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Ethical Conduct (MIP-01) MARRIOTT INTERNATIONAL POLICY (MIP) Ethical Conduct (MIP-01) - Ml Standards REVISED: OCTOBER 21, 2020 REVIEWED: OCTOBER 14, 2020 Region & Brand Applicability Table BRAND NAME ‘Above Property AC Hotels Aloft Hotels ‘Autograph Collection Autograph Collection - All Inclusive ‘Autograph Collection Residences Bulgari Bulgari Residences Courtyard Delta Hotels Delta Hotels - All-Inclusive Design Hotels EDITION Hotels EDITION Residences Element Hotels Fairfield Four Points htps:imgscloud marriott. comlstandards7id=1804 AP EUR MEA sno91622, 10:01 PM Gaylord Hotels v Headquarters v JW Marriott v JW Marriott - All-Inclusive v JW Marriott Residences v Le Meridien v Le Meridien Residences v Marriott Executive Apartments v Marriott Hotels v Marriott Hotels - All-Inclusive v Marriott Residences v BRAND NAME. uS/ CAN Marriott Vacations Club v MOXY Hotels v Protea Hotels by Marriott v Renaissance Hotels v Residence Inn v Ritz-Carlton Reserve v Sheraton Hotels v Sheraton Residences v SpringHill Suites v St. Regis Hotels v St. Regis Residences v The Luxury Collection v The Luxury Collection - All- v Inclusive The Luxury Collection v htps:imgscloud marriott. comlslandards7id=1804 Ethical Conduct (MIP-0%) - MI Standards v v CALA v v AP. EUR 4 886 6 MEA 4 886 ‘ 2n091622, 10.01 PM Residences The Ritz-Carlton v The Ritz-Cariton - All-Inclusive v The Ritz-Carlton Club v ‘The Ritz-Carlton Residences v The Ritz-Carlton Yacht Collection ¥ TownePlace Suites v Tribute Portfolio v Tribute Portfolio - All-inclusive v W Hotels v W Hotels - All-Inclusive v W Residences v Westin Hotels v Westin Hotels - All-Inclusive v Westin Residences v Ethical Conduct (MIP-0%) - Ml Standards v ¥ ¥ v v v v v v v v v v v ¥ v v v v v v v v v v v v v v ¥ v v v v v v v v v v v v ¥ ¥ v v v v v v v v v APPLIES TO: Architecture & Construction, Communications, Engineering, Event Management, Finance & Accounting, Fitness & Recreation, Food & Beverage, Front Office, Furniture, Fixtures & Equipment, Golf, Housekeeping, Human Resources, Legal, Information Protection, Purchasing, Quality Assurance & Guest Satisfaction, Residential Operations, Retail, Risk Management & Loss Prevention, Sales, Marketing & Revenue Management, Spa, Technology Requirements Applicabilty: Associates at al brands, all regions Key Responsibilities Section ” Policy Owner: (unless otherwise stipulated, is responsible for policy administration, compliance monitoring, implementation, and training) Senior Vice President, Global Compliance Counsel & Privacy Officer (Kimberly Shur) Policy Approver: (unless otherwise hitps:mgscloud marriott. comlslandards7id=1804 Executive Vice President, General Counsel (Rena Reiss) ano91622, 10:01 PM Ethical Conduct (MIP-01) - MI Standards stipulated, is responsible for approval of exceptions) 1. Policy ‘The Board of Directors of Marriott International, Inc. (the "Company") has approved and requires strict adherence to this Ethical Conduct Policy. Any waiver of this Policy, for executive officers or directors may be made only with the approval of the Board of Directors or a committee of the Board of Directors. Pursuant to this Policy, the Company will conduct its business in accordance with uncompromising ethical standards and comply with all applicable laws and regulations. Adherence to such ethical and legal standards should never be traded in favor of financial or other business objectives. High ethical standards and legal compliance are necessary to maintain both competitive advantage and the pride and confidence of our associates, and to provide quality products and services to customers and clients The Company requires every director, officer and associate (collectively, "associates") to adhere to high ethical and legal standards and to promote ethical and legal behavior. Associates should avoid seeking loopholes, shortcuts or technicalities, and should reject the notion that unethical behavior is acceptable because “everyone is doing it.” Every action should be judged by considering whether it is legal, fair to all concemed, and would withstand the scrutiny of, outsiders. Behavior which is found to violate this Policy, the Business Conduct Guide or any Marriott International Policy (MIP) will subject the violator to disciplinary action including, where appropriate, termination of employment. 2. Requirements All associates are responsible for understanding and upholding the legal and ethical standards detalled in this Policy and the Business Conduct Guide. The Business Conduct Guide contains standards that amplify and explain the Company's commitment to ethical conduct, legal compliance and fair dealing. Itis reasonably designed to deter wrongdoing and to promote: (1) Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships; (2) Compliance with applicable governmental laws, rules and regulation (3) The prompt internal reporting of violations of the Business Conduct Guide to an appropriate person or persons identified in the Business Conduct Guide. The Business Conduct Guide is posted on the Company's publicly accessible website and on the Company's internal website Marriott Global Source. Managers who are responsible for supervising other associates have a specific responsibilty to ensure that associates who report to them understand the expectations contained in this Policy and the Business Conduct Guide. Managers are expected to set the right tone and lead by example. For the Company to conduct its business in accordance with high ethical standards, every associate must comply with the requirements outlined below. hitps:mgscloud mariol.comslandards7id=1804 ano91622, 10:01 PM Ethical Conduct (MIP-01) - MI Standards 2.1 Obey All Applicable Laws and Comply with the Business Conduct Guide Obey all applicable laws and comply with the Company policies outlined in the Business Conduct Guide or any Marriott International Policy (MIP). While the Company does not expect its associates to be subject matter experts in all areas of law, each individual is responsible for being familiar with the pertinent laws and policies governing his or her areas of responsibilty. Associates should seek advice from the Law Department whenever they have a question concerning the application of law or the Business Conduct Guide The list below contains policies that address material civil and criminal legal responsibilities and is not meant to be exhaustive: + MIP 07: Global Anti-Corruption (Foreign Corrupt Practices Act & UK Bribery Act) + MIP 10: Antitrust + MIP 57: Compliance with Anti-Money Laundering and Anti-Terrorism Requirements + MIP 71: Due Diligence for Prospective Owners, Franchisees and Joint Venture Partners + MIP 75: Gift and Entertainment Policy + MIP 80: Interaction with Government, Poltical Activity, and Political Contributions in the U.S. + MIP 85: Global Trade Sanctions (Prohibited Countries, Business Entities and Individuals, + MIP 91: Global Privacy and Personal Data Governance Program 2.2 Report Financial Condition and Results of Operations Honestly and Fairly Be honest and act with integrity in all communications, in every record created and in all data entered. The Company's, books and records shall be kept in accordance with generally accepted accounting principles, and with established finance and accounting policies. Accrual and reserve entries, and the capitalization of costs shall be used only for legitimate business purposes. All associates will cooperate fully with internal and outside auditors during their examinations of the Company's books, records and operations. Certifications and reports of financial conditions will be true and accurate. Falsification is inconsistent with principles of integrity and will not be tolerated. For additional guidance, consult: + MIP 20: Procurement + MIP 44: Travel and Business Expense Reimbursements + MIP 66: Account Reconciliations + MIP 67: Disbursements 2.3 Deal Honestly and Fairly with Clients, Customers, Suppliers and Business Partners The long-term success of the Company depends upon establishing mutually beneficial relationships. While the law requires that we obey the letter of all written contracts and agreements, we will also strive to uphold the spirit of all business arrangements. Clients, customers, suppliers and business partners should be treated honestly and fairly. hitps:mgscloud mariol.comslandards7id=1804 B1091622, 10:01 PM Ethical Conduct (MIP-01) - MI Standards 2.4 Avoid Conflicts of Interest Associates should avoid actual or potential conflict of interest situations. A conflict of interest arises when personal interests interfere with a person's ability to make objective business decisions, work effectively for Marriott, or adversely affect Company relationships with potential or actual suppliers, vendors, customers, franchisees, or owners of Marriott- managed properties. Associates may not engage in outside business activities that detract from job performance, interfere with the ability of other associates to perform their jobs, or result in an actual or apparent conflict of interest. Associates are required to submit a written description of the proposed activity and obtain written approval from the associate’s immediate supervisor (who may consult with the business unit HR Executive) before engaging in any outside business activity (see MIP-59 for more details). Any associate having any interest, direct or indirect (other than an interest of 5% or less in a ublicly-held company), in any supplier, customer, competitor or franchisee of the Company, or an owner of a Marriott- managed property, should make prompt disclosure to their immediate supervisor and obtain written approval to continue the relationship. Corporate officers and certain associates have additional responsibilty further described in MIP-60. Associates should not offer their skills or services to competitors or engage in outside businesses which compete with or sell goods or services to the Company. Associates are prohibited from (a) taking for themselves personal opportunities, gifts, or things of value that are unlawful, improper or outside the bounds of Company guidelines; (b) using corporate property or information or personal position for unlawful or improper gain; and (c) competing with the Company. It would be a contfict of interest ifa director, officer or associate or a member of his or her family received improper personal benefits as a result of his or her position in the Company. For additional guidance, consult: + MIP 59: Outside Business Activities + MIP 60: Investing in Business Partners + MIP 11: Securities Trading 2.5 Safeguard the Company's Assets and Protect Confidential Information Associates shall protect the Company's assets and ensure thelr proper use. Personal use of assets, supplies, equipment or premises belonging to the Company or its clients is prohibited, unless proper authorization exists or prior written approval has been obtained for such use. Every associate is responsible personally for safeguarding Company assets Under his or her control. Marriott's records, including information stored electronically on computers, personal digital devices, or other media are considered Marriott assets. All associates are responsible for protecting the confidentiality of Marriott's proprietary information, except when disclosure is authorized or legally mandated. Confidential information includes information that is not known to the public (such as personal or financial information of customers, personnel matters, associate usemames and passwords) or Undisclosed or commercially sensitive information (such as sales, marketing or pricing strategies, trade secrets, business plans, ete.) For additional guidance regarding authorization or approvals, consult: hitps:mgscloud mariol.comslandards7id=1804 eno91622, 10:01 PM Ethical Conduct (MIP-01) - MI Standards + MIP 29: Global Information Security Policy MIP 34: Technology Acquisition MIP 44: Travel and Business Expense Reimbursement MIP 59: Outside Business Activities MIP 60: Investing in Business Partners MIP 91: Global Privacy and Personal Data Governance Program 2.6 Treat All Associates Fairly and With Dignity and Respect | and sexual harassment. The All associates are entitled to a work environment free of retaliation and verbal, phys Company is committed to the principles of and procedures set forth in its Guarantee of Fair Treatment, The Company is committed to providing equal opportunity in all aspects of employment regardless of race, color, religion, sex (including pregnancy), sexual orientation, gender identity or expression, national origin, age, disability, genetic information, veteran or military status, or any other basis protected by applicable law. The company believes that work force diversity is an important objective in its own right and is a source of competitive advantage, as well as a requirement of Equal Employment Opportunity laws. For addit ional guidance, consult: + MIP 02: Guidelines on Associate Relations + MIP 05: Harassment and Professional Conduct, + MIP 38: Equal Employment Opportunity 2.7 Report Suspected Violations of Standards or Laws / Business Integrity Line The integrity of the Company is diminished when there are violations of the law or our business conduct standards. The Company will establish and maintain enterprise-wide procedures for reporting ethical violations or violations of law on a confidential basis (the "Business Integrity Line’). Itis the responsibility of all associates to report any suspected or actual Violation of the law or this Policy. When you suspect or know that an action or inaction is illegal or in violation of ethical standards or Company policy, you should report it using one of the following of + Discuss your concems with your manager. + Contact the Business Integrity Line (your identity will remain confidential) © For North American Locations call +1 (888) 888-9188 © For Country Specific Phone Numbers see ethics.marriott.com © Report online at ethics.marriott.com © Contact Internal Audit by emailing Business Ethics@Marriott.com © Contact the Marriott Law Department by writing to Marriott Law Department, 10400 Fernwood Road, Bethesda, MD 20817 The Business Integrity Line and online resources are available 24 hours a day, seven days a week. The Company respects the confidentiality of associates who report a known or suspected violation. The Company has a “zero hitps:mgscloud mariol.comslandards7id=1804 7091622, 10:01 PM Ethical Conduct (MIP-01) - MI Standards tolerance” policy against retaliation, and will not tolerate any kind of retaliation against an associate for reports or complaints made in good falth or with reasonable grounds to believe that the Information reported is accurate. 3. Policy Compliance The Company takes its obligations to comply with the law and this Policy seriously. Violations of this Policy and any Company policy, including those contained in the Business Conduct Guide, may lead to disciplinary action, up to and including immediate termination of employment. 4, Compliance Monitoring (On an annual basis, Internal Audit will obtain certifications from directors, officers, and a broad range of management associates about whether they are aware of any violations of this Policy and confirm that management associates have read, understood and are in substantial compliance with the Business Conduct Guide and other ethics-related policies. This process is an integral part of Marriott's Legal and Ethical Compliance Program. Additional guidance regarding the Company's Legal and Ethical Compliance Program is contained in MIP-12 Legal Compliance Program. 5. Documents Associated with this Policy Business Conduct Guides (PDF) + Arabic + Canadian French + English + French (European) + German * Indonesian + Japanese + Russian + Simplified Chinese + Spanish (European) ‘+ Spanish (Latin American) + Traditional Chinese + Traditional Korean + Traditional Thai + Vietnamese EFFECTIVE: JANUARY 07, 2005 | PUBLISHED: JANUARY 01, 2005 hitps:mgscloud mariol.comslandards7id=1804 ano91622, 10:01 PM Ethical Conduct (MIP-01) - MI Standards Irthis document is older than December 15, 2022, visit Marriot Global Source to ensure you have the most up-to-date version ofthis standard MARRIOTT CONFIDENTIAL AND PROPRIETARY INFORMATION The contents ofthis material are confidential and propretary to Marriot Intemational, Inc, and may net be reproduced, disclosed, distiouted or used without the express permission ofan authorized representative of Marriot. Any olher use is expressly prohibited hitps:mgscloud mariol.comslandards7id=1804 sno19118722, 10.01 PM Ethical Conduct (MIP-01)- Ml Standards hitps:mgscloud marriott. comstandards7i s0n0