare any actual or potential conflicts of interest by completing the table and form below. Should any material changes occur you must submit an updated Declaration of Interest form,
including these changes.
Please note conflicts of interest include circumstances where a colleague has existing relationships whether personal (eg director, officer, partner, consultant) or through family members (spouse/domestic
partner, parents, children, siblings, in-laws) or close friends working with companies, corporations or firms that do or may do business with Jumeirah.
Conflicts of interest also include significant ownership, investment, financial or other, whether held directly or indirectly (eg through corporate arrangements) in companies, corporations or firms that are or
may become a business associate of Jumeirah.
For further explanation, please refer to section 3.2 of this Code, Managing Conflicts of Interest.

Name of Entity Position Held/Interest (please stipulate whether for yourself/family)

Date of Appointment or Interest Acquired Other Information (eg industry)

I certify to the best of my knowledge that I have disclosed to Jumeirah all relevant information relating to any actual or potential conflicts of interest and this information reflects the true position as at the date
of signature. I will submit an updated Declaration of Interest form if there has been a material change in any of this information.
The information will be held on the colleague’s employment file.

Date Business Unit

Name (print) Date of Joining
Job Title City and Country
Colleague Number
Grade Signature

6 DECLARATION OF INTEREST JUMEIRAH GROUP | CODE OF CONDUCT AND ETHICS

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