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Contributions, Community Engagement and Guidelines on Codes of Conduct Related to Charities (MIP-18) MARRIOTT INTERNATIONAL POLICY (MIP) REVISED: MARCH 19, 2021 Contributions, Community Engagement and Guidelines on Codes of Conduct Relates to Charives (MIP-18)- MI Standards REVIEWED: JANUARY 25, 2021 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 htps:imgscloud mariol.comlslandards?id=1837 AP EUR MEA 4 6086 ‘6 ant91622, 10:06 PM Four Points Gaylord Hotels Headquarters JW Marriott JW Marriott - All-Inclusive JW Marriott Residences Le Meridien Le Meridien Residences Marriott Executive Apartments Marriott Hotels Marriott Hotels - All-inclusive Marriott Residences BRAND NAME Marriott Vacations Club MOXY Hotels Protea Hotels by Marriott Renaissance Hotels Residence Inn Ritz-Carlton Reserve Sheraton Hotels Sheraton Residences SpringHill Suites St. Regis Hotels St. Regis Residences The Luxury Collection ‘The Luxury Collection - All- Inclusive htps:imgscloud mariol.comlstandards?id=1837 v v US/ CAN v v CALA v v AP v v EUR a MEA Contributions, Community Engagement and Guidelines on Codes of Conduct Relates to Charies (MIP-18)- MI Standards ant91622, 10:06 PM Contributions, Community Engagement and Guidelines on Codes of Conduct Relates to Charies (MIP-18)- MI Standards The Luxury Collection v v Residences ‘The Ritz-Carlton v v The Ritz-Carlton - All-Inclusive v v The Ritz-Carlton Club v v ‘The Ritz-Carlton Residences v v The Ritz-Carlton Yacht Collection ¥ ¥ TownePlace Suites v v Tribute Portfolio v v Tribute Portfolio - All-inclusive v W Hotels v a W Hotels - All-Inclusive v v W Residences v v Westin Hotels v v Westin Hotels - All-inclusive v v 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 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 Applicability: Associates at all brands, all regions Key Responsibilities: Section Hl Policy Owner: (unless otherwise stipulated, is responsible for Policy administration, compliance monitoring, implementation, and training) Vice President, Social Impact and Public Affairs (Melissa Flood) Policy Approver: (unless otherwise stipulated, is responsible hitps:mgscloud mariol.comlslandards?id=1837 Executive Vice President and Global Chief ant916122, 10:08 PM Contributions, Community Engagement and Guidelines on Codes of Conduct Relates to Charies (MIP-18)- MI Standards for approval of exceptions) ‘Communications & Public Affairs Officer (Tricia Primrose) Senior Vice President & Associate General Counsel Legal Representation (If Necessary) (Bhavana Boggs) + Chief Audit Executive (CAE) and Global Internal Audit Function have oversight responsibility for the facilitation of policy updates, 1. Policy Marriott International, Inc. (*Marriott” or the "Company") recognizes that Marriott's profitability and business interests are closely related to the strength of the communities it serves. The Company's Social Impact and Public Affairs department focuses its resources on national and global organizations that adhere to the company's Serve 360 priorities, while Strategic Business Units (SBUs)/Divisions do the same on the local level. Company resources are also leveraged through Marriott's Business Councils, This policy provides guidelines and requirements for evaluating requests and/or supporting non-profit and similar community-focused efforts. Serve 360 Priorities 4. Nurture Our World © Support the vitality of children © Deliver aid and support to communities, especially in times of need © Advance the sustainability of our communities by investing in their natural resources 2, Sustain Responsible Operations Reduce environmental impacts © Build & operate sustainable hotels © Source responsibly © Mitigate climate related risk 3, Empower Through Opportunity © Partner to ensure workplace readiness and access to opportunity throughout our business, including our supply chain © Focus on diverse populations, youth, women, people with disabilities, veterans and refugees 4, Welcome All and Advance Human Rights © Promote peace, cultural understanding and the freedom to travel © Foster an inclusive environment for all Work to end human trafficking Hold our business partners accountable htps:imgscloud mariol.comlstandards?id=1837 ant91822, 10:06 PM Contributions, Community Engagement and Guidelines on Codes of Conduct Relates to Charives (MIP-18)- MI Standards 2. Requirements 2.1, Evaluating Requests This section establishes general requirements and guidelines for evaluating requests for monetary and non-monetary contributions made by the Company and its SBUs/divisions and hotels. Organizations and activities to be considered are those that: Note: ‘Support the Company's Serve 360 priorities and meet clearly defined business objectives; Present lasting and positive social impact, as well as serve real, broad-based community needs; Promote increased public awareness and community participation; Offer an opportunity to make a fixed-term commitment; Exhibit strong community backing; Demonstrate strong management and sound financial practice: Demonstrate abilty to report progress/impact data back to Marriott or appropriate funding stakeholder, Provide proof of non-profit or non-governmental organization status (in the U.S., this is under Section 501(0)(3) of the U.S. Internal Revenue Code); Comply with the U.S. Patriot Act, OFAC, and all applicable laws; For U.S. based organizations, voluntarily incorporate applicable provisions of the Sarbanes-Oxley Act; Demonstrate that contributions will go directly to benefit the community rather than toward administrative or fundraising expenses, unless expressly agreed to by funding stakeholder, and Reinforce the positive reputation of Marriott. Itis important that all contributions comply with the Company's Ethical Conduct (MIP-01) and the Business Conduct Guide (PDF). 2.2, Restrictions ‘Asa general policy, Marriott will not make charitable contributions or provide support for: Individuals; Loans for any purpose; Organizations that foster or practice discrimination on any basis, including race, color, national origin, religion, gender, gender identity, sexual orientation, age, abilty or veteran status; Organizations or activities connected with controversial social or political issues; Religious organizations, fraternal organizations, and other organizations when serving only their own membership; Foundations; Fundraising activities (i.e. courtesy advertisements, souvenir programs and giveaway products) rather than direct, contributions to charity Sole or substantial sponsorship of single performances, contests or exhibitions by cultural or sports groups; htps:imgscloud mariol.comlstandards?id=1837 sit91822, 10:06 PM Contributions, Community Engagement and Guidelines on Codes of Conduct Relates to Charives (MIP-18)- MI Standards Retirement of mortgages or accumulated operating debts; Projects or events that have been completed; Campaigns that focus on specific health and disease control issues Organizations that are ineligible under federal or state laws to receive tax-deductible donations and/or, Local, state or federal agencies or employees (excluding times of disaster and Marriott-initiated recognition for such groups). 2.3. Global Giving Guidelines Corporate-level monetary contributions for charitable purposes are approved and disbursed by the Company's Social Impact and Public Affairs Department (SIPA), and are budgeted annually to support organizations that align with the Company's priorities. SBUs and Division-level contributions for charitable purposes are approved by SIPA but are disbursed by the SBUs/Divisions and hotels. Requests for in-kind donations of hotel stays and other discounts are decided and fulfilled at the hotel level and should therefore be directed to the appropriate hotel/s rather than the corporate office (see Section 2.6, below). Please reference the externally-facing Global Guidelines for Charitable Giving and Philanthropic Engagement (PDF) on Marriott Global Source (MGS) and Serve360.marriott.com for further guidance or to share with inquiring entities 2.4, Business Council Contributions Through Marriott's Business Councils, the Company has established a network of market leaders to leverage resources and position Marriott as a positive contributor in its communities. The Strengthen Communities section of the Business Council Guidebook (DOC) provides guidance to help Councils support community programs that are consistent with corporate policies and priorities. Each Council is responsible for promoting, leading or endorsing involvement in local community initiatives, non-profit and non-governmental organizations (NGOs) that align with our Serve 360 priorities and for ensuring that they are consistent with Company policies and priorities. 2.5. Continental/Division/Unit or Business Council Cash Contributions Monetary contributions for charitable purposes within continental divisions and their local operations are limited and generally support activities that further Company policies and priorities. They should be disbursed following Marriott Policy (see Global Anti-Bribery and Anti-Corruption (MIP-07)) and the Global Guidelines for Charitable Giving and Philanthropic Engagement (PDF). Requests from owners to use owner's funds to make charitable contributions in the hotel's name, in lieu of the ownership entity name or the owner's name, are not consistent with Marriot’s policy. Charitable contributions using funds of ownership entities or owners should be completed by the owner in the owner or affliated ownership name, as applicable, and should not be made by Mariott associates or in the hotel's name. Note: Consideration of significant ($50,000 USD+) cash contributions (not including fundraising) must be coordinated with the Social Impact and Public Affairs Department to ensure consistency with Marriott's policy and to avoid duplication of efforts htps:imgscloud mariol.comlstandards?id=1837 ett91822, 10:06 PM Contributions, Community Engagement and Guidelines on Codes of Conduct Relates to Charives (MIP-18)- MI Standards 2.6, Non-Monetary (In-Kind) Contributions Complimentary or discounted accommodations, meeting rooms, catering services, surplus food and equipment (excluding technology), are approved and disbursed at the local level, following Marriott's guidelines and priorities for contributions. As a rule, Marriott's corporate office does not provide in-kind support to non-profits or individuals, nor does it cover travel expenses related to illness, hardship, sports events or competitions. Additional guidance on non-monetary (in-kind) contributions can be found within the Global Guidelines for Charitable Giving and Philanthropic Engagement (PDF) and Global Anti-Bribery and Anti-Corruption (MIP-07). Non-monetary contributions to political committees or candidates must be approved by the Government Affairs Department and are separately governed by Interaction with Government, Political Activity, and Political Contributions in the United States (MIP-80). 2.7. Volunteerism Marriott encourages its associates to participate in Company-sanctioned volunteer activities that are designed to benefit the community and align with the Company's Serve 360 priorities, Marriott sanctioned volunteer activities should be identified under the name of Marriott or one of its brands. Branding may include a banner, a team name, a t-shirt, and/or Company identification, or may be otherwise specifically announced as a volunteer activity being done on behalf of the property, brand or Company. Volunteer activities completed as an individual and not through property, brand or Company affiliation will not be considered Company-sanctioned volunteering and therefore should not be recorded in Just Report It (see Section 2,14, below). Managers should consult Marriott's guidance on Compensation for Volunteer Activities (PDF) or a Human Resources professional to determine whether volunteers must be compensated for time spent participating ina volunteer activity sponsored by Marriott 2.8, Board Memberships Our associates, particularly hotel executive team members, are often asked to serve on the boards of non-profit organizations as representatives of Marriott. SBU/Division and hotel associates should recelve approval from their manager before agreeing to serve on a board on behalf of the Company, while corporate headquarters associates should seek approval from both their manager and the Social Impact and Public Affairs Department before proceeding, Associates should be aware that the Company does not commit to making cash or in-kind contributions or provide volunteer support for non-profits that include Marriott associates as board members. In general, for board membership requests, we prefer to align our most valuable resource — our associates — with issue areas and Serve 360 organizations that have strategic importance to the Company. Individual board memberships made on behalf of personal commitments and causes do not require manager or Company approval. 2.9, Matching Gifts Due to limited resources and the Company's own charitable priori 1s, Marriott does not typically match charitable gifts, including those made by associates, hotels, business units, business councils, disciplines or continents. htps:imgscloud mariol.comlstandards?id=1837 mt91822, 10:06 PM Contributions, Community Engagement and Guidelines on Codes of Conduct Relates to Charives (MIP-18)- MI Standards In certain cases, Marriott Bonvoy may run guest-facing points matching promotions to Serve 360 corporate strategic partners. 2.10, Fundraising Fundraising for non-profit and non-governmental organizations (NGOs) may be subject to country, state and/or local regulations, and licensing and reporting requirements; check with appropriate authorities and Global Anti-Bribery and ‘Anti-Corruption (MIP-07) before engaging in any fundraising. Organizations must represent that they comply with all applicable laws, including the Foreign Corrupt Practices Act, U.S. Patriot Act, and all applicable laws and regulations in countries where support is provided. Additional guidance on fundraising contributions can be found within the Global Guidelines for Charitable Giving (PDF). Fundraising on-property by third parties is discouraged and subject to the Company's and applicable hotel's non- solicitation guidelines (see Section 2.13, below) 2.11, Guest-Facing Opt-Out and Opt-In Fundraising “Opt-in” fundraising is the practice where guests are asked their permission in advance to add a donation amount for a charitable organization to a sale. “Opt-out” is the practice of automatically adding a donation amount to a sale which requires the guest to request the amount be removed from their bill if not interested in making the donation. Marriott strongly discourages “opt-out fundraising. The exception to this is the "Check Out for Children” program which is an opt-out fundraising mechanism with specific brands in select regions benefitting UNICEF. Any other opt-out fundraising, whether promotional or on-folio, must have above-property Chief Financial Officer approval ‘Opt-in’ fundraising must be clearly and consistently communicated to guests with sensitivity to how the solicitation may affect the business relationship and after consultation with above-property Chief Financial Officer leadership The preferred method of fundraising, with approval of any owner or other vested parties, is for the business unit to make the donation from the sale price of the product 2.12, Political Contributions Monetary contributions to support free enterprise organizations, political organizations, political candidates or policy issue campaigns, must be approved and disbursed by the Government Affairs Department. Policies regarding interaction with government, political activity, and political contributions in the United States are also available in Interaction with Government, Political Activity and Political Contributions in the United States (MIP-80) All other political contributions must be administered or approved by the Government Affairs Department. 2.13, Solicit ion Except for annual fundraising for select non-profit partners, Marriott does not permit solicitation of associates by charitable organizations on Company property (see Associate Relations (MIP-02)). 2.14, Reporting on Marriott Global Source Online Reporting Tool htps:imgscloud mariol.comlstandards?id=1837 att91822, 10:06 PM Contributions, Community Engagement and Guidelines on Codes of Conduct Relates to Charives (MIP-18)- MI Standards ‘SBU/Divisions, hotels and Business Councils use Just Report It, Marriot’s online reporting tool to report their Volunteerism as well as cash and in. ‘ind support for non-profits. This information is regularly shared with our associates, guests, shareholders, business partners, the media, investors and organizations through our annual sustainat annual report, and award applications. 2.15, Request to Sign a Code of Conduct We operate in an increasingly complex global business environment in which a growing number of important stakeholders, including nonprofits and NGOs, customers, business partners and investors, are seeking greater responsibilty and transparency regarding the way companies operate and the impact companies have in the community. (On occasion, this includes a request for Marriott or our hotels to sign, and therefore become an official signatory of a «written set of societal principles and related business practices, often called codes of conduct, compacts or value chain procurement principles. When this request is made, the following applies: Protocol for Requests to Sign Another Organization's Code of Conduct 1, Associates should not sign such commitments on behalf of their hotel/business unit, without approval, as they can have broad implications for Marriott, its operations, associates and guests. When responding to such a request, associates should consult, at a minimum, with their manager and Law, Human Resources and Social Impact, for corporate review of the request 2. Determine and provide the appropriate information to share with the stakeholder to demonstrate our existing responsible business practices, Our social and environmental business practices are included in Marriot’s Serve 360 Report, our human rights, animal welfare and environmental policies and position statements can be found on the Serve 360 Policies and Position Statements page. Both Marriott's Serve 360 Report and our Serve 360 policies and position statements are available externally on Marriott.com and intemally on MGS. 3, When relevant, share Marriott's Global Procurement Supplier Conduct Guidelines (PDF) with interested stakeholders. 3. Roles & Responsibilities 3.1, Social Impact and Public Affairs Department Social Impact and Public Affairs (SIPA) is responsible for the activities outlined in the Requirements above. In addition, SIPA is responsible for the management of this policy and relevant MGS references and links. 3.2. Company Leaders, Hotel Leadership and Business Councils Marriott's Company Leaders, Hote! Leadership and Business Councils are responsible for compliance with this policy and appropriate communication and training associated with the requirements herein. Business Councils and associates should refer to the Social Responsibility & Community Engagement section of the Business Council Guidebook (DOC) for additional guidance and information. 4, Policy Compliance Failure to comply with this policy may lead to disciplinary action up to and including termination 4.1. Compliance Monitoring htps:imgscloud mariol.comlstandards?id=1837 ort91822, 10:06 PM Contributions, Community Engagement and Guidelines on Codes of Conduct Relates to Charives (MIP-18)- MI Standards Compliance with this Policy shall be monitored using existing processes outlined in this Policy. Information and compliance is communicated through a permanent reference and link on the MGS Welcome Page of the MGS Online Reporting Tool. 5. Documents Associated with this Policy ‘Supporting Documents: + Business Conduct Guide (PDF) + Compensation for Volunteer Activities (PDF) + Ethical Conduct (MIP-01) + Global Anti-Bribery and Anti-Corruption (MIP-07) + Global Guidelines for Charitable Giving and Philanthropic Engagement (PDF) + Associate Relations (MIP-02) + Interaction with Government, Political Activity, and Political Contributions in the United States (MIP-80) + Serve 360 Policies and Position Statements EFFECTIVE: JANUARY 07, 2005 | PUBLISHED: JANUARY 01, 2005 IFthis documents older than December 15, 2022, vist Marriot Global Source to ensure you have the most up-to-date version ofthis standard, MARRIOTT CONFIDENTIAL AND PROPRIETARY INFORMATION ‘The contents of this material are confidential and propretary to Marriot International, Inc. and may not be reproduced, disclosed, distributed or used without the express permission ofan authorized representative of Marriot. 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