Just like trust, respect is earned.

You must show respect to earn respect.

1-RHG Code of Business Ethics 2022

 CODE OF BUSINESS ETHICS
November 2022

ethics.radissonhotels.com

Dear Colleague,

At Radisson Hotel Group (“RHG/Radisson”), we care deeply about doing the right thing.
Together, we have proven that we can succeed—providing value to our clients and
shareholders and opportunities for our people —while being a powerful force for good. Our
shared commitment to operating with the highest ethical standards and making a positive
difference in everything we do is what makes RHG special.

Respect is the key to all our actions. Just like trust, respect is earned. You must show respect
to earn respect. Our Code of Business Ethics (the “Code”) shows how we want to be
perceived as a company. RHG’s reputation and continued success as a global hospitality
leader is grounded in the RHG’s commitment to business integrity and in our application of
consistently high standards to everything we do. Around the world, all our stakeholders have
the right to expect that the Radisson, its hotels, its brands, and all its team members act and
take positions on key issues of business ethics with a single voice.

With the Code, we want to help our team members make ethical behavior a natural part of
what we do every day—with each other, our clients, our business partners, and our
communities. Because our business relies upon integrity and good judgment, this Code and
related internal policies have been developed to provide all members of the Radisson family
with guidance on not only what is legal but also what is right.

The Code is more than just a document-it’s what we believe, how we live and how we lead.
It’s embedded in all we do. It’s how we improve our business performance and build on
Radisson’s reputation in the marketplace. The Code builds on our core values by providing
greater detail about expected behaviors and drives our culture of compliance, ethical conduct
and accountability.

Please take the time to familiarize yourself with the Code, so that you can understand how to
best incorporate it your everyday actions at Radisson.

Sincerely,

Federico J. González
President and CEO of Radisson Hotel Group

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CONTENTS

INTRODUCTION .................................................................................................................. 4

GUIDING PRINCIPLES ..................................................................................................... 4

SCOPE- WHO DOES THE CODE APPLY TO? ................................................................ 4

BUILDING TRUST AND CREDIBILITY ............................................................................. 5

REPORTING AND PROCEDURAL NEXT STEPS ............................................................ 6

BUSINESS ETHICS: LEGAL INTEGRITY............................................................................ 7

MAINTAINING FINANCIAL INTEGRITY............................................................................ 8

RELATIONSHIP WITH THIRD PARTIES ........................................................................ 10

TEAM MEMBER RELATIONS AND EXPECTATIONS .................................................... 14

CONFLICT OF INTEREST .............................................................................................. 15

RESPONSIBLE BUSINESS ............................................................................................ 16

SUPPLIERS .................................................................................................................... 16

CONFIDENTIALITY, DATA PROTECTION & PRIVACY ................................................. 17

COMPETITION/COMPETITIVE PRACTICES ................................................................. 18

PREVENTING BRIBERY AND CORRUPTION ............................................................... 18

ANTI-MONEY LAUNDERING AND FACILITATION OF TAX EVASION .......................... 22

TRADE SANCTIONS ...................................................................................................... 23

REPORTING TO RHG AND COMPLIANCE CERTIFICATION .......................................... 23

3-RHG Code of Business Ethics 2022

INTRODUCTION

GUIDING PRINCIPLES
RHG is committed to maintaining the highest standards of business ethics, honesty and
integrity in line with its Responsible Business program for social, ethical and environmental
responsibility. “The Code” – contains rules and guidelines for our business conduct and
responsibilities with regards to colleagues, customers, hotel owners, guests, suppliers,
agents, shareholders, authorities, media and the world at large.

All companies and team members of RHG must comply with the laws and agreements
applicable to operations and positions in the countries and jurisdictions where they operate.
RHG will not cause or allow any team member to take any action which would result in
violation of applicable laws or regulations. RHG will forego any business opportunity that
requires a violation of the rules of this policy. This means that each team member must be
familiar with and comply with the laws and regulations that govern their job tasks.

The Code in short encompasses the following:

1. We respect the law

2. We show respect for all persons in all situations
3. We think ethically
4. We act fairly
5. We do not discriminate against anyone for any reason
6. We are honest and transparent
7. We are loyal to our employer
8. We do not exploit company resources
9. We think of safety at all times
10. We take care of the Earth

SCOPE- WHO DOES THE CODE APPLY TO?

This Code applies to all officers, directors, team members and agents (third parties acting on
RHG’s behalf) of RHG and of all its subsidiaries and associated companies. For avoidance
of doubt, the Code is applicable to all hotels owned, leased and managed by RHG. The
management teams must be role models for all points of contact with internal and external
stakeholders. Everyone, to whom this Code applies, is expected to understand and act in
accordance with both the Code and the spirit of this Code. The Code will be enforced
promptly, consistently, and effectively. Violations by a team member may result in individual
disciplinary action, up to and including termination of employment, and perhaps legal liability.

We recognize that some business cultures have practices that may violate our core values
and ethics, such that upholding them may be uncomfortable, even challenging. Doing the
right thing often requires courage. Saying no to these practices does not mean we disrespect
those cultures. Business opportunities do not take priority over our reputation or our Code.

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The information in the Code cannot address every difficult situation that may confront
colleagues throughout the world. Nonetheless, the Code aims at serving its purpose for being
an important guide and providing an introduction to many of our key global policies, however
it may not cover everything that may be relevant to you. It is important to remember that there
may be other policies, procedures and requirements that apply to your role and which you
must comply with in addition to the Code.

If you have a question about the Code or, if you have a concern and the Code does not
answer your question or address your concern, please do not hesitate to raise your concern
or question. It is your responsibility to report any violations of our Code or applicable law and
bring potential problems to RHG’s in the manner set forth under the Code. No retaliation will
be taken against a team member for reporting a violation by others in good faith.

As a team member my role is to: As a team manager I have additional

responsibilities and my role is to:
 Know and understand the Code;  Lead by example and maintain,
 Act consistently with the Code, and if in promote, and act in accordance with
doubt seek guidance from my team the Code in my daily work;
manager, human resources manager,  Ensure that the Code is alive within my
or the legal department; and team;
 Demonstrate and live our values, rules  Ensure that I am familiar with the Code,
of conduct and behavior, and principles since my team members may come to
of action. me for advice and guidance on certain
issues listed thereunder; and
 Identify compliance risks and make the
appropriate decisions regarding issues
relevant to my area of responsibility.

BUILDING TRUST AND CREDIBILITY

The success of our business is dependent on the trust and confidence we earn from our team
members, customers and shareholders. Trust is the key to establishing an ethical
organization environment -- one that guides decisions and actions. Trust in business is the
cornerstone of relationships with customers, suppliers, team members, and others who have
dealings with an organization. Trust means to be reliable and carry through words with deeds.
Trust is gained when a team member follows through ethical intent with ethical action. Trust
becomes pervasive only if the organization’s values are followed and supported by top
management. By modeling the organization’s values, senior leaders provide a benchmark for
all team members.

We gain credibility by adhering to our commitments, displaying honesty and integrity and
reaching company goals solely through honorable conduct. It is easy to say what we must
do, but the proof is in our actions. Everyone working for us must have and apply sound
judgement guided by the highest personal standards of honesty and integrity in all matters
affecting our company. This is a matter of responsibility, confidence and trust.

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Operating in as many countries and cultures as we do, we acknowledge diversity as an asset.
Certain customs and moral codes vary quite dramatically in our markets. Sometimes laws
and regulations vary as well. It’s imperative that all our people abide by local and international
legislation. We recommend any team member with concerns or questions about the Code to
discuss these directly with their supervisor.

REPORTING AND PROCEDURAL NEXT STEPS

Reporting of Potential Breaches or Complaints and Ethics Hotline

All of the RHG team members have an obligation to familiarize themselves with applicable
laws relating to their job responsibilities and all RHG policies. Breach of the Code, RHG
policies or the law may give rise to disciplinary action up to, and including, dismissal.

In order to deal with the infringements of laws or the Code as well as matters pertaining to a
team member’s rights, obligations or working conditions we have established an
independently operated business ethics hotline to ensure that employees can share
information or complaints about concerns regarding malpractices and misconduct they may
have observed. These can be reported confidentially and anonymously by filling out a report
form at ethics.radissonhotels.com, in line with RHG’s Whistleblowing Policy. Depending on
the nature of the complaint and its confidential nature, such employee can also always involve
its supervisor or respective area responsible.

The business ethics hotline can be used to report concerns and request advice or guidance
about actions or behaviors that are:

 Not aligned with our values, our Code, or related ethics and compliance policies; or
 Not in compliance with applicable laws; or
 That may significantly affect vital interests of RHG and its affiliates.

The independent supplier of this service will ensure that the concern is swiftly brought to the
attention of the appropriate person or persons in RHG and ensure that the report and follow-
up is documented. The reporting system ethics.radissonhotels.com is duly registered with
authorities where applicable. Data storage, handling and case management procedures,
including information and notification requirements, are specified in written guidance.

We treat such matters seriously and will handle any such complaints in compliance with the
stated policies and values. No one shall be discriminated against or punished for reporting
actual or suspected infringements in good faith. All reports will be handled in line with the
below procedure and will be treated confidentially.

Ethics Leadership Group

RHG has established an Ethics Leadership Group to ensure compliance with the Code and
follow up on potential breaches and complaints. This group is represented by the Global

6-RHG Code of Business Ethics 2022

Senior Vice President, Responsible Business and Safety & Security; Executive Vice
President & Global Chief Resources Officer; Executive Vice President & Chief Legal Officer
General Counsel RHG and Vice President Internal Audit. The Ethics Leadership group can
delegate this representation in light of needs that may come to light in a particular factual
matrix at the CSO or ASO level. The Ethical Leadership Group members can be contacted
in case of questions or clarifications. Any potential breach or complaint that is lodged through
the external ethics hotline will be submitted to the Ethics Leadership Group.

Process for Disciplinary Action

Upon receipt of a complaint, either directly or through the ethics hotline, the Ethics Leadership
Group will decide how to proceed. If the complaint represents a potential breach of the Code,
then the process for action will continue to an assessment and investigation of the complaint.

The Ethics Leadership Group will conduct the assessments and investigations into potential
breaches of the Code on a case-by-case basis, taking into consideration the aspects such
as the establishment/hotel where the complaint was lodged, contractual arrangements,
severity of the offence, nature of events or frequency of the violation. The principles of
procedural fairness apply to managing and investigating the potential breaches of the Code.
These principles encapsulate an opportunity to be heard, the rule against bias (decision-
makers do not have a personal interest in the outcome) and the evidence rule (decisions are
based on evidence).

Investigations and subsequent actions are proportional to the extent of the potential breach
of the Code. Disciplinary actions will vary depending on the violation and may inter alia
include reprimand, suspension or termination for more serious offenses. RHG may take legal
action in cases of corruption, theft, embezzlement or other unlawful behavior.

On the basis of the facts and information presented, the Ethics Leadership Group will decide
whether the matter should be:
• dismissed;
• resolved locally with or without corrective actions;
• addressing any systemic issues that are identified; or
• Some matters may involve potentially corrupt conduct and/or potential criminal behavior.
These matters require referral to an appropriate agency, for example, the police or
relevant statutory body.

BUSINESS ETHICS: LEGAL INTEGRITY

As a global leader in hospitality and travel management, RHG has operations or contracted
partners in over 110 countries. RHG’s policy is to comply with all applicable laws and
regulations everywhere it does business, including (but not limited to) competition law, anti-

7-RHG Code of Business Ethics 2022

bribery laws, team member health and safety regulations, labor laws, data protection/ privacy
laws, non-discrimination laws, laws relating to trade sanctions and tax evasion, and anti-
money laundering laws. Certain laws extend beyond country borders. As a global company,
RHG is regulated by many different laws at the same time. If there is a conflict or question,
please contact the Legal department.

RHG team members shall not engage in any unlawful activity while conducting business or
performing their day-to-day RHG duties, nor instruct nor facilitate others to do so. Violations
of law can subject RHG and its team members to civil suits (damage awards or fines) and/or
criminal penalties (fines or jail sentences). RHG will not do business with partners, suppliers
or other third parties who do not require the same legal compliance from their team members.

RHG team members will work with the Legal department and be truthful and cooperative in
connection with inquiries and investigations by government officials and regulatory agencies.
When we work with governments as our clients, RHG team members will also comply with
special requirements associated with government transactions.

MAINTAINING FINANCIAL INTEGRITY

Every RHG team member is expected to conduct their business with integrity and high ethical
standards. This includes our commitment to truthfulness in billing, accounting and financial
reporting practices.

Accurately Document All Financial Transactions

Our financial records serve as the basis for managing our business and are important in
meeting our obligations to shareholders, clients, suppliers and other contracting parties. All
records must be clear, truthful, timely and accurate. These records are necessary for
substantiating compliance with tax, financial and other reporting requirements. In its financial
reporting, RHG shall ensure that all transactions are:

• Compliant with legal and regulatory requirements

• Reviewed as appropriate with financial advisors and auditors
• Properly authorized according to RHG’s policies

All accounting records, as well as reports produced from those reports, should accurately and
fairly reflect in reasonable detail RHG’s assets, liabilities, revenues and expenses. All
transactions should be supported by accurate documentation, in reasonable detail, and
recorded in the proper account and accounting period. All team members have a responsibility
to avoid false or intentionally misleading entries.

All funds, cash and other assets must be recorded and accounted for. Any variance from this
requirement is strictly prohibited. Accordingly, team members must pay attention to the
accuracy of information submitted by others that inter alia include Owners, Contractors,
Vendors and other associates.

8-RHG Code of Business Ethics 2022

Should you discover or suspect a false or misleading item in a financial report or entry, or in
any information provided to Enable’s auditors, you must report it immediately to your
supervisor or via the ethics.radissonhotels.com.

Example:
Expense An associate submits an expense report to his manager for approval. A meal
Report expense on the report does not include an explanation of its business
Accuracy purpose, and the receipt amount and date do not match those stated on the
expense report. The manager does not carefully review the report and
approves it for reimbursement.

When approving transactions, managers have a duty to ensure expenses are

valid, are properly supported, and have a bona fide business purpose. In the
present scenario, the associate and his manager are both responsible for the
inaccuracy of the expense report.

I have lost my meal receipts from a recent work trip. Can I substitute some
personal receipts of similar value to reclaim my expenses?

No, it’s never acceptable to falsify records like this. You should talk to your
manager to work out a solution.

Accurately Disclose Financial Information

In addition, in connection with the preparation of the audited accounts, all team members
should cooperate with internal and external auditors at all times. Under no circumstances
should any team member manipulate, mislead or fraudulently influence internal or external
auditors in such a manner as to affect their opinion of the audited accounts. Inaccuracies in
our financial information may undermine the confidence of our customers, investors, and
owners and harm our reputation. Further, inaccurate financial records could result in RHG
failing to satisfy legal, regulatory, or fiduciary obligations.

RHG conducts its business operations with honesty, reliability and integrity. RHG must speak
with one voice to third parties (such as the media, investors and financial analysts). Only
team members designated by the Chief Executive Officer, or the Chief Financial Officer are
authorized to make comments, disclosures or statements to third parties on RHG financial
policy, positions or reporting. Comments, disclosures or statements to third parties shall be
made in accordance with applicable information and communication policies within RHG.

While every effort is made to ensure that controls are in place to prevent fraud, RHG team
members must report all incidents of fraud to the Internal Audit department and Legal
department of the group.

If your job involves signing contracts or making other financial commitments, you must
comply with all contracting requirements and the principles set out in the Delegation of
Authority Policy – including who reviews and approves contracts, what types of provisions

9-RHG Code of Business Ethics 2022

to include or exclude, when to seek legal review and what recordkeeping obligations apply.
Please refer the updated Delegation of Authority policy on Hotelkit or the Intranet.

When in doubt, raise your concerns with a manager who has the authority to conduct further
inquiry.

RELATIONSHIP WITH THIRD PARTIES

Guest and Customer Relations

We are a company of diverse cultures serving diverse guests. We seek to understand our
unique global communities, and to create an environment of inclusiveness.

RHG’s goal is to create, develop and sustain strong and long-lasting relationships with our
guests, franchisees, partners, property owners, financial partners, suppliers and other third
parties by adhering to the Code and by striving to deliver a superior guest experience every
time.

Services and products should always be designed and delivered in line with agreed cost,
specifications and timescales. All statements and communications must be accurate.
Customers should be given what is promised and at the promised price.

RHG highly values the preservation of good relations with our guests and partners. Guest
and stakeholder satisfaction is fundamental to our future success. Misrepresentations about
RHG’s products and services may lead to costly legal action. A false claim, a small untruth, or
even a perception of dishonesty can jeopardize the loyalty and satisfaction of our customers

A team member’s interaction with a guest or potential guest will affect the guest’s experience
and perception of RHG, and all team members are expected to behave in a manner that
projects a positive image of RHG. This includes face-to-face personal interactions as well as
interactions by phone, email, social media and/or internet.

Giving and offering gifts, entertainment and hospitality

Please note that there are specific rules relating to giving or offering Gifts, Hospitality or
Entertainment to government or political party officials; please refer to the section 'Prevention
of Bribery and Corruption'.

Principle
Team members should never attempt to bribe or improperly influence the team members,
agents of, or others who may be acting for, any external party – including, but not limited to
customers, owners of hotels or other enterprises with which we want to do or retain business
– in an attempt to obtain/retain business, to gain any other benefit for RHG or to induce or
reward improper behavior.

10-RHG Code of Business Ethics 2022

However, RHG also recognizes that gift-giving (including reasonable and infrequent meals
and appropriate entertainment) to non-governmental customers, franchisees, owners, media
(to the extent not state-owned or controlled) or their team members may be appropriate and
acceptable under limited circumstances and following hospitality industry practice.

Conditions
When giving gifts is an expected and widely recognized cultural norm, a modest gift (other
than cash or any cash-equivalent) may be provided if, and only if, the following conditions are
complied with:

(i) It directly relates to the promotion or demonstration of RHG's services and products
or to promote successful working relationship with individuals or entities with whom
RHG maintains a business relationship;
(ii) It is not lavish or extravagant - rather, it must be of reasonable and modest value;
(iii) legally permissible under local law and not prohibited under the policies applicable
to the recipient, to the extent it is not flagged by the recipient;
(iv) provided on an infrequent basis;
(v) not prohibited under the policies applicable to the recipient i.e. to the extent it is
not flagged by the recipient;
(vi) provided solely for the purpose of building generalized goodwill and not for the
purpose, or with the expectation of receiving anything in return and given without
an express or implied understanding that the recipient or any other person is in
any way obligated by acceptance of the gift;
(vii) reasonable and proportionate to the business activity being undertaken;
(viii) It is given or received in a manner that will not improperly influence a business
decision;
(ix) It is approved in accordance with the rules set out in below in respect of i) Non-
Governmental Individuals and Entities and ii) Government and Public Officials;
and
(x) It is accurately and fully recorded on expenses reports and in accordance with the
RHG Gift and Entertainment policy.

Approval and Recordal Process

Anyone wishing to provide a gift that complies with the above, should follow the approval and
recordal process under the Gifts and Entertainment Policy available on HotelKit or the
Intranet.

To the extent it relates to the giving of complimentary rooms, the above conditions need to
be complied with and such gift giving needs to be in line with the company policy.

Example:
Offering A doctor from the University Hospital helped organize several online
Complimentary educational sessions on vaccination against corona virus for RHG
Stay team members. As a token of appreciation, the RHG has offered the
doctor complimentary stay at any of the RHG leased properties in
Belgium in line with the company policy.

11-RHG Code of Business Ethics 2022

 Is this allowed?

Yes, this is allowed, to the extent that the recipient doctor does not flag
the complimentary stay as going against his own code of business
ethics.

A potential Client who is an Owner of a chain of hotel properties and

with whom RHG intends on building a business relationship with, is
offered First Class fight tickets for an in-person meeting to discuss
business opportunities with the expectation that such treatment would
possibly be in favor of creating an opportunity for business.

Is this allowed?

No, in line with the basic principles set out in the Code, such an offering
is not allowed since it indicates that it has been offered with an
expectation of receiving something in return.

Receiving or being offered gifts, hospitality and entertainment

Principle
RHG recognizes that it is customary within the hospitality and travel industry for some
suppliers to offer to team members of RHG certain gifts or promotions.

Conditions

A. General Principle for Receiving Gifts or Promotions

RHG recognizes that team members may take advantage of gifts or promotions provided that
the following conditions apply:

(i) the gifts or promotions are legally permissible;

(ii) nothing specific can ever be expected in return;
(iii) it must be connected to a legitimate and generalized business promotional activity
or the performance of an existing contract and not from anyone who has or is
seeking a business relationship with RHG;
(iv) the gifts or promotions have been recorded and/or approved in line with the Gifts
and Entertainment Policy;
(v) the team member complies with any conditions set forth by the supplier;
(vi) the gifts or promotion is not in connection with or intended to create a commercial
advantage.

When a RHG team member receives a gift or promotion that is in compliance with the Code,
it is advisable for such team member to raffle it among department members.

12-RHG Code of Business Ethics 2022

 B. Customary Gifts

RHG recognizes further that customary meals, entertainment, or other forms of hospitality
from someone who has a business relationship with RHG is allowed where appropriate as a
business courtesy or local tradition to the extent these are reasonable, which is determined
as follows in addition to the above conditions under section A that apply:

(i) The customary gifts are reasonable in the context of the local economy in which
the meal or entertainment is to be provided;
(ii) it must be otherwise consistent with RHG’s policy including RHG Procurement
Policy which allows RHG team members to purchase at advantageous rates with
3rd Party vendors; and
(iii) when evaluating the reasonableness of the customary gift, the frequency with which
meals and/or entertainment are provided for a particular person must be taken into
account, as modest goodwill offerings, frequently provided, can become lavish and
improper over time.

In line with the Gift and Entertainment Policy, such customary gifts will be recorded in line with
said policy with no requirement to list any estimated value of the gift as long as it is deemed in
line with the above sections.

Example:
Receiving Gifts A vendor offers an RHG team member floor-level seats to a popular
sporting event. The vendor explains that he does not want anything in
return; he cannot attend the event, and he does not want the seats to
be wasted. The value of the tickets are more than 1500 Euros.

The RHG team member should ensure that the gift was offered not with
the intention to gain any improper advantage but in light of an ongoing
business relationship. Furthermore, in line with the Gift and
Entertainment Policy, for this particular gift, the RHG team member
should seek approval from an Executive Committee member, and the
gift should be recorded.

Receiving A potential franchisee partner invites an RHG team member to discuss

Hospitality business over dinner and insists on paying the entire bill.

Assuming the meal is not inappropriately lavish, the team member may
accept the meal.

Guiding Principle Summary

RHG team members must use common sense in giving and accepting gifts in the context
of business relationships keeping in view the rationale that is generally acceptable in the
relevant jurisdiction. Accepting gifts that could compromise objectivity in making decisions

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 for RHG, that creates the appearance of impropriety, or that violates the law must be
avoided completely.

Team members must employ best judgment practice in cases where they cannot decline
gifts without offending the gift-giver. In case of doubt on the part of the RHG team member,
ask a supervisor.

In line with the Gift and Entertainment Policy such gifts are required to be reported
depending on the jurisdiction of employment of the RHG team member.

TEAM MEMBER RELATIONS AND EXPECTATIONS

RHG seeks to maintain a culture that supports team member well-being and inclusion and is
committed to encouraging a positive working environment that meets and exceeds legal
requirements.

RHG expects team members to behave politely and respectfully in all interactions. This
includes in-person interaction as well as interactions by phone, email, social media or
internet. All team members should demonstrate integrity, professionalism and respect for
those with whom they work. We do not tolerate behavior that threatens the well-being of any
colleague, customer or other persons. RHG team members must never verbally or physically
mistreat others or engage in offensive behavior. This encompasses sexual or other
harassment, abusive or intimidating treatment, inappropriate language or gestures,
discrimination and any other conduct that interferes with a team member’s ability to do their
job – regardless of whether or not the behavior is illegal.

We recruit individuals without regard to race, gender, age, disability, marital status, sexual
preference, nationality, caste, affiliation with a political organization, national origin, veteran
status, religious or union organization, minority group or any other characteristic protected by
law.

RHG expects that every team member shall ensure that all our cultural beliefs are practiced
and will uphold the principles set forth in this Code.

Our cultural beliefs are:

• We deliver memorable moments every day, everywhere, every time.

• We enjoy serving with our “Yes I Can!” spirit.
• We grow talent, talent grows us.
• We are many minds, with one mindset.
• We value open and direct interactions to build trust.
• We believe anything is possible.
• We have fun in all that we do.

14-RHG Code of Business Ethics 2022

CONFLICT OF INTEREST

As a general rule, RHG team members should never use or attempt to use their position
within RHG to obtain any improper personal benefit for themselves, their families or for any
other person or entity – including RHG itself.

RHG does not accept situations that could create a conflict, or the appearance of a conflict,
between RHG’s interest and the team member’s personal interests.

Team members of the central office (“CSO”) and area offices (“ASOs”), business units and
hotels of RHG may, however, encounter situations on the job or in their free time where their
own personal interest, or that of persons or companies in which they have ties or links
(financial or otherwise), may conflict with RHG’s interest and such conflicts may take many
forms.

Although RHG recognizes and understands that its team members may take part in activities
outside their jobs and we respect our team members’ privacy when it comes to personal
conduct outside of work, team members may not ask for or receive any payment, other than
for legitimate business reasons, from actual or potential franchisees, partners, property
owners, financial partners, competitors or suppliers.

No team member may use RHG proprietary information or other confidential information
entrusted to RHG to obtain any improper personal benefit for themselves, their families or
any other person.

The following are examples of such conflicts of interest, which an RHG team member should
not get involved in:

(i) an individual deriving personal gain through RHG information or business;

(ii) owning (yourself, your spouse or a family member residing with you) a financial
interest in suppliers to or competitors of RHG (except for stock in publicly traded
companies, which may not exceed 1%);
(iii) in relation to suppliers of RHG, to the extent an RHG team member is involved or
has influence in the decision-making of RHG to appoint such supplier, such RHG
team member should not accept services from such supplier;
(iv) contracting a supplier, either directly by RHG or through a contracting party of
RHG, that is a related party of an RHG team member whereby the team
contracting the work with such supplier is in a direct reporting line to such RHG
team member;
(v) accepting outside compensation for work already being paid for by RHG; and
(vi) serving as director, officer, team member or consultant of a supplier to or
competitor of RHG.
(vii) In the context of their professional activities, all RHG team members must act at
all times in the interest RHG. While respecting the personal life of its team
members, RHG expects them to proactively avoid any apparent or real conflicts
of interest. Any RHG team member who is a family member or relative of another
RHG team member holding a position of leadership and is in a direct reporting

15-RHG Code of Business Ethics 2022

 line to such RHG team member holding said leadership position must disclose
this immediately to the Area HR Department.

If there is any doubt as to whether there may be an actual or perceived conflict of interest, it
should be disclosed to a member of the Ethics Leadership Group to determine how the matter
should be resolved.

RESPONSIBLE BUSINESS

RHG is committed to assisting our guests in addressing environmental issues, as well as in

managing and reducing their environmental impact.

RHG expects its suppliers to be aware of and address environmental issues as well.

RHG is committed to ensuring that no modern slavery, human trafficking, or other human
rights violations exists in its business or supply chains. RHG has signed the United Nations
Global Compact (The Compact). The Compact asks companies to embrace, support and
enact, within their sphere of influence, a set of core values in the areas of human rights, labor
standards, the environment and anti-corruption. RHG has long supported the End Child
Prostitution, Child Pornography and Trafficking of Children for Sexual Purposes (ECPAT)
Code of Conduct to protect children against sexual exploitation in travel and tourism. All team
members are expected to abide by the Compact and the ECPAT Code.

Under no circumstances may RHG funds, property (including electronic devices and RHG-
supported technology) or personnel be used to further or support activities prohibited by the
Compact, ECPAT Code or this Code. RHG has no tolerance for human rights abuses, nor
for any form of modern slavery, either in our organization, or in our supply chains.

SUPPLIERS

RHG relies on its suppliers to provide quality services and products to our guests. It is critical
that all RHG suppliers share our commitment to conducting business with high ethical
standards.

RHG team members should have an understanding of our supplier’s businesses and
operations and shall conduct business with suppliers in accordance with our contractual
obligations. In such interactions, team members are also expected to treat suppliers with
respect and exhibit the same level of ethical conduct that we expect of the supplier.

Team members who interact with suppliers shall ensure that suppliers are reputable and
qualified. They shall also articulate RHG’s supplier management process, procedures and
timescales, enabling suppliers to understand the expectations, requirements and criteria of
RHG in selecting a supplier during the bid process.

RHG Team members must exercise careful scrutiny over suppliers and service providers that
may be using the labor of people coerced into working by threat or intimidation; comply strictly

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with the minimum legal working age in each host country; and exercise the utmost care and
attention in choosing suppliers and service providers.

Confidential information received from suppliers will be maintained in confidence.

CONFIDENTIALITY, DATA PROTECTION & PRIVACY

We protect the confidentiality of information to which we have access in the course of our
business in accordance with applicable law and contractual obligations. This information
includes but is not limited to, RHG trade secrets, financial data, products, personnel
information, business transactions and information entrusted to RHG in confidence by third
parties – as well as information concerning our team members, clients, guests, travelers,
suppliers and shareholders. We are all responsible for protecting this confidential
information regardless of the form in which it comes to us (in conversations, paper copy,
electronically, etc.).

We require written confidentiality agreements (also called non-disclosure agreements) with

any party to whom we will be disclosing confidential information.

Confidential information belonging to third parties obtained through previous employment or

unethical or unlawful means, must not be communicated to RHG. Likewise, RHG team
members may not divulge any confidential information to third parties, whether during or
following employment with one of RHG’s hotels or business units. When in doubt, you should
treat information as confidential and consult the Legal department for guidance.

In addition, RHG needs to collect and process personal data of individuals in order to
effectively run its businesses. We consider compliance with all applicable data protection
laws to be crucial to both RHG corporate values and the success of our business. RHG
therefore undertakes to comply with all applicable data protection and privacy laws with
respect to guests, team members, and other individuals’ personal data, including with regards
to the international transfer of such information and any laws related to specific types of data,
such as medical or credit card information. This requires all team members and other
individuals working for RHG to ensure that whenever they handle personal data in the context
of their duties, they do so in accordance with the relevant legal requirements and all relevant
RHG policies and procedures, notably including the General Radisson Personal Data
Handling Policy and the Hotel Personal Data Handling Policy which are available in the
‘GDPR’ section on the Intranet.

RHG expects each team member to always personal data as follows:

(i) access and process personal data only to the extent necessary for the purposes
for which the data was collected, and only when directly related to his/her duties;
(ii) store personal data in a secure way; and
(iii) disclose and transfer personal data only with data processing agreements or
appropriate safeguards in place, where necessary, and in accordance with all
applicable RHG policies and procedures or with prior approval of the competent
person.

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RHG team members must be careful when handling computers, software, data and e-mail
messages to ensure that no inadvertent access to sensitive information is allowed. For
instance, computers should be physically protected, and passwords should not be divulged.

COMPETITION/COMPETITIVE PRACTICES

RHG complies with the antitrust and competition laws of the many countries where we do
business. These laws strictly forbid exchanging sensitive competitive information (such as
any information relating to pricing, customers, or strategies) with competitors as well as
entering into agreements that restrict competition. As part of our efforts to ensure compliance
with these laws, we will have no agreements, understandings or plans with competitors that
limit or restrict competition – including price fixing, allocation of clients or geographic markets,
agreements to boycott or refuse to deal with certain customers or suppliers, or agreements
to coordinate terms or conditions for wages, benefits or other compensation. If you become
aware at any time about discussions on restricting competition, you must immediately inform
the Legal department.

In addition to risks arising from dealings with competitors, you should also be mindful of the
risks associated with agreements with our business partners, suppliers and customers,
including clauses that set minimum prices, clauses that provide for exclusivity, or price parity
clauses.

These laws are often complex and global in reach, and you should seek the advice of the
Legal department before taking any action that could be considered anti-competitive.

Example:
Discussions A manager from a competing hotel tells me about an increase in the
with price of his rooms during the upcoming summer period. This is
Competitors obviously valuable information. Who can I talk to about it and what can
I do with it?

Any exchange of sensitive information with competitors, especially

about pricing or discounting policy, is unlawful and may distort
competition. Such conversations must be ended immediately, and
information received must not be disclosed to anyone. Given the
seriousness of such a situation, the matter must be reported without
delay to your manager and the Legal Department

PREVENTING BRIBERY AND CORRUPTION

RHG has zero tolerance of bribery. Every team member must fully comply with the
requirements of this Code as well as applicable laws relating to bribery and corruption
including without limitation the US Foreign Corrupt Practices Act (FCPA) and UK Bribery Act
(UKBA). All persons conducting business on behalf of RHG, or for the benefit of RHG, must

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always act in a manner consistent with RHG’s commitment to doing business with integrity,
including by avoiding bribery-related conduct or corruption of any kind.

RHG’s policy is to comply with all applicable laws and regulations, everywhere it does
business. This policy extends to all of RHG’s domestic and foreign operations, including
operations conducted by subsidiaries, consultants, agents, advisors, vendors, intermediaries,
any majority – owned or controlled affiliates – including joint ventures or any other parties
with whom we may partner, or which may act on our behalf. Any violation of anti-corruption
laws is serious and puts both RHG and the persons involved at risk of significant monetary
fines, criminal penalties (including prison time for individuals) and severe damage to RHG’s
reputation.

No team member shall be involved, directly or indirectly, in giving, making, offering, receiving,
requesting, authorizing, allowing or facilitating bribes (involving money or anything else of
value) to any person to obtain or retain business for RHG or secure any other improper
advantage. This prohibition is very broad and covers: (i) cash payments; (ii) non-cash
payments, benefits and favors; and (iii) otherwise legitimate business expenditures, such as
gifts, entertainment, and hosted travel or training, if they do not meet the requirements of this
policy. RHG prohibits these payments and transfers of value whether they are made directly
or indirectly through third parties, such as consultants, agents, advisors, vendors,
intermediaries, and joint venture partners. No team member may assist, aid or facilitate third
parties engaging in bribery.

In addition to prohibiting bribery, RHG requires that all RHG personnel, worldwide, ensure
that all transactions and dispositions of assets are consistent with management
authorizations, while maintaining books and records that fairly, timely, accurately, and in
reasonable detail, reflect the nature of all transactions undertaken by RHG and the disposition
of all RHG’s assets.

Each country in which RHG conducts business has anti-corruption laws and regulations. It is
important to understand the requirements of, and to comply with, each of those prohibitions
on bribery as well. For more information on the rules related to a particular country, contact
the Legal department.

Third parties

Third parties acting on RHG's behalf are also prohibited from offering, giving or receiving
bribes. Team members shall undertake good-faith efforts to ensure that no agents,
consultants, joint ventures, vendors and other contracted partners make any payments or
provide any gifts or anything else of value on our behalf, or for our benefit, that would not be
permitted if we were to make the payment or provide the gift directly.

RHG’s policy and applicable laws require RHG to satisfactorily complete rigorous anti-
corruption due diligence prior to entering into any binding agreements for transactions, such
as third-party and intermediary engagements, joint ventures, mergers, acquisitions, franchise
agreements, hotel management contracts and strategic investments. The Legal department
must be involved with other departments in such diligence and in the final assessment of the

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findings. Our zero-tolerance approach to bribery and corruption must be communicated to all
suppliers, contractors and business partners at the outset of our business relationship with
them – and as appropriate thereafter.

In addition, no team member shall provide advice to a third party or other business associate
on how to engage in practices, which, if they were acts of RHG’s team members, would be
inconsistent with this policy or this Code.

Gifts, hospitality and entertainment

While gifts, hospitality, travel and entertainment can often be a legitimate part of conducting
business, they can also constitute, or be seen to constitute, bribes. Please refer to the
sections in this Code on Client, Customer and Guest Relations and on Conflict of Interest for
further guidance on when team members can give, offer and receive gifts, hospitality, travel
and entertainment to non-government officials.

Dealing with public officials

Particular care should be taken when dealing, directly or indirectly, with government and
public officials.

In line also with the Gift and Entertainment Policy, no team member may make payments to
or offer or give anything of value (including cash or gift cards, discounted or free food,
beverages, entertainment or use of hotel facilities) to government or political party officials
without seeking specific approval from the Executive Vice President & Chief Legal Officer,
General Counsel.

Facilitation payments, which are small unofficial payments made to secure or expedite the
performance of a routine process an official is already under a duty to perform is a bribe
(regardless of size or local business practices) and are often illegal. Team members may
not make any such payments without seeking specific approval from the Executive Vice
President & Chief Legal Officer, General Counsel.

Government or political-party officials include anyone directly or indirectly employed by acting

for any government body or agency or anyone performing a public function. This should be
understood widely and includes, for example, anyone working for any national or local
government or public department, body or agency (e.g., police, fire, state-owned or controlled
media, health inspection officials and other government regulators), people holding a public
position, team members of state-owned or controlled enterprises, team members of public
international organizations, officials of a political party, candidates for political office and
members of a royal family, as well as the spouses and immediate family members of any of
the above. It is not always obvious that someone is such an official, so if you are in any doubt
as to who you are dealing with, consult with the Executive Vice President & Chief Legal Officer,
General Counsel.

Political and charitable activity

20-RHG Code of Business Ethics 2022

RHG funds, property (including electronic devices and computer systems) and services may
not be used for political campaigns, political parties or to make contributions to any political
campaigns, political parties or charitable causes on behalf of, or for the benefit of, any
government official or political or party figure.

While team members may participate as individual citizens in the political process, decisions
to do so are entirely personal and voluntary. Team members engaging in political campaign
activities are expected to do so as private citizens and must at all times make clear that their
views and actions are their own, and not those of RHG. Team members must not use their
position with RHG to coerce or pressure other team members to make contributions to, or
support or oppose any political candidates, elections or ballot initiatives. Team members will
not be reimbursed directly or through compensation increases for personal political
contributions or expenses, and RHG will not take any action towards an team member based
on their political contributions or lack thereof.

Example:
Bribery of Following a tax audit in a country, the General Manager of a leased
Public Officials hotel receives a reassessment notice. The basis for this reassessment
appears to be unjustified. This is what local tax inspectors sometimes
do in the hope of being offered cash compensation in exchange for
withdrawing the reassessment. The compensation is very small in value
compared to the reassessment.

By paying even a symbolic amount, the team member can expose

himself/herself and RHG to criminal prosecution. In addition, such an
team member is subject to disciplinary action that could result in his/her
dismissal

In such a situation, team members should immediately notify their

manager, and the Executive Vice President & Chief Legal Officer,
General Counsel who is equipped in assisting team member handle the
situation appropriately.

Bribery of Third A company is planning to hold its annual convention in one of the
Parties managed hotel properties of RHG that needs to see an improvement in
its occupancy rate. The contract would involve accommodating three
hundred people over two days in the middle of the low season. To obtain
this contract, the General Manager in line with the Complimentary Stay
policy available on Hotelkit is inclined to provide a stay to convention
organizer and his assistant for a week’s stay at the hotel with their
respective families to familiarize themselves with its advantages.

It may be appropriate to offer complimentary stay basis the Company

Policy to both the convention organizer and his assistant. However,
extending any undue benefits or extras such as an invitation to the
family to stay free of charge at the hotel would clearly be inappropriate

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 or even be considered as an act of private corruption. Consequently,
this must be avoided. It may be prudent to issue the convention
organizer with full documentation beforehand, clearly defining the
amenities and services included in your invitation and a suggested
schedule of meetings, visits and introductions to service providers, etc.
is very much recommended.

ANTI-MONEY LAUNDERING AND FACILITATION OF TAX EVASION

RHG is committed to operating with the highest ethical standards and strictly prohibits any
form of crime, including any crime that inter alia involves obtaining an economic benefit
through illegal methods i.e. money laundering, tax evasion, embezzlement of funds and/or
improper payments.

Anti-money laundering laws impose significant penalties for acquiring, possessing, hiding, or
dealing with the proceeds of crime. RHG has a zero-tolerance approach when it comes to
any sort of violation of anti-money laundering laws.

RHG can also be held responsible for facilitating or enabling tax evasion by third parties,
including by all RHG agents, consultants, advisors and partners.

Non-compliance with such laws is serious and puts both RHG and the persons involved at
risk of significant monetary fines, criminal penalties (including prison time for individuals) and
severe damage to RHG’s reputation.

This applies to all RHG team members and directors as well as to agents, consultants,
advisors, partners and others performing services for or on RHG's behalf. We require that
RHG team members be vigilant at all times, analyze all relevant activities that may be
performed in the course of their association with RHG and promptly raise concerns and/or
suspicions relating to any financial crime or tax evasion in accordance with this policy.

Such suspicious situations may include without limitation the following:

• RHG being requested to receive or make payments to any entity that is not a party to
the transaction, it being noted however that RHG’s payment policy does not authorize
payments to be made to any entity other than the contracting entity (Please check the
policies applicable to payments on HotelKit for further details);
• Where money is transferred or routed through unrelated countries or bank accounts,
in particular countries or territories that are considered 'offshore' or which otherwise
represent an enhanced risk of financial crime;
• Requests to provide or receive payment at times unrelated to when services are
provided;
• Requests for overpayments or for refunds following an over-payment;
• False reporting such as misrepresenting prices, misdescribing goods or services, or
misdescribing taxes;
• Where payments are made or received in anonymous forms (such as cash, vouchers
or prepaid cards);

22-RHG Code of Business Ethics 2022

 • Payments from multiple sources to satisfy a single invoice;
• Any other oddly structured transactions or arrangements.

Any such red flags should be immediately reported to the Executive Vice President & Chief
Legal Officer, General Counsel.

Receipt of A hotel owner intends on paying for the fees in lieu of services provided
Payments by RHG under the IMA from the bank account and company not agreed
under the contract.

This factual matrix does not comply with Group rules and presents a
risk of money laundering. RHG’s contracts its partners clearly identifies
all payment details in compliance with RHG policies. Such a situation
must immediately be brought to the attention of your manager and the
legal department.

TRADE SANCTIONS

RHG is committed to ensuring that it conducts business in compliance with all applicable
sanctions regimes and will not engage with any parties sanctioned under such measures.
Trade sanctions generally prohibit companies and individuals from engaging in business
activities with certain countries or with particular restricted persons or entities. Team
members and anyone doing business for or on behalf of RHG must therefore be clear who
we are dealing with and of transactions and jurisdictions that represent an enhanced
sanctions risk. If you have any doubts or concerns about the restrictions that may apply to
your business activities on behalf of RHG, please contact the Legal department.

Breaching sanctions carries serious penalties including significant fines and imprisonment,
as well as reputational harm. As such, RHG and all team members and representatives must
exercise caution as to whom:
• services are provided to/ we allow services to be provided to; and
• goods are purchased from.

RHG and all team members and representatives must never deal with any person or
property in a manner which contravenes applicable trade sanctions or restrictions, including
without limitation those adopted by the UK and EU.

REPORTING TO RHG AND COMPLIANCE CERTIFICATION

All General Managers of the Owned, Leased, and Managed hotels of RHG have to report in
as further described below for gifts, cash or cash equivalents received by any manager or
staff member in the hotel.

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The same process is applicable to all Central, Area, Regional, Sales and Purchasing Offices
for any such gifts given or received by the management and any of the staff.

The Executive Committee, members of the Business Leadership Team and Head of
Departments have to report in the same manner.

In light of the above, each person that falls within the following categories must complete and
electronically submit a Compliance Certificate (to the Executive Vice President & Chief Legal
Officer, General Counsel) by 31 January of each year at the latest to confirm adherence with
this Code and any relevant policies that may be referred to herein for the previous calendar
year (an example of the compliance certificate is attached) on the platform used by RHG:

• The members of the Executive Committee

• The Heads of Departments (both at CSO and ASOs)
• Area Senior Vice Presidents
• Regional Directors and District Directors
• Hotel General Managers and Financial Controllers of Owned, Leased, and Managed
Hotels
• Persons in sales and procurement (including at CSO and area/regional levels) that
are at manager level or above

A Statement of Exception should also be attached to the Compliance Certificate, if applicable.

24-RHG Code of Business Ethics 2022