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900 - ACCESSIBILITY, SAFETY AND SECURITY

ACCESSIBILITY, SAFETY AND SECURITY


900-

900 - ACCESSIBILITY, SAFETY AND SECURITY

901.00 BUILDING CODE AND GOVERNMENT REGULATION.................................................................................................. 900-2


902.00 ACCESSIBILITY............................................................................................................................................................... 900-2
903.00 EMERGENCY RESPONSE AND CRISIS INCIDENT PLANNING ..................................................................................900-2
904.00 FIRE LIFE SAFETY.......................................................................................................................................................... 900-6
905.00 SKYLIGHT INSPECTION................................................................................................................................................. 900-7
906.00 SECURITY TEAM MEMBERS ......................................................................................................................................... 900-8
907.00 GUEST ROOM SECURITY.............................................................................................................................................. 900-8
908.00 MASTER KEY CONTROL................................................................................................................................................ 900-9
909.00 LOST AND FOUND.......................................................................................................................................................... 900-9
910.00 HOTEL ACCESS.............................................................................................................................................................. 900-9
911.00 INFORMATION PRIVACY AND DATA PROTECTION ..................................................................................................... 900-9
912.00 INSURANCE .................................................................................................................................................................. 900-15
913.00 NOT APPLICABLE TO THIS BRAND ............................................................................................................................ 900-21
914.00 RISK MITIGATION PLAN ............................................................................................................................................... 900-21

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901.00 BUILDING CODE AND GOVERNMENT REGULATION


The hotel, in all aspects of its facilities and operation, must comply with all applicable laws, codes, ordinances, and regulations.
902.00 ACCESSIBILITY
The hotel must meet all local disability requirements and any brand-specific requirements. Equipment/devices for travelers with disabilities must be available
as a loan item, and complimentary to the guest. All management-on-duty and front desk staff must be familiar with the location and operation of such
equipment/devices. A list of these items must be maintained at the front desk.
903.00 EMERGENCY RESPONSE AND CRISIS INCIDENT PLANNING
The hotel must have Emergency Response Plans and a Crisis Management Plan to address Threats and Crisis Incidents that may compromise life safety,
damage assets, harm reputation, and/or cause disruption to business operations. There is a distinct difference between Emergency Response Plans and a
Crisis Management Plan.
Emergency Response Plans provide specific guidance on how to address a variety of scenarios (see examples in Standard 903.01). Not all scenarios are
Crisis Incidents and taking quick action may help reduce the likelihood of one of these scenarios becoming a Crisis Incident. The Emergency Response Plan
minimum requirements are set forth in Standard 903.01.
A Crisis Management Plan is not scenario specific; however, it is intended to be used with the relevant Emergency Response Plans if the situation has
escalated to the level of a Crisis Incident. The Crisis Management Plan minimum requirements are set forth in Standard 903.02.
Further Definitions relevant to this Section 903:
An Operational Incident is a low-risk event that requires action as part of the normal course of business operations and does not require activation of the
hotel SCT or corporate crisis teams. An example of an Operational Incident is a leaking pipe in the hotel that causes minor damage that may require repairs
and/or insurance claims. Another example is a temporary power outage that does not result in significant business disruption.
A Threat is something that is likely to have a direct impact to the hotel, such as an approaching tropical storm that has not reached the property, spread of
pandemic flu that has not yet affected Team Members or guests, or nearby major events such as the Olympics or social unrest that may disrupt business
operations. Another example of a Threat is a risk to Hilton’s reputation due to a verbal altercation at the hotel that is recorded on a mobile device that may be
later posted on social media.
A Crisis Incident is an event that is currently happening or has happened with a direct/indirect impact to the hotel such as being in the direct path of a tropical
storm, an earthquake that causes on-property damage or injuries, cybersecurity attack, workplace violence or active attack. An example of an indirect Crisis
Incident is a terrorist attack occurring in the city where the hotel is located.
A Reputational Threat or Crisis Incident is one in which involves adverse Media (Press, Social Media or other public attention) that is likely to negatively affect
the opinion of the public with respect to the hotel, the brand or the company. An example of a Reputation Crisis Incident would be a guest posting a video of
an alleged discriminatory or biased interaction with a hotel team member that catches the attention of the Media. Please see REPUTATION RISK
MITIGATION (903.05).
903.01 EMERGENCY RESPONSE PLANS
The hotel must have written, hotel-specific Emergency Response Plans in place and provide ongoing training to address the response and management of
the below emergency situations which may have the potential of becoming Operational, Reputational or Crisis Incidents. All plans (or copies of the plan) at
the hotel must be consistent, updated annually, and easily accessible to all on-property Team Members.
The list below represents the minimum required topics in hotel Emergency Response Plans. Hotel management may include additional topics relevant to their
property.

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Emergency Response Plan Contents


• Emergency Contacts and Phone Numbers
• Emergency Notification
• Emergency Supply Inventory
Incidents/Threats, Emergency Scenarios and Information (ordered from “A” to “Z”):
• Active Attack / Shooting
• Media and External Inquiries
• Asbestos Disturbance / Release
• Body Fluid Spill
• Boiler Failure
• Bomb Threat and Search Procedures
• Chemical Spill
• Chemical, Biological, Radiological, and Nuclear Incident
• CPR Certified Team Members
• Criminal Activity
• Death / Suicide
• Death or Drowning
• Demonstration, Civil Unrest
• Riot, Protest
• Discrimination or Bias Claims
• Disorderly Behavior
• Electrical and Lighting Failure
• Elevator Failure or Entrapment
• Enforcement Officer Visit
• Eviction
• Fire Emergency or Explosion
• Fire Sprinkler Activation
• Fire System Impairment
• Foodborne Illness and Food Contamination
• Gas Release/Leaks
• Guest Illness
• Human Trafficking
• Infectious Diseases
• Legionella
• Pandemic Flu
• Norovirus

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• Natural Disasters and Other Weather Related Emergencies (NOTE:Hotels must have emergency response procedures that are relevant to their location.
For example, tropical storm procedures must be in place if the hotel is located in an area prone to hurricanes, cyclones, or typhoons. Other examples
include, but are not limited to earthquakes, tsunamis, wildfires, and tornadoes.)
• Overcrowding
• Panic Alarm Activation
• Pool Emergencies and Concerns
• Bodily Fluid Spill
• Broken Glass
• Chlorine Gas Escape at Pool
• Failed Water Samples (Spa/Pool)
• Structural Failure of Pool Hall Elements
• Water Clarity
• Robbery
• Serious Accident
• Sexual Assault or Rape
• Sprinkler Activation
• Telecom Failure
• Terrorism
• Theft of Guest Property
• Transportation Emergencies
• Water Failure or Contamination
The list above reflects the minimum requirements. Requirements as to communicating with Hilton are set forth in Standard 903.03 (REPORTING OF
THREATS AND CRISIS INCIDENTS USING HILTON ALERT (Standard 903.03).
NOTE: This Standard requires all franchised hotels to create such a Plan; however, the Franchisee is solely responsible for the content of the Plan (including
ensuring that the Plan is effective). Hilton will not review such Plan for adequacy.
903.02 CRISIS MANAGEMENT PLAN
The hotel must have a written hotel site Crisis Management Plan in place to manage and resolve major Threats and Crisis Incidents (including repairing any
reputational damage to the hotel and/or Hilton or our affiliates). All Plans (or copies of the Plans) at the hotel must be consistent, updated at least semi-
annually, and easily accessible to all on-property Team Members.
The Crisis Management Plan must include the following sections:
• Site Crisis Team (SCT): Identification of the members of the hotel SCT members, roles, responsibilities, escalation requirements, and reporting protocols
to the appropriate stakeholders. See REPORTING OF THREATS AND CRISIS INCIDENTS USING HILTON ALERT (Standard 903.03) for requirements
relating to Communicating with Hilton.
• Roles and Responsibilities: Guidance on the roles and responsibilities of each applicable person.
• Escalation and Reporting: Guidance for escalation and reporting consistent with this and other Hilton standards including the use of Hilton Alert. See
REPORTING OF THREATS AND CRISIS INCIDENTS USING HILTON ALERT (Standard 903.03).

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• Evacuation Information: Guidance and instructions on evacuation policies and procedures.


Hilton may provide additional guidance to franchised hotels on best practices to follow generally or in specific types of incidents. This guidance is a
suggestion and reflects best practices observed by our managed or other hotels.
NOTE: This Standard requires all franchised hotels to create such a Plan; however, the franchisee is solely responsible for the content of the Plan (including
ensuring that the Plan is effective). Hilton will not review such Plan for adequacy.
903.03 REPORTING OF THREATS AND CRISIS INCIDENTS USING HILTON ALERT
A member of the hotel SCT is required to immediately report Threats or emergency incidents to Hilton as set forth below.
Hilton Alert (powered by AlertSense) is Hilton’s crisis communications mobile application that must be used by hotel SCTs to report Threats and Crisis
Incidents.
All hotel Team Members that serve as part of the hotel SCT must have acquired a license to use and must be trained on the use of the Hilton Alert mobile
application. The hotel will appoint a team member who will be enabled to grant Hilton Alert licenses to other designated on property team members (using
either Fusion (Managed) or Identity Manager (Franchised). Each hotel must have a sufficient number of SCT members set up with Hilton Alert, depending
upon the hotel’s needs (e.g., size or complexity), with a minimum number of 3 SCT members. Hotels must also ensure that SCT members have the
appropriate hotel facility ID(s) linked to their Team Member profile in Identity Manager (IDM). These can be updated directly in IDM by the General Manager
or the hotel’s IDM supervisor (Managed hotels may also reach out to Human Resources for assistance). Visit Business Continuity & Crisis Management on
the Lobby to learn more about Hilton Alert and how to grant Hilton Alert access to hotel SCT members (www.hiltonalert.hilton.com).
Severity Assessment Questions
When faced with a Threat or Crisis Incident, the hotel must consider the following questions. If the answer is YES to at least one of the questions below the
SCT must report the situation to Hilton by using the Hilton Alert mobile application.
• Was there serious illness, injury, or suspicious loss of life?
• Was there significant property damage or loss?
• Was or could there be a significant business disruption?
• Was there a partial or full evacuation of the property?
• Were there or do you anticipate media inquiries or external interest including social media impact?
If the hotel is unable to access the Hilton Alert mobile application during a Threat or Crisis Incident, a member of the hotel SCT must report the situation to
Hilton using the most expeditious methods available, (e.g., the Hilton Crisis Hotline: +1 214-572-7474).
Note that if the SCT is unavailable to report immediately, the hotel must otherwise ensure immediate communication.
903.04 EXTERNAL COMMUNICATION
To protect the reputation of the property, brand and Hilton, hotels must take the following actions during a Crisis Incident or Threat.
• Identify a hotel spokesperson, and inform hotel Team Members that all inquiries and questions must be directed to this designated person.
• Obtain Hilton and Brand Public Relations approval on all press releases prior to distribution. All media interactions pertaining to Hilton’s and/or the hotel’s
position or response on an incident must be reviewed and approved by the appropriate Regional Communications contact. See the Comms Shop for more
guidance on how to deal with external communications and a list of approved Hilton contacts.
• Hire a reputable agency with experience in crisis management, to support the hotel with communications and remediation.
• Facilitate immediate and decisive de-escalation action to fully remedy the incidents with the individual or group.

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• Identify an owner and management company representative to be the single point of engagement throughout the process.
The Comms Shop
PATH: The Lobby > Departments > Corporate Affairs and Brand PR > The Comms Shop
903.05 REPUTATIONAL RISK MITIGATION
Hotels must ensure that hotel Team Members and SCTs are trained on Emergency Response Plans, Crisis Management Plans and Hilton Alert requirements
and procedures every 6 months.

904.00 FIRE LIFE SAFETY


Minimum standards for fire safety systems approval, testing, maintenance and training are detailed below. These minimum standards do not supersede more
stringent applicable laws. Refer to Brand’s Design, Construction and Renovation Standards for complete fire safety system requirements.
904.01 EMERGENCY LIGHTING
Emergency lighting must be provided in accordance with standards found in the Brand’s Design, Construction and Renovation Standards.
904.02 APPROVAL, TESTING, AND MAINTENANCE
Written approval of the plans for required fire safety systems must be obtained from the governmental authority having jurisdiction prior to installation of the
fire safety system. The form of written approval may vary by governmental authority. For the purposes of these Brand Standards, “written approval” is defined
as a certificate, letter of approval, permit, stamp of approval, or other approval method as used by the governmental authority.
Written certification that the required fire safety systems have been installed according to the approved plan by a licensed contractor and are fully operational,
tested and approved by the authority having jurisdiction must be obtained from the installation contractor.
All fire safety systems installed (including any systems installed above and beyond the requirements of this standard) must be tested and maintained either:
• Through a maintenance contract with an organization licensed to install and maintain such equipment, or by individuals trained to perform such inspection
maintenance and testing.
• Testing and maintenance of sprinkler systems must be in accordance with the stricter of the manufacturer’s instructions, NFPA 25, as otherwise specified
by the governmental authority having jurisdiction over the hotel, or as specified in the Brand’s Design, Construction and Renovation Standards.
• Testing and maintenance of smoke detection systems (or heat detection devices where appropriate) must be in accordance with the manufacturer’s
instructions, NFPA 72, or as otherwise specified by the governmental authority having jurisdiction over the hotel or as specified in Section 2516.00.
• A statement certifying that such testing and maintenance have been performed must be signed by either the maintenance company representative and by
the general manager of the hotel OR By the individual trained to perform such maintenance and testing and by the general manager of the hotel.
• All statements certifying such testing must be kept on file at the hotel and be made available to the Quality Assurance auditor upon request. Such testing
and maintenance must be performed at least once every six months. A minimum of one test per year must be conducted by an outside third party licensed
to test fire safety equipment. Guest room/suite smoke detectors must be included as part of this testing and documentation. Carbon Monoxide detectors, if
mandated in Design, Construction and Renovation Section 2516.00, must also be included as part of this testing and documentation.
NOTE: Refer to The Lobby for the complete list of testing and maintenance requirements by maintenance contractor and hotel personnel.
904.03 FIRE EXTINGUISHERS
Portable fire extinguishing equipment must be located throughout the hotel and/or in accordance with all local laws, whichever are more stringent.

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All portable fire extinguishing equipment must be tested and checked according to a scheduled plan and applicable law, and documented accordingly.
904.04 EMERGENCY SHUT-OFF
The hotel must post a detailed plan displaying the hotel layout and location of all working components of the hotel’s fire safety system and utility shutoffs (fire
pumps, sprinkler system, pull stations, alarm, electrical and gas).
The hotel layout with emergency procedures must be posted in the work area behind the front desk, maintenance and housekeeping, easily accessible to all
Team Members.
Photographs must be taken of the fire system and utility shutoff components and posted with the hotel layout denoting the location of that piece of equipment
to allow familiarization of the fire safety components by the team members.
904.05 TRAINING
The General Manager, Assistant Manager, all guest services (Front Desk) personnel, maintenance supervisors, housekeepers and night auditors as well as
any other personnel designated as “Managers-On-Duty” at the hotel must be familiar with the operation of the security, fire safety systems, fire evacuation
procedures and the operation of portable fire extinguishers.
All Team Members must comply with emergency training as specified in Section ##109.00##.
904.06 SELF AUDIT
The hotel must conduct a self-audit on safety and security issues biannually. Records of this audit must be kept on file for review by Hilton quality assurance
and safety & security auditors for a period of no less than 3 years.
904.07 FIRE DRILLS
Fire drills must be conducted twice a year to maintain the readiness of all Team Members. Documentation of each fire drill must be maintained for the current
calendar year plus the previous 6 years for Quality Assurance and Safety & Security to review.
904.08 FIRST AID KITS
Fully-stocked first-aid kits must be available at the front desk area, kitchen/pantry area, housekeeping area and maintenance area, and any other areas
required by applicable law. Contact regional Safety & Security/Hilton Supply Management for a complete listing of approved medical supplies.

905.00 SKYLIGHT INSPECTION


If the hotel or ancillary buildings have skylights, they must include the following provisions:
• Skylights that are not of load bearing construction must have signage to indicate “fragile surface” and signage must be displayed in line with internationally
recognized or local signage regulations.
• Skylights that can be opened must have opening mechanisms positioned to prevent falls from height during opening and closing operations. Alternatively
provisions must be made to ensure compatibility with fall restraint systems.
• The positioning of skylights must allow safe access for cleaning and maintenance purposes or provision must be made to ensure compatibility with fall
restraint systems.
• Skylights located on or near pedestrian routes (including for servicing and maintenance purposes) must be adequately protected by the provision of
guardrails around skylights or dedicated skylight protection systems.
• If required by local law, skylights must be inspected in line with local codes and inspection certificates retained for review.

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• New construction hotels must retain the warranty certification for the original installation.
906.00 SECURITY TEAM MEMBERS
Security guards, whether on staff or contracted, must not be armed while on the hotel’s premises.
907.00 GUEST ROOM SECURITY
907.01 ENTRY DOOR
All guest room entry doors must be equipped with the following:
907.01.A ENTRY DOOR LOCKS
Fastened with an adhesive, door guard (swing) lock installed with tamper-proof screws and mortise lock set with a 3/4″ latch, one-inch throw dead bolt,
anti-celluloid feature and panic release;
907.01.B DOOR VIEWER
180-degree door viewer installed at 54-60 inches above the finished floor, and an additional viewer at 46 inches above the finished floor for accessible
guest rooms.
Upon replacement of the guest room door or viewer, the hotel must comply with the Brand’s Design, Construction and Renovation Standard
##2510.01.C.4##
907.01.C EMERGENCY INSTRUCTIONS
Display security and emergency instructions on the back of the door or on the wall immediately adjacent to the door.

907.02 BALCONY / PATIO DOORS


Sliding glass doors to guest room balconies or patios must be equipped with a secondary locking device and have a safety instruction decal affixed to the
inside pane of glass advising guests to utilize locking devices and not to leave children unattended on balconies.All glass doors, e.g. sliding patio and
balcony doors must have identifying logo or brand approved stickers at:Adult level (approximately 60" / 1.5m above finished floor)Child level (approximately
31" / 79cm above finished floor).
907.03 Not Applicable to this Brand
907.04 KEY CARDS
All hotels must utilize brand approved electronic lock key cards. Refer to the standards below:
• Room keys must not display the hotel name, logo, or room number at any time.
• No third-party advertising may be featured anywhere on the key.
• Room numbers must never be announced.
• A coding system must be used for key card labeling that allows in-house verification of room numbers.
• If a guest requests a replacement room key, verify guest identification prior to issuance.
907.05 INCOMING TELEPHONE CALLS
The hotel must comply with the following incoming telephone protocol:
• Guest names or room numbers are never given out.

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• Calls are not transferred to guest rooms without the caller identifying correctly the last name of a registered guest.

908.00 MASTER KEY CONTROL


• The hotel must implement a key control program.
• One full set of keys must be clearly labeled and kept by the hotel’s accounting or security personnel and another one in the hotel’s main safe.
• The hotel must maintain a written policy that monitors and controls the issuance and retrieval of all master keys (both analog and electronic keys).
909.00 LOST AND FOUND
• Lost and found articles must be dated, stored, and maintained in a secure area in accordance with applicable law or for 90-days whichever is more
stringent. Credit cards, medication, or perishable items must be held for 48 hours.
• Found articles must be properly dated, stored, and secured. Records must be maintained and procedures established to ensure prompt, accurate response
to a guest's inquiry concerning a lost article. The hotel manager must have access to the secured area 24 hours a day in order to return properly identified
items to guests.
• Lost and found articles must be logged and maintained in a secure area in accordance with applicable law and must be retained for at least 90 days (or a
greater period if required by law) before discarding. Valuables must be maintained for one year. The lost and found log can be maintained using either OnQ
Property Management or a separate book or electronic system.
910.00 HOTEL ACCESS
All entrance/exit doors normally locked during specific times, or as required by code, must have signs both inside and outside the doors that indicate the time
they are locked and include directions to the appropriate alternate entrance/exit doors.
All exterior entrance doors of the hotel must provide registered guest access with the use of their key cards. All fire exits of the hotel must remain locked from
the exterior side at all times.
911.00 INFORMATION PRIVACY AND DATA PROTECTION
These Privacy Brand Standards set forth the privacy, confidentiality, and security requirements for customers’ “Personal Information” that is Processed in
connection with operation of the hotel. They are intended to promote customer trust, facilitate compliance with privacy and data protection laws and to help
manage privacy-related risk. They apply to all collection, use, sharing and other handling and Processing of Personal Information at the property level and are
applicable to all brands. These Standards apply globally except where otherwise noted. The reference to “hotel” in these Privacy Brand Standards refers to all
Hilton-branded properties and such references include hotel personnel and the owners and franchisees, unless otherwise noted.
“Personal Information” is any information that:
• Can be used (alone or in combination with other information within the hotel’s control) to identify (directly or indirectly), locate, or contact a specific
individual; or
• Can be associated with an identified or identifiable individual
For example, Personal Information consists of an individual’s name in combination with their address, email address, Honors number, mother’s maiden name,
Date of Birth, Taxpayer Identification Number, passport details, driver’s license number, other identification number issued by a government or public body, or
financial account number (with or without any code or password that would permit access to the account). Personal Information can be in any media or format,
including computerized or electronic records as well as paper-based files, including all copies, fragments, excerpts, whether or not such Personal Information
has been intermingled with other information or materials.

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“Sensitive Personal Information" is a subset of Personal Information, which due to its nature has been classified by law or by policy as deserving additional
privacy and security protections. Sensitive Personal Information includes:
• Information about the race, religion, ethnicity, medical or health information, political opinions, trade union membership, background check information, or
sexual life of an identifiable individual
• Genetic or biometric data; and
• Social Security Number
Cardholder Information consists minimally of the full payment account number (PAN) but can also include cardholder name, expiration date and/or service
code.
“Processed” or “Processing” means any operation or set of operations which is performed on Personal Information, or on sets of Personal Information,
whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use,
disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
911.01 COLLECTION, USE, AND ACCESS TO PERSONAL INFORMATION
Personal Information must be collected and used in a reasonable and lawful manner and in accordance with these Standards. All Processing of Personal
Information shall be limited to operation of the hotel as a hotel, consistent with these Standards, and only as permitted by applicable law.Hotel may collect
and use an individual’s Personal Information only for the following purposes:The purposes stated in the Hilton Global Privacy Statement (including to Process
reservations and provide customer service)Fulfilling or responding to a request from the individualPerforming hotel's contractual obligations to the
individualComplying with hotel’s legal obligationsOther purposes expressly approved in writing by Hilton.Personal Information and Cardholder Information
may not be collected on a stand-alone website.Personal Information may not be used by hotels (including hotel personnel, owners or franchisees) for direct
marketing purposes (e.g., direct mail, email campaigns, telemarketing), unless approved in writing by Hilton.Within the hotel, access to Personal Information
must be limited to personnel who reasonably need access to such Personal Information for legitimate business purposes (such as to facilitate personalized
guest interactions) or to carry out their assigned functions.Personal Information may not be used to market the products or services of a third-party or a non-
Hilton branded hotel.Hotel may only request Sensitive Personal Information from guests to the extent collection of such information is required by local
law.Hotel may use Sensitive Personal Information that is voluntarily provided by an individual (e.g., a health condition or food allergy that requires an
accommodation) only as permitted by law to provide customer service, meet an individual's particular needs, or respond to a request from the individual.Hotel
may not call customers on property to ask for Cardholder Information. While guests are on property, hotels must obtain Cardholder Information (other than
card on file transactions) from the guest, in person, at the front desk.Guest collateral (e.g., key packets) must state: "The Hotel will never call your room to ask
for credit card information."
911.02 CLOSED CIRCUIT TELEVISIONS (CCTV)
CCTV cameras may not be placed in, or aimed at, guest rooms/suites, locker rooms, restrooms, recreation bodies of water or other non-public areas. Hotel’s
use of CCTV cameras, installation, and the retention of CCTV footage must comply with applicable local laws, including required notice provisions. This
provision does not limit the Hotel from using other industry standard security surveillance methods.
911.03 NOTICE AND TRANSPARENCY
Hotel is responsible for providing information about its privacy practices to individuals whose Personal Information is Processed by hotel. Notices must
comply with applicable laws.Two copies of the Hilton Global Privacy Statement must be available at the front desk of each hotel. One copy must be in the
local language. The Global Privacy Statement must be provided to individuals upon request.In countries where an abbreviated privacy notice has been

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approved for inclusion on the registration card, a copy of such notice must be included on hotel registration cards. Privacy notices must be updated as
required by Hilton.All customer-facing hotel websites must link to the Hilton Global Privacy Statement, and no other privacy policy (unless approved in writing
by Hilton). Franchisees and owners may not operate hotel-related websites that collect Personal Information unless approved by Hilton.In addition to the
foregoing, where acting as a controller, franchisees and owners are responsible for providing individuals whose Personal Information is Processed by them
with a privacy notice identifying them as the controller, if and when required by applicable laws. Such notice shall conform to the requirements of these
Standards and applicable laws.
911.04 CHOICE TO OPT-OUT
For property-level Processing of Personal Information:Hotel must provide individuals with a reasonable opportunity to object to the Processing of their
Personal Information by property-specific systems. Where applicable law requires the express or explicit consent of the individual for the collection and other
Processing of their Personal Information, hotel must obtain and maintain a record of such consent. Hotel must honor individuals’ requests regarding
marketing communications. For corporate-wide Processing of Personal Information: In hotels where the local tab of the OnQ Property Management System
(or other property management system used by hotel) is capable of recording a guest’s request to receive marketing communications, hotel must promptly
enter the guest’s request in the property management system. If an individual expresses a desire to opt out of marketing communications from Hilton, hotel
must communicate that preference to Hilton by sending an email to customer_privacy@hilton.com. Hotel must promptly forward requests (including the
applicable telephone number) to opt-out of telemarketing to membersupport@hgvc.com.
911.05 DISCLOSING PERSONAL INFORMATION TO THIRD PARTIES
Hotel may disclose Personal Information to third party service providers only when both of the following apply:Such third party is a hotel service provider that
has entered into a written agreement that incorporates or includes language substantially similar to the Hilton Privacy and Data Protection Standards for
Service Providers and otherwise meets requirements of applicable lawPrior to entering into a contract or disclosing Personal Information, the hotel should
have a reasonable basis for believing that the service provider (a) is capable of maintaining appropriate safeguards for the Personal Information, and (b)
maintains sufficient procedures to detect and respond to security breaches that could compromise Personal Information. Hilton managed properties are
required to submit third party vendors and products to security reviews per Hilton policy.Franchisees are additionally responsible for: (i) ensuring that its
service providers are bound by law or contract to limit their use of the Personal Information to performance of the service for franchisee and otherwise for
appropriate purposes, consistent with the “Collection, Use and Access to Personal Information” clause above, and to have appropriate security controls in
place; and (ii) ensuring that written agreements are in place with any service provider that will Process Personal Information that includes such additional
provisions required by applicable law.Hotel may disclose Personal Information to government or public authorities (including law enforcement), where
required by law or where permitted by applicable Hilton policies.Hotel may disclose Personal Information to the extent reasonably necessary to enforce the
hotel’s rights or protect the safety and security of hotel, its guests or personnel, or to respond to an emergency.Hotel may disclose Personal Information
pursuant to the written consent of the individual whose Personal Information will be disclosed, provided that the consent complies with applicable data
protection laws and is documented and retained if and as required by applicable law.Personal Information may not be sold or rented to third parties, or
provided to third parties for such third parties’ own use, including marketing of the third parties’ products or services.All transfers of Personal Information to
and from the hotel must be completed consistent with the requirements of applicable law, these Standards, and applicable Hilton policies. International
transfers of Personal Information (including permitting remote access to Personal Information from another country) must also comply with laws for such
cross-border transfers.The following provisions apply to franchisee hotels located in the European Union, the European Economic Area and/or their member
states, Switzerland and the United Kingdom: Pursuant to your franchise agreement, the Standard Contractual Clauses (the “SCC”) apply to transfers of

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Personal Information by franchisee from the European Union, the European Economic Area and/or their member states, Switzerland and the United
Kingdom, to Hilton in the United States, to the extent the SCC are required with respect to the transfer. Upon franchisee’s written request, and subject to
applicable confidentiality obligations, franchisor shall make available reasonable information regarding franchisor’s or its applicable affiliates’ compliance with
the obligations set forth in the SCC and franchisee agrees that provision of such information will satisfy Hilton’s (or its affiliates’) obligations under Clause II.e
of the SCC. In the event franchisor does not make such information available to franchisee, franchisee may contact franchisor in accordance with the
“Notices” Section of the franchise agreement to request a facilities audit of the procedures relevant to the protection of Personal Information. Franchisee shall
reimburse franchisor for franchisor and its affiliates’ reasonable costs incurred and time spent for any such facilities audit. Before the commencement of any
such facilities audit, franchisee and franchisor shall mutually agree upon the scope, timing, and duration of the audit in addition to the reimbursement rate and
costs for which franchisee shall be responsible. Franchisee shall promptly notify franchisor with information regarding any non-compliance discovered during
the course of an audit.Franchisee acknowledges that franchisor may disclose Personal Information to its affiliates for the purposes set forth in the SCC.
Turkey: Hotel may disclose Personal Information to third party service providers only when both of the following apply:Such third party is a hotel service
provider that has entered into a written agreement that incorporates or includes language substantially similar to the Hilton Privacy and Data Protection
Standards for Service Providers and otherwise meets requirements of applicable lawPrior to entering into a contract or disclosing Personal Information, the
hotel should have a reasonable basis for believing that the service provider (a) is capable of maintaining appropriate safeguards for the Personal Information,
and (b) maintains sufficient procedures to detect and respond to security breaches that could compromise Personal Information. Hilton managed properties
are required to submit third party vendors and products to security reviews per Hilton policy.Franchisees are additionally responsible for: (i) ensuring that its
service providers are bound by law or contract to limit their use of the Personal Information to performance of the service for franchisee and otherwise for
appropriate purposes, consistent with the “Collection, Use and Access to Personal Information” clause above, and to have appropriate security controls in
place; and (ii) ensuring that written agreements are in place with any service provider that will Process Personal Information that includes such additional
provisions required by applicable law.Hotel may disclose Personal Information to government or public authorities (including law enforcement), where
required by law or where permitted by applicable Hilton policies.Hotel may disclose Personal Information to the extent reasonably necessary to enforce the
hotel’s rights or protect the safety and security of hotel, its guests or personnel, or to respond to an emergency.Hotel may disclose Personal Information
pursuant to the written consent of the individual whose Personal Information will be disclosed, provided that the consent complies with applicable data
protection laws and is documented and retained if and as required by applicable law.Personal Information may not be sold or rented to third parties, or
provided to third parties for such third parties’ own use, including marketing of the third parties’ products or services.All transfers of Personal Information to
and from the hotel must be completed consistent with the requirements of applicable law, these Standards, and applicable Hilton policies. International
transfers of Personal Information (including permitting remote access to Personal Information from another country) must also comply with laws for such
cross-border transfers.
911.06 ACCESS AND CORRECTION
In General: Hotel must provide guests an opportunity to review, correct and take certain other actions with respect to the Personal Information that hotel
maintains about them, consistent with applicable law. Before allowing someone to take such actions with respect to Personal Information, hotel must confirm
that either (i) the Personal Information pertains to that individual, or (ii) that individual has been authorized to review and correct the Personal Information by
the person to whom the Personal Information pertains. Specific Categories of Guest Requests:Where applicable law provides individuals with the rights
described in (a) through (e) below, owners and franchises must respond to individuals’ requests to exercise such rights in a manner that complies with
applicable law. Where responding to an individual’s request requires access to Personal Information in Hilton corporate systems, owners and franchisees
must notify Hilton of such request promptly (but in any event within one business day of receipt of the request) by sending an email to

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DataProtectionOffice@hilton.com. Hilton-managed hotels must comply with the “Data Subjects Rights Procedures” (which may be accessed via the Lobby) in
acknowledging and responding to such requests. Access and Correction: Individuals must be provided with a reasonable opportunity to examine their own
Personal Information. Where individuals have rights of access, they must be able to confirm the accuracy and completeness of their Personal Information
and have their Personal Information corrected. Any corrections must also be communicated to applicable third parties. Erasure: In certain circumstances,
individual have the right to request that their Personal Information be deleted. Valid requests for deletion must be honored and communicated to applicable
third parties that are Processing such Personal Information. Processing Objection: In certain circumstances, individuals have the right to object to the
Processing of their Personal Information. Valid objections must be honored. Restriction of Processing: Individual have the right to restrict the Processing of
their Personal Information in certain circumstances. Valid restriction requests must be honored. Data Portability: Individuals have the right to request that
certain of their Personal Information be provided to them in a machine-readable format. Valid data portability requests must be honored. All requests must be
acknowledged and individuals informed if the request will not be granted.
911.07 DATA ACCURACY, RETENTION, AND DISPOSAL
Hotel must take reasonable measures to keep Personal Information appropriately accurate, complete, and up-to-date. Hotel must retain and dispose of
Personal Information in an appropriate manner that prevents unauthorized access to the Personal Information, and in accordance with applicable law and
applicable information security and document retention policies. Hotel must notify Hilton if it becomes aware of any inaccuracies in Personal Information.
Hotel must limit the number of copies of Personal Information and Cardholder Information stored to those reasonably necessary for ongoing business and
record-keeping purposes, consistent with the applicable retention schedule. Making photocopies of credit cards, passports or other identification is prohibited,
unless required by local law. When applicable, hotel must make the card security code unreadable on any printed copy and electronic image, and secure the
copies in accordance with PCI-DSS and applicable data protection laws.See Information Security Brand Standards for additional details regarding storage
and disposal of Personal Information.
911.08 INFORMATION AND DATA SECURITY
It is the Property's responsibility to safeguard the Personal Information in its possession or control, and to comply with these Standards and applicable laws.
Property will adopt, implement and maintain appropriate security procedures and practices to prevent the unauthorized access, destruction, modification, use
or disclosure of Personal Information. Such procedures and practices will be compliant, at a minimum, with the terms of Hotel’s agreement(s) with Hilton,
these Privacy Standards and applicable laws. All such procedures and practices will take into account the nature of the Personal Information and the
commensurate risks associated with such Personal Information.Property will ensure that: (i) its Team Members and agents will be required, as a condition of
employment or retention, to protect all Personal Information in Property's possession or otherwise acquired by Property; (ii) its Team Members and agents
who will be provided access to, or otherwise come into contact with, Personal Information, will receive appropriate training relating to the protection of
Personal Information; and (iii) it will impose appropriate disciplinary measures for violations of its information security policies and procedures.Property will
review and, as appropriate, revise its security procedures and practices: (i) at least annually or whenever there is a material change in Property's business
practices that may reasonably affect the security or integrity of Personal Information; (ii) in accordance with prevailing industry practices; (iii) in accordance
with applicable laws, and (iv) as reasonably requested by Hilton’s Global Information Security Office.
The hotel must comply with all laws and regulations relating to information or data security. The hotel must comply with Hilton Information Security Standards,
as published on The Lobby here: https://lobby.hilton.com/departments/itsecurity/Pages/Global-Information-Security/Hotel-Information-Security.aspx.
Key Information Security Standards and responsibilities required for all hotels include:
• Maintaining a written record of the hotel personnel responsible for implementing and performing the hotel’s information security responsibilities.

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• Maintaining a written record of all hardware and software (i.e., a technology asset inventory) with relevant and applicable details such as those
technologies that store, process, and/or transmit Restricted or Confidential Information.
• Ensuring only Hilton Managed Technology is connected to, or operates on, the Information System. Uncertified Software, Unauthorized Equipment, or
technology not managed by Hilton via a HITS, or other written agreement is not permitted to connect to, or operate on, the Information system.
• Managing access controls to hardware, software, and facilities:
• In accordance with the principle of least privilege;
• Removing access immediately upon termination of employment; and
• Conducting and maintaining a written record of, periodic reviews to confirm access (e.g., quarterly user access review).
• Ensuring user accounts and passwords (including those assigned to support vendors) to software, hardware, and facilities systems are:
• Not shared;
• Unique and assigned to specific persons; and
• Subject to complexity and periodic change requirements specified by Hilton.
• Ensuring all remote access and remote administration of any system conforms to Hilton Standards. Vendor remote access capability must be disabled
when not in use and monitored when support is required - “always-on” 24 hour, seven days a week access is prohibited.
• Conducting and maintaining a written record of periodic inspections to verify, at a minimum:
• The on-going efficacy of physical access controls such as door locks and monitoring systems;
• Unauthorized wireless devices and keystroke/data loggers are not connected to networks or systems; and
• Payment card swipe devices reconcile to inventory records and do not have signs of tampering.
• Cooperating with and supporting all Hilton Information Security requests and investigations, including but not limited to:
• Malware eradication
• Hotel-level data such as log or video monitoring records
• Immediate removal of unauthorized hardware or software from the hotel’s systems and networks; and
• Forensic system imaging for any system connected to, or that was once connected to, a Hilton network.
911.08.A CERTIFICATION OF COMPLIANCE
General Managers (or their designee) are required to read and acknowledge, in writing, their understanding and agreement to comply with the Hotel
Information Security Standards at least annually.

911.09 COMPLAINTS
Complaints: Hotel must promptly and appropriately address any allegations, complaints, or inquiries that Personal Information has not been handled or
protected appropriately. Complaints that allege a violation of law, or any claim, action, lawsuit, proceeding, inquiry, audit, or enforcement action either initiated
by a data protection authority or involving the Processing of Personal Information, should be reported within one business day of receipt of the request to
privacy@hilton.com. Appointment of a DPO by Franchisees and Owners: Where required pursuant to applicable laws, franchisees and owners shall appoint
a data protection officer (“DPO”) and shall notify Hilton of such appointment. Franchisees and owners shall notify Hilton in advance of making any public
representation (in any format or venue, including oral presentations and written publications) about its data protection practices with respect to the
hotel.Reporting to a Data Protection Authority: Hotel must notify Hilton prior to (i) self-reporting or otherwise notifying a data protection authority or other
regulator of any potential violation of applicable law, or other circumstance pertaining to Processing of Personal Information; or (ii) engaging in consultation
with a data protection authority in connection with any ongoing or envisaged Processing activities.

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911.10 BREACH NOTIFICATION


Hotel must notify Hilton at ISC@hilton.com within 24 hours if such hotel has reason to believe that any Personal Information, or information or other material
that can be used to access Personal Information, in any form or on any media, has been acquired, modified, used, disclosed or accessed, by any
unauthorized person, or any person in an unauthorized manner or for an unauthorized purpose. Hotel shall, at Hilton’s request, fully assist Hilton in
responding to and resolving any security incidents and security breaches. Owners and franchisees must appropriately investigate and remediate any such
breach at their sole expense, in cooperation with Hilton. Owners and franchisees shall bear all costs associated with responding to and resolving a security
breach arising in connection with or as a result of the Processing of Personal Information related to the hotel including (without limitation), conducting an
investigation, notifying individuals and others as required by law, providing individuals with credit monitoring, and responding to individual, regulator and
media inquiries.
911.11 GUEST DATA
Hilton maintains, and requires that owners and franchisees comply with, these Standards in order to promote brand consistency among the hotel and other
Hilton-branded hotels and their guests, and to enable owners and franchisees to receive the benefits afforded to Hilton-branded hotels. Owners and
franchisee are responsible for ensuring compliance with these Standards by all of their workers, service providers, affiliates and business partners. The
following provisions apply to franchisees with hotels located in the European Union, the European Economic Area and/or their member states, Switzerland, or
the United Kingdom:Personal Information regarding guests or prospective guests of hotel (“Guest Data”) is Processed by franchisor and by franchisee, each
for its own independent business purposes. Franchisor is the sole controller with respect to the Processing of Guest Data by franchisor in connection with the
license and maintenance of the System (as defined in the franchise agreement). Franchisee has exclusive day-to-day control of the business and operation of
the hotel and is the sole controller with respect to the Processing of Guest Data by franchisee in connection with its operation of the hotel (subject to these
Standards).Any use of Guest Data by franchisees or owners after the expiration or termination of the franchise or management agreement (as applicable) is
limited to the extent necessary for the purpose of operating the hotel as an hotel (for example, to honor existing reservations), and is at the sole risk and
responsibility of franchisees and owners. Any such use is further subject to compliance with applicable law.Franchisee is the sole controller with respect to all
Processing of Personal Information: (x) that is received by franchisee from third parties (including individuals) and not Processed within the Information
System (as defined in the franchise agreement); and (y) regarding franchisee’s Team Members.
Turkey: Hilton maintains, and requires that owners and franchisees comply with, these Standards in order to promote brand consistency among the hotel and
other Hilton-branded hotels and their guests, and to enable owners and franchisees to receive the benefits afforded to Hilton-branded hotels. Owners and
franchisee are responsible for ensuring compliance with these Standards by all of their workers, service providers, affiliates and business partners.
911.12 TELEPHONE AND DEVICE SECURITY
The use of all Cellular Telephone and Wireless PDA Devices must conform to Hilton's security standards established for Personal Wireless Devices as stated
in the information security standards published on The Lobby."Personal Wireless Devices" means personal wireless electronic devices, including devices that
are authorized and configured to receive Hilton e-mail and/or process Protected or Confidential information, including Credit Cardholder Data, and which may
also connect to Hilton's network or systems either directly or indirectly. Some types of Personal Wireless Devices may have advanced features, such as e-
mail or the ability to run applications. Connecting unauthorized devices to the HITS Information System is prohibited. Examples of Personal Wireless Devices
include but are not limited to: personal digital assistants, netbooks, laptops and other personal computers, BlackBerries, iPhones and other smartphones and
cellular, Internet or other telephones.

912.00 INSURANCE

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NOTE: The following Insurance Requirements section is written with U.S. Dollars used for coverage types and minimum limits. The insurance obtained must
meet or exceed these brand standards based on current currency conversions.
Franchisee/Owner must meet or exceed the insurance requirements specified in this Hilton Holdings Inc., Brand Standards Manual (“Manual”), unless
specifically indicated to the contrary in the Management Agreement (“Agreement”). Insurance requirements are split into TWO areas:Insurance required
during Construction (or Significant Renovation); and Insurance required during Operation.
Wherever possible, global standards have been provided. To the extent requirements differ for hotels located within the U.S. and those located outside the
U.S., specific standards are provided
912.01 INSURANCE REQUIRED DURING CONSTRUCTION
912.01.A OCCUPATIONAL INJURY
Minimum Required Limit: As required by local law
NOTE: Occupational Injury insurance, as required by law or regulation, must be in force prior to the hiring of any Team Members.
912.01.B EMPLOYERS LIABILITY
Minimum Required Limit: $1M per occurrence or as required by local law
NOTE: The EL limits can be satisfied by any combination of Occupational Injury Scheme, EL, and/or PL policies. However, the certificate of insurance
must clearly indicate that PL insurance affords coverage for EL.
912.01.C GENERAL LIABILITY / PUBLIC LIABILITY
Minimum Required Limit: $10M each occurrence
NOTE: Coverage must include:
Products-completed operations,Personal and advertising injury,Protective liability,Independent contractors, andLiability assumed under an insured
contract (including the tort liability of another assumed in a business contract) on an "occurrence basis”.This insurance may not have any restrictions,
modifications or exclusions for explosion, collapse, underground property damage, earth movement or damage to work performed by a
subcontractor.Contractor must carry completed operations insurance for a period of not less than 5 years after the completion of the project.
912.01.D AUTO LIABILITY
Minimum Required Limit: As required by local law
NOTE: As required by local law
912.01.E POLLUTION LEGAL LIABILITY
Minimum Required Limit: (if exposure exists) $1M
NOTE: If the Contractor's policy is on a claims-made form, the retroactive date of the policy must be on or before the date of the commencement of
services by Contractor.
Insurance must be maintained and evidence of insurance must be provided for at least three (3) years after completion of the work. If the coverage is
canceled or not renewed, and it is not replaced with another policy with a retroactive date that precedes the date of Contractor’s agreement, the
Contractor must provide extended reporting coverage for a minimum of three (3) years.
912.01.F UMBRELLA / EXCESS LIABILITY
Minimum Required Limit: See Underlying Requirements

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NOTE: Insurance requirements for PL, EL and AL may be satisfied with a combination of primary umbrella and/or excess policies.
912.01.G PROFESSIONAL ERRORS AND OMISSIONS
Minimum Required Limit: Limits Commensurate with risks
NOTE: The Architect and all other professionals must carry E&O. Such policy shall cover claims arising out of negligent errors or omissions during the
performance of professional services and include coverage for attorney fees. The retroactive date of the policy must be shown on the certificate of
insurance and must be before the date of the agreement. If the coverage is canceled or not renewed and it is not replaced with another policy with a
retroactive date that precedes the date of this agreement, all professionals must provide extended reporting coverage for a minimum of two (2) years
after completion of the agreement or the work on the former policy. Professionals shall keep such insurance in force during the course of this
Agreement for a period of not less than two (2) years after the date of completion.
912.01.H BUILDER'S RISK
Minimum Required Limit: 100% Completed Value (Full Replacement Cost) or limits sufficient to avoid co-insuranceEarthquake and Flood (not less than
75% of the replacement cost or full probable maximum loss (PML) if in an earthquake and/or flood hazard area Windstorm – 75% Replacement Cost or
PML
NOTE: “All Risk” form and including the following: cold testing, windstorm, flood (if in a 100 year zone), earthquake (if in high hazard zone) and
collapse, including collapse resulting from design error This insurance must apply to: property intended for incorporation into the work for the entire
duration of the contract including: Property in the course of construction, reconstruction, or repair;Property while in transport to the site;Property stored
at the site or off premises;Scaffolding, staging, shoring, formwork, fences, false work, and temporary buildings and any similar items commonly referred
to as construction equipment located at the site;Furniture, fixtures, andOther personal property typical to a hotel located on premises or in storage or at
any other temporary location.The policy must cover the cost of removing debris, including demolition as may be made legally necessary by the
operation of any applicable law, ordinance or regulation.Permission to occupy or a partial occupancy clause or definition must be included and allow
occupancy without qualification. This insurance must include Business Interruption coverage including the Brand's interest for full recovery of net profits
and continuing expenses of the hotel projected for 12 months following a covered loss (including Rental Value and payments that would have been
owed the Brand in the absence of a loss). This insurance must be maintained in effect until the earliest of either the date on which all persons and
organizations who are insured under the policy agree that it may be terminated or as provided for in the contract documents. This insurance must name
all Franchisees/Owners of the premises, agents of the Franchisee/Owner, and Contractors of any tier as insured. The policy must include a waiver of
subrogation stating that all Franchisees/Owners and Contractors waive their rights of subrogation against one another with respect to losses covered by
this policy.
912.01.I GENERAL REQUIREMENTS
NOTE: Franchisee/Owner must defend, indemnify and hold Hilton Holdings, Inc., its owners, subsidiaries and affiliates now or hereafter existing,
harmless from any and all damages or claims arising out of the failure of any Contractor, supplier or vendor doing business with the hotel to maintain
adequate insurance. Contractors must not be allowed on the site or within the premises until the stated insurance requirements are evidenced.
Contractor's insurance, with the exception of an Occupational Injury Scheme, must name Franchisee/Owner, Hilton Holdings, Inc., and each of their
owners, subsidiaries and affiliates (including their respective directors, officers and Team Members), now or hereafter existing as additional insured,
and copies of these endorsements or their equivalent must be provided to Franchisee and the Brand.
Franchisee/Owner, at its option, may purchase an "Owner controlled insurance program" or "wrap up."

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912.02 INSURANCE REQUIRED DURING OPERATION

912.02.A PUBLIC LIABILITY AND EXCESS LIABILITY


Minimum Required Limit: Participation in Brand insurance program is mandatory.
NOTE: The Brand or its designee will, at Franchisee/Owner’s cost, provide upon the commencement of operation of the hotel and maintain at all times
during the term of the Agreement, third-party PL in such amounts as the Brand may deem necessary. Franchisee/Owner will be named as an additional
insured. The Brand may elect to maintain all or part of such policies under an arrangement insuring one or more hotels operated by the Brand or its
affiliates or subsidiaries, in which event the cost of such insurance to Franchisee/Owner will be allocated by the Brand on the same basis as other
hotels of the Brand.If the Brand cannot obtain coverage, Brand will advise Franchisee/Owner of acceptable insurance requirements.
912.02.B WORKERS COMPENSATION / OCCUPATIONAL INJURY SCHEME
Minimum Required Limit: As required by local law or regulation
NOTE: Occupational Injury insurance, as required by local law or regulation, must be in force prior to the hiring of any Team Members.
912.02.C EMPLOYER'S LIABILITY
Minimum Required Limit: $1M per occurrence or as required by local law
NOTE: The EL limits can be satisfied by any combination of Occupational Injury Scheme, EL and/or PL policies. However, the certificate of insurance
must clearly indicate that PL insurance affords coverage for EL.
912.02.D GENERAL LIABILITY / PROPERTY OWNER'S LIABILITY
Minimum Required Limit: Commensurate with Risk
NOTE: Franchisee/Owner must procure and maintain Property Owners Public Liability policy fully protecting Franchisee/Owner for liability arising out of
its ownership, possession and use of the hotel. Exposure will depend on the extent to which Franchisee/Owner is involved in day to day operation of
the hotel. Hilton recommends that Franchisee/Owner consult with a licensed insurance broker to determine appropriate limits.
912.02.E AUTO LIABILITY
Minimum Required Limit: The greater of US$25,000 and limit required by local law
NOTE: If hotel owns and operates vehicles, Franchisee/Owner must procure and maintain AL as required by local law or regulation subject to a
US$25,000 minimum
912.02.F WATERCRAFT LIABILITY
Minimum Required Limit: Commensurate with Risk
NOTE: Hilton recommends that Franchisee/Owner consult with a licensed insurance broker to determine appropriate limits
912.02.G AIRCRAFT LIABILITY
Minimum Required Limit: Commensurate with Risk
NOTE: Hilton recommends that Franchisee/Owner consult with a licensed insurance broker to determine appropriate limits.
912.02.H COMMERCIAL PROPERTY AND BUSINESS INTERRUPTION
Minimum Required Limit: Full Replacement Cost or limits sufficient to avoid co-insurance

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Earthquake and Flood (not less than 75% of the replacement cost or full probable maximum loss (PML) if in an earthquake and/or flood hazard area
Windstorm – 75% Replacement Cost or PML
NOTE: Property Damage on a special causes of loss policy form (""All Risks""), including terrorism (may be part of the liability policy or a separate
policy) covering 100% of the insurable replacement value of the building and its contents. Such limit must be sufficient to avoid a co-insurance penalty,
if applicable. The policy must include coverage for the peril of windstorm and for ordinance and law.
This requirement for Earthquake and Flood only applies to hotels in an earthquake or flood hazard area. Please work with your insurance professional
to determine whether or not your hotel is in a high hazard area.
If a PML study is being used to determine appropriate earthquake, flood or wind limits, the PML must be based on the results of a professional study.
912.02.I BOILER AND MACHINERY (EQUIPMENT BREAKDOWN)
Minimum Required Limit: Full replacement cost of items
NOTE: Broad form Boiler and Machinery insurance against loss from accidental damage to, or from the explosion of, boilers, air conditioning systems,
including refrigeration and heating apparatus, pressure vessels and pressure pipes in an amount equal to 100% of the actual replacement value of such
items (without taking into account any depreciation) plus full recovery of the net profits and continuing expenses of the hotel. Continuing expenses must
specifically include royalty/license fees and other fees payable to the Brand.
912.02.J TERRORISM
Minimum Required Limit: Full replacement cost and business interruption
Third party liability if not covered in the GL policy
NOTE: Terrorism coverage shall be obtained and maintained for both first-party damage and-third party liability either stand-alone, through a
government operated or mandated pool, or as part of the PL coverage and the Property Damage/ Business Interruption coverage.
912.02.K CRIME
Minimum Required Limit: Commensurate with risk
NOTE: Please consult with a licensed insurance broker to determine appropriate limits. The Crime insurance must include coverage for the following
risks and consider more than cash on hand: Team Member DishonestyForgery & AlterationMoney & SecuritiesComputer FraudSafe
RobberyCounterfeit Paper
912.02.L GENERAL REQUIREMENTS
NOTE: With the exception of Property, Boiler & Machinery and Occupational Injury, all policies obtained by Franchisee/Owner must name the
Franchisee/Owner as named insured, and must name Hilton Holdings, Inc., and its owners, subsidiaries and affiliates now or hereafter existing as
additional insured including their Team Members, officers and directors. All policies of Franchisee/Owner must be endorsed to be primary insurance
with no recourse to, or contribution from, any other similar insurance, if any, which may be carried by Hilton Holdings, Inc., and its owners, subsidiaries
and affiliates. Evidence of such must be supplied to the Brand.Any deductibles or self-insured retentions above $50,000 or 5% of the replacement cost
of the hotel must be declared to and approved by Hilton Holdings, Inc., Risk Management Department, at: 7930 Jones Brand Drive, McLean, VA 22102;
Email: Risk.Management@hilton.com.Requests by Franchisee/Owner to modify requirements for Earthquake, Flood, Windstorm or Terrorism may be
submitted to Hilton Risk Management for consideration. Guidelines for such requests may be requested at Risk.Management@hilton.comFranchisee/
Owner must deliver or cause to be delivered to the Brand upon renewal or change in limits or coverage each of the following:Certificates of insurance or
documentation acceptable to Hilton Holdings, Inc., evidencing the insurance, including applicable endorsements. Where applicable each certificate

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must specifically identify and/or list: Insured location(s) by name, address and Facility ID number.Relevant policy numbersRelevant parties as being
named additional insured (as specified above)Correct Hilton legal entity as certificate holder (Hilton Inc., 7930 Jones Branch Dr., McLean, VA
22102)For Property, Boiler & Machinery and Business InterruptionWindstormEarthquake and/or Flood as appropriateTerrorism (unless provided
separately)A signed letter written or translated to English from the insurance agent or broker who placed the required insurance affirming that he or she
has read and understood the insurance requirements contained in this Manual. This letter must specifically address whether the insurance the agent or
broker has placed complies with the insurance requirements set forth in this Manual.A signed checklist from the insurance agent or broker indicating
whether there is coverage for each of the minimum requirements set forth in this Manual.For samples of these letters and checklists, as well as sample
certificates and evidence of property insurance, please request a copy from Hilton Holdings, Inc., Risk Management department at
Risk.Management@hilton.com.For notice purposes the certificate holder is “Hilton Holdings, Inc., Attn: Risk Management, 7930 Jones Branch Drive,
McLean, VA 22102"All certificates or other documents evidencing insurance must be provided in English with currency indicated in U.S. dollars. Limits
required in this standard may be satisfied in the local currency equivalent at the time the policy is purchased.All evidence of insurance required herein
including certificates must be sent, either by fax, email or upload, to Hilton Holdings, Inc.'s, external partner as indicated on OnQ’s Risk Management
page: Proof of Insurance (Certificates).Hilton Holdings, Inc.'s, external partner will review and audit each certificate of insurance in line with
requirements as set out in this Manual.If Franchisee/Owner does not obtain or maintain the required insurance or policy limits, the Brand can (but is not
obligated to) obtain and maintain the insurance or such portion of the insurance (Difference in Limits”/”Difference in Conditions”) needed to bring
Franchisee/Owner’s insurance in line with the requirements herein for Franchisee/Owner without first giving Franchisee/Owner notice. If the Brand does
so, then Franchisee/Owner must immediately pay the Brand upon request, the premiums and costs incurred by Brand.The Brand makes no
representation, implied or express, that the foregoing insurance requirements are adequate to protect Franchisee/Owner.The insurance coverage
requirements contained in this Manual are only minimum requirements. These requirements do not relieve Franchisee/Owner from responsibility for
any loss or claim for damages arising out of the Agreement. Franchisee/Owner must indemnify the Brand for any claim for damages due to failure of
Franchisee/Owner or any Contractor, supplier or vendor doing business with Franchisee/Owner to maintain adequate insurance.To ensure compliance,
the Brand strongly recommends that Franchisee/Owner reproduce all insurance requirements in this Manual in full and submit it to a licensed agent or
broker experienced in writing insurance for hotels.Failure of the Brand to demand evidence of compliance with the insurance requirements in this
Manual or failure of the Brand to identify a deficiency from evidence that is provided shall not be construed as a waiver of Franchisee/Owner's
obligation to maintain such insurance.At the request of the Brand, Franchisee/Owner must deliver a copy of each policy bearing certification of the
insurance company underwriter(s), that the policy is a complete copy of the policy issued with all endorsements to the Brand.The Brand may increase
or decrease the minimum amount of insurance, require additional or different types of insurance, or otherwise change the requirements to make them
comparable to the amount and kinds of insurance carried by other properties or hotels, taking into account the size and location of the hotel and
changing circumstances in the law and insurance marketplace.Franchisee/Owner must obtain and maintain any other insurance required by local or
national statute or law.
912.02.M BUSINESS INTERRUPTION
Minimum Required Limit: Full recovery of net profits and continuing expenses for 12 months
NOTE: Full recovery of the net profits and continuing expenses of the hotel (including rental value) for a 12 month period must be carried. Such limit
must be sufficient to avoid a co-insurance penalty, if applicable.
Continuing expenses must specifically include royalty/license fees and other fees payable to the Brand, its subsidiaries and affiliates. The policy must
include coverage for all perils identified for Commercial Property Insurance and Boiler & Machinery above.

900-20 CONFIDENTIAL Hampton - Brand Standards - Europe Generated On October 26, 2020
900 - ACCESSIBILITY, SAFETY AND SECURITY

Hilton Holdings, Inc., and its owners, subsidiaries and affiliates now or hereafter existing must be included as an additional insured as respects their
interest in Business Interruption insurance.

913.00 Not Applicable to this Brand


914.00 RISK MITIGATION PLAN
Hilton may identify, from time to time, actual or perceived risks in connection with the hotel’s location in a country. Without limiting any of its other obligations,
Owner will comply with any applicable Risk Mitigation Plan issued by Hilton for hotels located in countries (or locations within countries). Such Risk Mitigation
Plan may include requirements to address concerns including compliance, safety and security, government affairs, and human rights. The list of applicable
countries (or locations within countries) is attached as Appendix [A] (the “Country List”). The Country List and/or the Risk Mitigation Plan may be amended,
supplemented, replaced or deleted by Hilton from time to time, and Owner shall comply with any such variations. In addition, Owner should identify and
assess risks relevant to their property to determine if further measures should be implemented. Hilton shall not be liable to Owner in connection with any
matter or measures referred to in the Risk Mitigation Plan.

900-21 CONFIDENTIAL Hampton - Brand Standards - Europe Generated On October 26, 2020

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