91622, 10:04 PM
This content matches your MGS Profile.
Business Relationships with Principal Independent Auditor and
Employees (MIP-13)
MARRIOTT INTERNATIONAL POLICY (MIP)
REVISED: FEBRUARY 16, 2022 |
‘Business Relationships with Principal Independent Auditor and Employees (MIP-13)- Ml Standards
REVIEWED: FEBRUARY 09, 2022
Region & Brand Applicability Table
BRAND NAME Us/ CAN
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:mgscloud mariol.comslandards?id=1832
AP
EUR
MEA
4 6086
‘6
wr91622, 10:04 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:mgscloud mariol.comslandards?id=1832
v
v
US/ CAN
v
v
CALA
v
v
AP
‘Business Relationships with Principal Independent Auditor and Employees (MIP-13)- Ml Standards
v
v
EUR
MEA
an91622, 10:04 PM
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 - All-inclusive
Westin Residences
v
¥ v
¥ ¥
¥ ¥
v ¥
¥ v
v ¥
¥ ¥
v ¥
v
v v
v ¥
¥ v
¥ ¥
¥ v
v ¥
‘Business Relationships with Principal Independent Auditor and Employees (MIP-13)- Ml Standards
v
6 6 6 6 8 6 KK HK
‘
4
4 48
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
Sect
Hl
training)
is responsible for policy administration,
Policy Owner: (unless otherwise stipulated,
‘compliance monitoring, implementation, and
Chief Audit Executive (Keri Day)
htps:mgscloud mariol.comslandards7id=1832
a791622, 10:04 PM ‘Business Relationships with Principal Independent Auditor and Employees (MIP-13)- Ml Standards
Policy Approver: (unless otherwise Audit Committee of the Board of Directors
stipulated, is responsible for approval of
exceptions)
+ Chief Audit Executive (CAE) and Global Internal Audit Function have oversight responsibility for the
facilitation of policy updates.
1. Policy Overview
In the interest of maintaining the independence of the Principal Independent Auditor of Marriott International, Inc. (the
Company ), and in accordance with the requirements of the Securities and Exchange Commission and the Nasdaq
Exchange, the Audit Committee of the Board of Directors has adopted this policy for direct or indirect business
relationships with the Company's Principal Independent Auditor and for hiring current and former partners and
employees of the Company's Principal Independent Auditor. The Audit Committee may amend and/or supplement this
policy from time-to-time in any manner that is consistent with applicable laws, rules, and regulations.
2. Policy Statement
Unless approved by the Company's Chief Financial Officer and the Audit Committee of the Board, the Company may not
enter into any business relationship, including but not limited to, alliances, licensing arrangements, joint ventures, co-
ventures, sponsorships, co-marketing arrangements, cooperative arrangements, investing, lending, or borrowing monies,
or acting as a lessor or lessee. Business relationships do not include the performance by our Principal Independent
‘Auditor of audit or other professional services that have been pre-approved by the Audit Committee of the Board of
Directors in accordance with MIP-70 or services provided to the Company's Principal Independent Auditor and its
employees in the normal course of business.
The Company may not hire any Auditor Employee who served as an Engagement Team Member during the Annual
Engagement Period preceding the annual engagement period that includes the date (or proposed date) of initial
employment of the candidate into a Financial Reporting Oversight Role.
The Company may not hire any other person who was an Auditor Employee during the previous two (2) Annual
Engagement Periods preceding the Annual Engagement Period that includes the date (or proposed date) of intial
employment of the candidate into any Financial Reporting Oversight Role, a position at or above the director level within
the Company's Global Finance organization, or other position at or above the vice president level, unless approved by
the Company's Chief Financial Officer.
3. Roles and Responsibilities
3.4. Chief Financial Officer
In granting, any approval under this policy, the Chief Financial Officer shall consider the appropriate concentration of
Auditor Employees within the Company's financial reporting function. The Chief Financial Officer shall inform the Audit
Committee on a quarterly basis of hires of Auditor Employees made with his/her approval.
3.2. Internal Audit Department
htps:imgscloud mariol.comlslandards7id=1832 an91622, 10:04 PM ‘Business Relationships with Principal Independent Auditor and Employees (MIP-13)- Ml Standards
The Internal Audit Department will survey, at least annually, the Officers and members of the Board of Directors of the
Company regarding all business relationships (as defined in section 2. Policy Statement) between the Officers and
Directors and members of th
immediate family (spouse, parents and stepparents, children and stepchildren, siblings,
and all other dependents) and the Company's Independent Auditors.
3.3. Associates in a Financial Reporting Oversight Role
Associates who are in a Financial Reporting Oversight Role (except for non-management members of the Board of
Directors) and their immediate family members may not use the Company's Principal Independent Auditor for personal
tax services
4, Policy Compliance
Non-compliance with this Policy may present legal and financial liability for the Company and result in disciplinary action
Up to and including termination from employment.
5. Compliance Monitoring
Compliance with this Policy shall be monitored by the Chief Audit Executive at least annually as described in section 3.2
6. Definitions
As used in this policy:
Annual Engagement Period means the period beginning the day after the Company files its Annual Report on Form 10-K
for the previous year with the Securities and Exchange Commission and ending the day the Company files its Annual
Report on Form 10-K for the current year.
Auditor Employee means any current or former partner, principal, shareholder, or professional employee of the
Company's present Principal Independent Auditor and its affiliates, but does not include a person holding such a position
with a former independent auditor following the effective date of any change in the Company's independent auditor.
Engagement Team Member means any Auditor Employee who participated in the audit, review or other attest services
related to the Company's consolidated financial statements during the applicable Annual Engagement Period, including
audit partners and all persons who consult with others on the audit engagement team during such engagements
regarding technical or industry-specific issues, transactions, or events, provided that Engagement Team Member does.
not include any person, other than the audit engagement lead partner and concurring partner, who provided ten or fewer
hours of audit, review, or attest services during the applicable Annual Engagement Period,
Financial Reporting Oversight Role means a role in which a person is in a position to or does exercise influence over the
contents of the financial statements or over anyone who prepares them, and includes members of the board of directors,
the chief executive officer, the president, the chief financial officer, the chief operating officer, the general counsel, the
executive vice president, chief accounting officer, controller, chief audit executive (director of internal audit), director of
financial reporting, or treasurer, and any person who occupies any equivalent position.
htps:imgscloud mariol.comlslandards7id=1832 5791622, 10:04 PM ‘Business Relationships with Principal Independent Auditor and Employees (MIP-18)- Ml Standards
Principal Independent Auditor means the independent auditor who is engaged to opine on the Company's consolidated
financial statements and perform certain other services including audit, audit related, tax and other services other than
those prohibited non-audit services as defined by the Securities and Exchange Commission.
7. Documents Associated with this Policy
‘Supporting Documents
+ Audit Committee Pre-Approval of Independent Auditor Fees and Services (MIP-70)
EFFECTIVE: JANUARY 07, 2005 | PUBLISHED: JANUARY 01, 2005
this document is alder than December 15, 2022, visit Marriot Global Source to ensure you have
standard,
MARRIOTT CONFIDENTIAL AND PROPRIETARY INFORMATION
‘The contents of his material are confidential and propretay to Martiot Intemational, Inc, and may not be reproduced, disclosed, distributed or
used without te express permission ofan authorized representative of Marriot. Any other useis expressly prohibited
12 most up-te-date version of this
htps:imgscloud mariol.comlslandards7id=1832 or19118722, 10:08 PM
Business Relationships with Principal Independent Auditor and Employees (MIP-13) - MI Standards
WT