91622, 10:02 PM This content matches your MGS Profile. Global Anti-Bribery and Anti-Corruption (U.S. Foreign Corrupt Practices Act and U.K. Bribery Act) (MIP-07) MARRIOTT INTERNATIONAL POLICY (MIP) REVISED: JUNE 13, 2022 | Global Ani-Bribery and Ant-Corrupton (US. Foreign Gorupt Practoes Act and U.K. Bribery Act) (MIP-07) - Ml Standards REVIEWED: MAY 15, 2022 Region & Brand Applica! BRAND NAME us/ CAN ‘Above Property v AG Hotels v Aloft Hotels v Autograph Collection v Autograph Collection - All Y Inclusive Autograph Collection . Residences Bulgari v Bulgari Residences v Courtyard v Delta Hotels v Delta Hotels - All-Inclusive v Design Hotels v EDITION Hotels, v EDITION Residences v Element Hotels v Fairfield v htps:mgscloud mariol.comstandards?id=1810 ity Table AP EUR MEA 4 8°68 S 1991622, 10:02 PM Global Ani-Bribery and Ant-Corrupton (US. Foreign Gorupt Practoes Act and U.K. Bribery Act) (MIP-07) - Ml Standards Four Points v ’ v v v Gaylord Hotels v v v v v Headquarters v v v v v JW Marriott v v v v v JW Marriott - All-Inclusive v ’ v v v JW Marriott Residences v v v v v Le Meridien v v v v v Le Meridien Residences v v v v v Marriott Executive Apartments v v v v v Marriott Hotels v v v v v Marriott Hotels - AlLInclusive v v v v v Marriott Residences v v v v v BRAND NAME us/ CAN CALA AP EUR MEA Marriott Vacations Club v v v v v MOXY Hotels v v v v v Protea Hotels by Marriott v v v v v Renaissance Hotels v v v v v Residence Inn v v ¥ v v Ritz-Carlton Reserve v v v v v Sheraton Hotels, v v v v v Sheraton Residences ¥ v ¥ v v SpringHill Suites v v v v a St. Regis Hotels v v v v v St. Regis Residences v ’ v v v The Luxury Collection v ’ v v v The Luxury Collection - All Inclusive htps:mgscloud mariol.comstandards?id=181091622, 10:02 PM Global Ani-Bribery and Ant-Corrupton (US. Foreign Gorupt Practoes Act and U.K. Bribery Act) (MIP-07) - Ml Standards The Luxury Collection Residences ‘The Ritz-Carlton The Ritz-Carlton - All-Inclusive ‘The Ritz-Carlton Club The Ritz-Carlton Residences The Ritz-Carlton Yacht Collection TownePlace Suites Tribute Portfolio Tribute Portfolio - All-Inclusive W Hotels W Hotels - All-Inclusive W Residences Westin Hotels Westin Hotels - Al-inclusive Westin Residences 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, Fumiture, 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 Applicability: Associates at all brands, all regions Key Responsibilities Sect a training) is responsible for policy administration, Policy Owner: (unless otherwise stipulated, compliance monitoring, implementation, and Senior Vice President, Global Compliance Counsel & Privacy Officer (Kimberly Shur) htps:mgscloud mariol.comlstandards?id=1810 3991622, 10:02 PM {Global Ani-Bribery and Ant-Corrpton (US. Foreign Gorupt Practoes Act and U.K. Bribery Act) (MIP-07) Ml Standards Policy Approver: (unless otherwise Executive Vice President, General Counsel (Rena Reiss) stipulated, is responsible for approval of exceptions) 1. Policy Itis the policy of Marriott International, Inc, ("Marriott” or "the Company") to comply with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act ("FCPA") and the U.K. Bribery Act. In addition, many countries have enacted their own anti-corruption laws and thus it is increasingly important to ensure that, in complying with this Policy, you are familiar with the laws and regulations that apply to you and your area of responsibility. This Policy applies to our business conducted around the world and prohibits all forms of bribery in both the public and private sectors. It is against the law and Company policy to promise, offer, give, or authorize, directly or indirectly, a bribe or anything of value to any person, including any government official, employee of, or representative of, a state-owned or controlled entity, in order to obtain or retain business or gain any other type of business or competitive advantage for Marriott. These payments are prohibited whether they are called “kickbacks,” “facilitation payment “bribes”; for purposes of this Policy, all such payments are referred to as “bribes.” This prohibition against offering, promising or paying bribes also applies to all third parties who provide services and act on Marriott's behalf, such as business partners, consultants, contractors, vendors, suppliers or agents. This Policy likewise covers the receipt of a bribe by, or for the benefit of, a Marriott associate. The Information provided below is only a summary of the FCPA and the U.K. Bribery Act and does not cover every aspect of those or other applicable laws. Marriott publishes and provides amplifying guidance and training related to these anti-corruption laws. Questions that are not specifically answered by this Policy can be resolved by referring to other sources published on the Company's intranet, such as the FAQs referenced at the end of this Policy, or by contacting Marriott's Law Department for guidance. 2. U.S. Foreign Corrupt Practices Act A. Anti-Bribery ‘The FCPA prohibits giving or offering anything of value to non-U.S. government officials and employees for the improper Purpose of influencing any decision to benefit the Company. The FCPA also prohibits giving or offering anything of value indirectly through third persons if the payor has knowledge or strong suspicions that those third persons intend to make prohibited payments. ‘The FCPA's anti-bribery provisions are broadly written. A bribe can be anything of value given in an attempt to influence: a person's actions or decisions in order to gain or retain a business advantage and can include: + cash + gifts htps:mgscloud marriott. comstandards7id=1810 4991622, 10:02 PM Global Ani-Bribery and Ant-Corrupton (US. Foreign Gorupt Practoes Act and U.K. Bribery Act) (MIP-07) - Ml Standards + meals + entertainment + transportation + rooms + spa or health club access + discounts or vouchers + excessive promotional activities + Marriott Bonvoy points or airline miles + Marriott Bonvoy status upgrades * political or charitable donations + employment or business opportunities The FCPA sets no minimum value for what can constitute a bribe, Under the FPA, the definition of a foreign official is broad and includes government officials from outside the United States and its territories. A foreign official includes any elected or appointed government official or government employee from any of the following entities or anyone acting in an official capacity on behalf of these entities: a. Any government, government agency, department or branch (including the military and members of the ruling Royal families); b. Any government ministry or bureau (including ministries of tourism or government-controlled visitors bureaus); ©. Any federal, state, local or municipal level of government; d. Any embassy or consulate of any country; . Any public international organization, such as the World Bank or United Nations; and f. Any government-owned or controlled business or enterprise or quasi-government body SOEs, including state- ‘owned or public universities. Foreign officials also include candidates for public office and party officials. ‘Additionally, be mindful that a gift given to a private citizen may also violate commercial bribery laws in some countries, as well as Marriot's policies concerning gifts and entertainment stated in MIP-75, Please ensure you are familiar with any commercial bribery laws that apply to you and your area of responsibilty For guidance regarding government officials in the United States and its teritories, please consult MIP-80. B. Books and Records In addition to prohibiting bribery of foreign officials, the FCPA also requires that a corporation's books, records and accounts be kept "in reasonable detail’ to "accurately and fairly reflect” its business transactions. The requirement to be accurate and complete applies to all books and records and encompasses expense reports, invoices and all business- related documents. htps:mgscloud marriott. comstandards7id=1810 5991622, 10:02 PM Global Ani-Bribery and Ant-Corrupton (US. Foreign Gorupt Practoes Act and U.K. Bribery Act) (MIP-07) - Ml Standards Its never appropriate to mischaracterize transactions in the Company's books and records. 3. U.K. Bribery Act Similar to the FCPA, the U.K. Bribery Act prohibits bribery of foreign public officials for the improper purpose of influencing any decision to benefit the Company. The U.K. Bribery Act further prohibits the bribery of any person for the improper purpose of influencing any decision to benefit the Company thus this law is broader than the FCPA as it specifically prohibits bribery in the commercial context. Under the U.K. Bribery Act, both the bribe giver and the bribe recipient can be subject to liability, including criminal prosecution, The U.K. Bribery Act also mandates that adequate procedures must be adopted by a company to prevent bribery. The law holds companies, such as Marriott, strictly responsible for falling to prevent a bribe from being paid to obtain or retain business or to gain a business advantage. 4. Roles & Responsibilities Itis the responsibilty ofall officers, directors, associates, and other persons acting on behalf of Marriott (collectively, ‘associales") who may deal with employees of foreign governments, state-owned entities or commercial entities to become familiar with the restrictions imposed by the FCPA, U.K. Bribery Act and any other applicable commercial bribery or anti-corruption laws. Associates shall refrain from giving, promising or authorizing anything of value, directly or indirectly, to a foreign official or to any person in order to obtain or retain business or gain any other type of competitive advantage All associates are responsible for accurately recording all business transactions and keeping complete and accurate books and records of business expenditures, including expense reports. Associates are required to accurately document the purpose of a transaction, the provider or recipient of funds, the accounts to and from which funds are transferred and the entities and departments responsible for particular transactions. In addition, managers who are responsible for supervising other associates have a special responsibility to ensure that associates who report to them understand and comply with all the anti-corruption laws that may be applicable, including the FCPA and the U.K. Bribery Act. 5. Governance and Training A. Legal and Ethical Steering Committee (LESC) and Legal and Ethical Compliance Councils (LECCs) ‘As explained in greater detail in MIP-12 (‘Legal and Ethical Compliance Program’), the LESC and Continent's LECC are responsible for ensuring the further development and implementation of an overall legal and ethical compliance program incorporating, at a minimum, compliance with this Policy, B. Finance and Internal Audit The Finance organization and the Internal Audit Department have shared responsibility for implementing and monitoring Proper accounting controls and procedures as may be necessary to assess compliance with the applicable law and htps:mgscloud marriott. comstandards7id=1810 ee91622, 10:02 PM Global Ani-Bribery and Ant-Corrupton (US. Foreign Gorupt Practoes Act and U.K. Bribery Act) (MIP-07) - Ml Standards regulations, Internal Audit will take appropriate steps to evaluate compliance with this Policy and, as appropriate, ensure reports to the Board of Directors and Audit Committee are timely submitted. ©. Training The Law Department shall oversee the implementation and periodic updates of a training program to ensure compliance with this Policy. The LECCs in each Continent are responsible for coordinating with the Law Department to oversee the development and implementation of a training program to help educate associates and ensure compliance with this Policy. A training program is available in the Digital Learning Zone (DLZ) for associates in relevant positions to be utilized as deemed necessary by each Continent President or Business Unit EVP. in order to provide reasonable assurances that the objectives of this Policy will be achieved. Each Continent CFO will be accountable for sponsoring the training and will collaborate with the Continent CHRO to take proactive steps to monitor and ensure satisfactory completion rates for required training. For Corporate HQ and other above property groups, the Law Department will provide guidance to the VP, Law Department HR, who will collaborate with the appropriate Global HR Officers to publish relevant training communications. Global HR Learning and Development will monitor and periodically report training completion rates globally to the Continent CHROs, Global HR Officers, and the VP, Law Department HR. 6. Policy Compliance and Reporting Violations or Suspicious Activity AS a publicly-traded U.S. company with extensive global operations, the Company is committed to conducting its business in accordance with all applicable laws, rules, and regulations and the highest standards of business ethics Compliance with this Policy is part of that responsibilty. All associates must act in accordance with this Policy and with the Company's commitment to follow all applicable anti-corruption and anti-bribery laws, Violations of this Policy may lead to disciplinary action, up to and including immediate termination of employment and referral for prosecution, Violations of this Policy may result in criminal prosecution or civil sanctions against the individuals involved and the Company. Penalties can include significant jail time, significant fines, disgorgement of profits, the risk of private lawsuits, as well as reputational damage and loss of goodwill. Under certain anti-corruption laws, the Company is not permitted to, and will not, reimburse associates for any monetary fines imposed on the person as a result ofa violation. Itis the responsibility of all associates to report any suspected or actual violation of this Policy. If an associate becomes aware of any activity that may violate this Policy, including any situation where a request or offer is made for a bribe, kickback or any other payment the propriety of which is questionable, the associate is required to immediately report such information to his or her manager, the Law Department or Internal Audit. Associates may also report a known or suspected violation of this Policy by using the Company's Business Integrity Line. The Company respects the confidentiality of associates who report a known or suspected violation and has a "No Retaliation” policy for associates ‘who raise a concer in good faith or with reasonable grounds to believe the information reported is accurate. 7, Documents Associated with this Policy + A Resource Guide to the U.S. Foreign Corrupt Practices Act, published by the U.S. Department of Justice and Securities and Exchange Commission 2020 (PDF) htps:mgscloud marriott. comstandards7id=1810 199118722, 10:02 PM ‘Global Ani-Sebery and Ant+Corupton (U.S. Foreign Gorrpt Practices Aet and UK. Brbery Act (MIP-07) Ml Standards + The U.K. Bribery Act 2010 Guidance, published by U.K. Ministry of Justice + FAQs on Interacting with Non-U.S. Governments: Compliance with Anti-Corruption and Anti-Bribery Laws (PDF) + FAQs on Interacting with Non-U.S. Governments: Compliance with Anti-Corruption and Anti-Bribery Laws (Traditional Chinese Language Version) (DOC) + FAQs regarding Marriott Bonvoy Events (PDF) + Legal and Ethical Compliance Program (MIP-12) + Gift & Entertainment Policy (MIP-75) + Interaction with Government, Political Activity, and Political Contributions in the United States (MIP-80) Note: in the case of proposed gifts, compliments, meals, entertainment and contributions to government officials or political persons in the United States and its territories, please consult MIP-80 and coordinate with Marriott's Government Affairs Department before taking any action. EFFECTIVE: JANUARY 01, 2005 | PUBLISHED: JANUARY 01, 2005 Irthis document is older than December 15, 2022, visit Marriott Global Source to ensure you have the most up-to-date version ofthis standard, MARRIOTT CONFIDENTIAL AND PROPRIETARY INFORMATION ‘The contents of this material ara confidential and propretary to Marriot Inerational, Inc. and may not be reproduced, disclosed, distributed or used without the express permission ofan authorized reprasantaive of Marriot. Any olher use is expressly prohibited htps:mgscloud marriott. comstandards7id=181019118722, 10.02 PM Global Ani-Bribery and Ant-Corrupton (US. Foreign Gorupt Practoes Act and U.K. Bribery Act) (MIP-07) - Ml Standards 99