Business Conduct Guide

Our Tradition of Integrity

 Our business
relies upon
integrity and
good judgment.

J.W. Marriott, Jr.

Dear Colleague,

Marriotts reputation and continued success as a global hospitality leader are grounded in our commitment to
service and business integrity and in our application of consistently high standards to everything we do.

Since the very beginning, a fundamental commitment to hard work, fair business practices, and respect for others
has shaped our everyday decision making and has guided our relationships with all of our stakeholders associates,
owners, business partners, franchisees, customers, and the communities in which we work.

Our commitment to being a responsible corporate citizen has not changed since 1927. Decisions that do not reflect
our fundamental values of integrity, honesty, and fairness can compromise our competitiveness, lead to significant
financial losses, and harm our associates.

Because our business relies upon integrity and good judgment, this Business Conduct Guide and related Company
policies were developed to provide all members of the Marriott community with guidance on not only what is legal
but also what is right.

This Guide supports our pledge to uncompromising business standards and a fair and ethical workplace.

All of us who act on behalf of Marriott are responsible for upholding Our Tradition of Integrity.

Sincerely,

J.W. Marriott, Jr.

Chairman and Chief Executive Officer
Continue the Marriott Tradition of Integrity.

Be Accurate, Honest, and Fair.

Avoid Even the Appearance of Wrongdoing.

Obey the Law.

Understand the Implications of Your Actions.

Be Trustworthy.

Treat Others with Dignity and Respect.

Work for the Good of the Community.

 Business Conduct Guide

Introduction.................................................................................................... 2 jump
Expectations and Responsibilities.......................................................... 2
Responsibilities of Marriotts Leadership................................................ 3
Confidential Reporting and No Retaliation.............................................. 4
Where to Go for Help............................................................................ 5
Acting with Honesty and Integrity............................................................... 7 jump
Accurate Books, Records, and Reports................................................ 8
Dealing Fairly with Customers.............................................................. 10
Competition Law and Antitrust............................................................. 11
Dealing Fairly with Competitors........................................................... 13
Commercial Bribery and Improper Gifts............................................... 14
Interacting Honestly with the Government............................................... 17 jump
Bribery, Illegal Gratuities, and Gifts....................................................... 18
Political Contributions and Activities.................................................... 21
Lobbying....................................................................................... 22
Providing Information to the Government............................................. 23
Trade Restrictions and Boycotts.......................................................... 23
Protecting Marriotts Assets and Reputation............................................ 25 jump
Proper Use of Marriotts Assets............................................................ 26
Protecting Confidential Information....................................................... 27
Insider Trading..................................................................................... 29
Protecting Marriotts Reputation........................................................... 30
Use of Associate Time......................................................................... 31
Conflicts of Interest.............................................................................. 32
Corporate Opportunities..................................................................... 33
Protecting and Respecting Customers and Associates.......................... 35 jump
Fair and Harassment-Free Workplace.................................................. 36
Health, Safety, and Security................................................................. 37
Customer and Associate Privacy......................................................... 37
Promoting the Greater Good...................................................................... 39 jump
Giving Back to the Community............................................................. 40
Supporting Human Rights and Human Dignity...................................... 40
Environmental Responsibility................................................................ 41

1
 Business Conduct Guide

Expectations and Responsibilities

Every day, we welcome guests, conduct business, and make What is Expected of Everyone?
decisions and choices on behalf of Marriott International As Marriott associates, officers, directors, or other persons acting on
(Marriott) and all of the Marriott brands. behalf of Marriott (collectively associates), you are expected to be
familiar with and work within the code of business conduct detailed in
Every day, we are confronted with situations that test our this Business Conduct Guide.
values, our beliefs, and our judgment.
You are also expected to obey the law at all times. While Marriott does
The reputation of Marriott is built upon the actions of all of us not expect everyone to be subject matter experts in all areas of law, each
who act on behalf of Marriott. individual is held responsible for being familiar with the pertinent laws
governing his or her areas of responsibility.
It is vitally important for each of us to understand our legal
You may be required to certify from time to time that you have read
and ethical responsibilities so that we can make the right
and understand the Business Conduct Guide and are complying with
decisions every day. Marriott policies regarding legal and ethical business conduct.

Who is Responsible?
All Marriott associates are responsible for upholding the legal, ethical,
and social standards detailed in this Business Conduct Guide.
This Business Conduct Guide applies to the business operations
of all Company-branded hotels and businesses (including The
Ritz-Carlton), all Marriott business units, Marriott offices,
departments, and majority-owned subsidiaries.
Managers who are responsible for supervising other associates have
a specific responsibility to ensure that associates who report to them
understand the expectations contained in this Business Conduct Guide.

When do the Rules Apply?

The rules apply whenever Marriotts interests are directly affected. This
could include actions taken while on or off Marriott premises or while on
duty or off duty, depending on the circumstances. You must be prudent
and apply good judgment to your own actions and decisions.

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 Business Conduct Guide

Responsibilities of Marriotts Leadership

Managerial associates, officers, and directors are expected

to set the right tone and lead by example. Positive adherence
to the Business Conduct Guide and other policies is largely
dependent upon managements leadership.
Be knowledgeable of and refer frequently to the Business Conduct Guide
and other Marriott policies in your interactions with associates. Encourage
others to apply these policies as they fulfill their responsibilities.

Creating the Right Environment

Communicate what is expected of associates.
S
 et the right example. Others are likely to follow your lead.
Waiver
D
 o not set unrealistic goals that place indirect pressure on associates to
compromise our ethical standards. The Board of Directors of Marriott has
approved and requires adherence to the
R
 ecognize associates for acting with integrity. Business Conduct Guide. Any waiver of any
Report known violations of policy or law. provisions of the Business Conduct Guide
otherwise applicable to executive officers
Foster a work environment that encourages the reporting of Business or directors, may be made only with the
Conduct Guide and policy violations. prior approval of the Board of Directors or
Adopt open door processes for the benefit of associate a designated committee of the Board of
communications. Directors.

Safeguard the confidentiality of those who report violations in good faith

and protect them from retaliation and job reprisal.

Application of Marriotts Ethical Standards to Others

Be mindful of Marriotts ethical standards when hiring contractors,
vendors, suppliers, and agents. Ensure that they satisfy Marriotts
standards.
It is just as wrong to retain or hire someone to engage in illegal or
unethical conduct as it is to engage in that conduct yourself.

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 Business Conduct Guide

Confidential Reporting and No Retaliation

This Business Conduct Guide provides you with the When reporting a suspected violation, you do not have to give your
information you need to identify potential compliance issues, name. However, you are encouraged to provide your name to assist with
the investigation of a potential violation. Conversely, associates who raise
to seek advice, and to report or raise a potential issue within
a concern are ensured a reasonable degree of confidentiality during the
Marriott. investigation and resolution of a concern.
When to Seek Advice No Retaliation means that associates who report a concern in good
If you are unsure of what to do in a given situation, stop to ask yourself: faith cannot be subjected to any adverse employment action, including
separation, demotion, suspension, or loss of benefits because of the
Is the action legal? report.
Is it consistent with Marriotts business values, and is it a winning If you believe someone has retaliated against you for your role in report-
situation for both Marriott and the customer? ing a concern or participating in an investigation, report the matter using
How would you feel about your decision if your friends and community the Business Integrity Line or other resources listed on page 5, Where
learned about it in the media? to Go for Help.
What would you do if you owned Marriott, and you were responsible for Enforcement of Business Conduct Violations
our reputation?
Violations of the Business Conduct Guide will be addressed promptly,
If you are still unsure if an action is a violation, discuss your questions and consistently, and effectively. Punishment may include prosecution,
concerns with an appropriate resource listed on page 5, Where to Go involuntary separation from employment, or other appropriate discipline
for Help. or performance management measures. A final update may be provided,
Note that in some instances, although the action may be appropriate, if appropriate, to the person who reported the violation, if the report was
written approval may be required. not made anonymously.
Associates who conceal misconduct, falsify records, knowingly make a
Confidentiality; No Retaliation
false report, or fail to comply with Marriott policies also may be subject
Marriott respects the confidentiality of associates who report potential to disciplinary action, up to and including termination.
Business Conduct Guide violations and has a No Retaliation policy for
Managers may be subject to disciplinary action if they do not adequately
associates who raise a concern honestly and in good faith.
supervise associates for whom they are responsible.

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 Business Conduct Guide

Where to Go for Help

The integrity of Marriott is diminished whenever our business Contact Internal Audit.
conduct standards are violated. You are encouraged to Telephone: Call the Chief Audit Executive or Business Ethics Manager
continue our Tradition of Integrity by asking questions and E-mail: Business.Ethics@Marriott.com
reporting Business Conduct Guide and policy violations. Fax: +1 (301) 380-3186
When you suspect or know that an action or inaction is or could be a Use the Online Form listed under the Contact Us page of the
violation of Marriott standards, consider the following options: Business Ethics site on MGS to report your ethical or legal concern
through Marriotts confidential website
Discuss your concerns with your manager. Use the open door
Mail: Marriott International, Inc.
process.
Attention: Internal Audit
Read the relevant Company policies. They are available on Marriotts 10400 Fernwood Road
intranet (Marriott Global Source or MGS), published as Marriott Department 52/924.09
International Policies (MIPs). Bethesda, MD 20817

Call the Business Integrity Line. Contact the Marriott Law Department.
In the United States (U.S.), U.S. territories, and Canada: Mail: Marriott International, Inc.
Marriott properties: (888) 888-9188 Attention: General Counsel
10400 Fernwood Road
Ritz-Carlton properties: (877) 777-RITZ or (877) 777-7489
Department 52/923.30
Outside the U.S., U.S. territories, and Canada, refer to the phone Bethesda, MD 20817
numbers listed on posters and printed materials at your workplace.
Ethics resources and materials can also be found on the Business Ethics
site on MGS.

Please note: The Business Integrity Line and online resources are
available 24 hours a day, seven days a week. Remember, Marriott
adheres to a policy of No Retaliation. See page 4.

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 Be Accurate,
Honest, and Fair.
Avoid Even the
Appearance of
Wrongdoing.

6
Acting with Honesty and Integrity

Always act with honesty and integrity. This applies

to recordkeeping especially with financial records
and to your business interactions with customers,
competitors, vendors, and others.
Additionally, obey all laws that govern these
relationships and activities.

Accurate Books, Records, and Reports..................... 8

Dealing Fairly with Customers...................................10

Competition Law and Antitrust..................................11

Dealing Fairly with Competitors................................13

Commercial Bribery and Improper Gifts...................14

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 Business Conduct Guide Acting with Honesty and Integrity

Accurate Books, Records, and Reports

Be honest and act with integrity in all communications in Requirements:

every record created and in all data entered, from financial Accurately document the purpose of transactions, the provider
information and personal resums to quality and safety or recipient of funds, the accounts to and from which funds are
reports. Our books, records, and reports are only as accurate transferred, and the entities and departments responsible for particular
transactions.
as the data from which they are derived.
Respond truthfully to all appropriate questions from auditors.
Who is Responsible?
Make certain that all information and reports supplied to government
We all might, at some point, contribute to the accuracy of information authorities, self-regulatory organizations (such as the Financial
maintained by Marriott or submitted to regulators. Industry Regulatory Authority), shareholders, securities analysts, and
You should never falsify or distort any information or documents related the general public are accurate, timely, and supported by necessary
to your work for Marriott. The duty to ensure the accuracy of records documentation.
encompasses: Ensure that all travel and entertainment expenses are supported by
Expense reports actual receipts and have a valid business purpose. Expenses must
be reasonable and within guidelines prescribed by MIP-44 (Travel &
Benefits claims Business Expense Reimbursement).
Invoices
Do not inappropriately delay or accelerate the recognition of revenues
Entries in financial books and records or expenses or overstate or understate assets or liabilities.
Numerous other Marriott documents Do not distort the true nature of any transaction, no matter what the
Managerial associates are responsible for ensuring that their subordinates reason
understand and adhere to this principle. and no matter how insignificant the result may seem.
Do not discard, destroy, or improperly alter records that are required to
Accurate Financial Records are Critically Important
be preserved by law, by policy, or by specific hold directives.
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 Marriott failing to Seek Advice
satisfy legal, regulatory, or fiduciary obligations and cast doubt on When something about a record does not seem right, raise your concerns
Marriotts integrity and honesty. with a manager who has the authority to conduct further inquiry.
Remember, Marriott adheres to a policy of No Retaliation. See page 4.

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 Business Conduct Guide Acting with Honesty and Integrity

Accurate Books, Records, and Reports

Accuracy of Information Submitted by Others

We all must pay attention to the accuracy of information submitted by Examples
others with whom we interact, including: Accurately Assigning Project Budgets
Owners A manager is working on two projects Project A, which is under
Franchisees budget, and Project B, which is over budget by a small amount. So
that he can report that Project B was within budget, he recorded
Joint venture partners a very small amount of the expenses incurred on Project B to the
Customers under-budget Project A.
Contractors Is this Acceptable? No. The manager may not distort the purpose
Vendors of expenses, no matter how insignificant the amount.

Other associates Expense Report Accuracy

An associate submits an expense report to his manager for
approval. A meal expense on the report does not include an
explanation of its business 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
Take care of the little reimbursement.

things every day...

Who is Responsible? The associate and his manager are
both responsible for the reports inaccuracy. When approving
transactions, managers have a duty to ensure expenses are valid,
- J. Willard Marriott are properly supported, and have a bona fide business purpose.

This philosophy of our founder is behind all

Marriott policies, procedures, and systems.

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 Business Conduct Guide Acting with Honesty and Integrity

Dealing Fairly With Customers

As a leading worldwide hospitality company, Marriott is

dedicated to providing exceptional customer service. Examples
Customers should always be treated fairly and with respect. Clarifying Services with a Customer
Q. You met with a customer about providing catering services for
Customers should be given what is promised and at the promised price.
an event. The contract and discussions with the customer correctly
Misrepresentations about Marriotts products and services may lead to represented the products and services to be provided. However,
costly legal action. A false claim, a small untruth, or even a perception of you suspect that the customer has an incorrect understanding
dishonesty can jeopardize the loyalty and satisfaction of our customers. about the meal being provided. What should you do?
When communicating with customers and the public: A. Although you acted honestly, you should clarify and resolve any
Be truthful, without embellishment or omission, when representing the confusion before providing the services, so as not to risk having a
dissatisfied customer.
nature and quality of Marriotts products, services, prices, contractual
terms, and other information. Colleague Misrepresents Services to a Customer
Avoid even inadvertently misleading customers. Q. During a customer meeting, you hear a colleague make a
Only make claims about Marriotts products and services that you know representation about Marriotts services, which you believe to be in
error. What is the appropriate response or action?
to be true or have adequate information to support.
A. The response depends upon the circumstances and relationships
of the people involved. You should take prompt steps to clarify and
correct the misstatement.
Seek Advice
If the error appears to be inadvertent, either correct the
If in doubt, clarify with your manager or an appropriate member of
misstatement during the meeting or talk with the colleague
management. after the meeting.
If an intentional misrepresentation is suspected, consult with your
manager or an appropriate member of management.

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 Business Conduct Guide Acting with Honesty and Integrity

Accurate Books, Records, and Reports

Competition and antitrust laws affect almost every aspect Do Not Make Unlawful Agreements with Competitors
of our global business, including our international activities, Any agreement or understanding with competitors to limit competition or
which may be subject to both U.S. antitrust laws and the collaborate can be unlawful even if the firms involved did not act on the
laws of the European Union or of other countries where we agreement or if the firms actions did not actually harm competition.
do business. Our policy is to comply with all applicable laws Depending upon the jurisdiction, certain agreements are automatic
and regulations. violations of antitrust laws, including:
Actual or inferred agreements to raise, lower, or stabilize prices (e.g.,
Penalties for violating or even appearing to violate competition laws room rates)
may be severe for both Marriott and Marriott associates.
Agreements to reduce output (e.g., keeping inventory off-line)
As required by your duties and position at Marriott, you are responsible
for being reasonably familiar with applicable competition laws where you Agreements to allocate customers, products, or geographic territories
do business. (e.g., refraining from development in certain areas)
It would be impossible to describe here all of the global competition laws Agreements to boycott or refuse to deal with certain customers or
that apply to our business. However, examples of the most common suppliers
potential violations relevant to us are set forth below and in more detail in Agreements to coordinate terms or conditions for wages, benefits,
MIP-10 (Antitrust Compliance). fees, or other compensation for associates, independent contractors,
or vendors, except as permitted by specific labor laws

Competition laws are designed to

keep businesses from engaging in
anticompetitive practices, particularly
those that unfairly affect prices or
allocate business.

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 Business Conduct Guide Acting with Honesty and Integrity

Competition Law and Antitrust

What Other Practices Might Violate Competition Laws? Is Below-Cost Pricing Ever Acceptable?
The following business practices are typically not appropriate, depending There are limited circumstances where below-cost pricing may be
upon the circumstances and the laws of the applicable country or locality: acceptable, such as introductory offers. If in doubt, consult the Marriott
Predatory or below-cost pricing or other exclusionary practices that are Law Department.
designed to maintain or create a monopoly by impairing a competitors
ability to compete or that are designed to drive out or deter competition
Example
Exclusivity arrangements that deny a competitor access to customers,
distribution channels, or raw materials, particularly if they result in higher Conversations with Competitors
prices for consumers Marriott and a competitor are planning to build hotels in an emerging
Tying or conditional arrangements, which require a customer who market. At an industry meeting, the competitors employee casually
wants to buy or lease one product to also buy or lease a second suggests to a Marriott associate that the two hotel chains should
coordinate the sites of their new hotels to avoid crowding.
product, should not be imposed without prior approval of the Marriott
Law Department Correct Action: Associates should be on heightened alert when
interacting with competitors. The conversation above could violate
competition laws. The Marriott associate would be prudent to
change the subject, remove himself from the conversation, and
Seek Advice
contact the Marriott Law Department for guidance.
Seek guidance from the Marriott Law Department in these situations or
when in doubt about any competitive strategy.

Good food and good service

at a fair price...
 premise of the Marriott culture since 1927, when
A
J. Willard and Alice Marriott opened a root beer stand, and
the future Marriott International was born

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 Business Conduct Guide Acting with Honesty and Integrity

Dealing Fairly With Competitors

Marriott competes on the merits of our

products and services. Use caution in Examples
discussing a competitors products and New Hire with Competitor Insights
services. Marriott recently hired a former employee of a competitor who had been exposed to the
You should not make false claims or remarks that competitors confidential and proprietary information.
unfairly disparage competitors or that improperly Correct Action: The new associate and the business unit where he works should ensure that
interfere with a competitors business relationships. all legal and ethical obligations are observed during the associates transition and employment
However, you may point out legitimate weaknesses by Marriott. He should not divulge to Marriott nonpublic information he received while working
in a competitors products or operations. for the competitor or use the competitors confidential information
in his work.
Use information concerning competitors in a
manner that is lawful, fair, and consistent with Improper Access to Competitor Information
Marriott policy.
During a Marriott meeting, an associate announces that she has information that has not been
Respect the trade secrets and nonpublic information released to the public regarding a competitors plans to revamp its facilities in a key Marriott
of others, and avoid unauthorized use of patented, business location. Other associates suspect the information may have been divulged in
copyrighted, privileged, or confidential information violation of a confidentiality agreement.
belonging to competitors. Correct Action: If the information is subject to a confidentiality agreement or should not have
been disclosed by the source, accepting and sharing the information is a violation of Marriott
policy. The associate may not use the information competitively unless it is determined that it
was obtained properly and that its use is neither illegal nor unethical.

Request to Improve on Competitor Proposal

A customer offers a Marriott associate a copy of a written proposal from a competitor and asks
if Marriott can improve on the competitors terms.
Correct Action: The associate may not review the competitors proposal without first
determining whether its disclosure to Marriott is in violation of a confidentiality agreement or
other duty that the customer owed to the competitor. If in doubt, the associate may not share
or use the information without consulting with the Marriott Law Department.

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 Business Conduct Guide Acting with Honesty and Integrity

Commercial Bribery and Improper Gifts

Never compromise ethical standards to gain a competitive Improper Gifts

advantage or to meet a business objective. This includes Marriott has established clear policies regarding the acceptance and
making or receiving improper payments or gifts. giving of gifts between associates and business partners, customers,
contractors, vendors, and suppliers. You are expected to abide strictly
Commercial Bribery by those policies, as detailed in MIP-75 (Gift & Entertainment Policy).
Payments made on behalf of Marriott and in connection with A few highlights from the gift policy include:
Marriotts business must be made solely for lawful and legitimate You may not request gifts for your personal benefit in connection with
business purposes. your work for Marriott.
You may not request, receive, give, or offer anything of value in the form Marriott places specific annual aggregate limits on the type, value, and
of a bribe or kickback. This unethical practice is not acceptable simply nature of unsolicited gifts that you may accept.
because everyone is doing it or because it is necessary to compete in Personal acceptance of discounts or free services from vendors may
a particular market. also be prohibited if you are responsible for procuring for Marriott
If you take bribes or kickbacks, this deprives Marriott of your honest those same types of products or services. These could be considered
services and prevents Marriott from receiving the best possible value in kickbacks.
negotiating for goods and services. Avoid frequent acceptance of gifts, even if the gifts are not lavish and
Giving bribes or kickbacks to employees or persons associated with are individually within the value limits established by Marriott.
Marriotts business partners, customers, contractors, vendors, or Decline gifts otherwise permitted by
suppliers may harm the other party, too. Marriott policy if you know or suspect that the gift would violate the
Promoting business through bribery is obviously unethical and may policies of the givers employer.
subject Marriott to civil lawsuits and criminal prosecution. Bribery in Marriott policy strictly forbids the acceptance of cash other than an
commercial transactions is illegal in the U.S. and in other countries and ordinary gratuity for those associates who routinely receive tips as part
localities where Marriott does business. of their jobs.
For these reasons, associates involved in commercial bribery could be Know Policy; Use Common Sense
subject to serious employment consequences, including involuntary
separation from employment or even criminal prosecution. In addition to abiding by Marriott policy, use common sense in giving
and accepting gifts in the context of business relationships. Do not
accept any gift that could compromise your objectivity in making
decisions for Marriott, that creates the appearance of impropriety, or
that violates the law.

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 Business Conduct Guide Acting with Honesty and Integrity

Commercial Bribery and Improper Gifts

Are There Any Exceptions?

When the value of a gift exceeds the annual Examples
value limits established by Marriott, your manager Costly Gift from a Vendor
may make a limited exception in appropriate
A Marriott associate with responsibility for making purchasing decisions receives a watch,
circumstances. Key considerations include whether valued at $750 USD, as a gift from a vendor who has done recurring business with the
the gift serves a business purpose and otherwise associates department for many years. May the manager approve acceptance of the watch?
does not violate Marriotts gift policies or legal or
Correct Action: The manager should consider the value of the gift, the ongoing nature
ethical standards. A written record of the exception
and recurring award of the business, the associates role in the procurement process, and
must be maintained.
appearances. Weighing these factors, the manager must direct the associate to return the gift.
Stricter Rule Relating to Government Officials Tickets to a Sporting Event
Marriotts permissible gift rules are not applicable A vendor offers a Marriott associate floor-level seats to a popular sporting event. The vendor
when the intended recipient of the gift is a explains that he does not want anything in return; he cannot attend the event, and he does
government official. It is rarely appropriate to not want the seats to be wasted. The value of the tickets, however, exceeds the value limits
give anything of value to national, state, or local established by Marriott.
government officials (whether U.S. or non-U.S.), Correct Action: Even if the associate does not believe that the gift was offered to gain any
including meals and travel expenses. (Refer to improper advantage, the associate must politely decline the tickets because their value
the following section, Interacting Honestly with exceeds the value limit specified in MIP-75.
Government.)
A Business Dinner
A vendor invites a Marriott associate to discuss business over dinner and insists on paying the
More Information entire bill.

Consult MIP-75 for more information Correct Action: Assuming the meal is not inappropriately lavish, the associate may accept
regarding Marriotts gift policies. the meal.

Paid Trip to a Trade Show

A prominent vendor offers an associate an all-expenses-paid trip to attend a trade show.
Attendance would assist the associate in her work for Marriott, but the aggregate value of the
travel expenses exceeds the annual limit established by Marriott.
Correct Action: The associate must obtain prior approval from a manager to accept payment
of the travel expenses. The manager may approve the travel if it furthers Marriotts business
and does not appear to have been offered for improper purposes.

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 Obey the Law.
Be Responsive.
Understand the
Implications of
Your Actions.

16
Interacting Honestly with the Government

Wherever you live or work, there are very specific rules

to guide your interactions with the government and
government officials. These rules may concern political
contributions, lobbying, gifts, illegal gratuities, or
providing anything of value to officials.
Be responsive when supplying information to regulatory
agencies or other government entities, and understand
Marriotts policy on trade restrictions and boycotts.

Bribery, Illegal Gratuities, and Gifts...........................18

Political Contributions and Activities.........................21

Lobbying....................................................................22

Providing Information to the Government..................23

Trade Restrictions and Boycotts...............................23

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 Business Conduct Guide Interacting Honestly with the Government

Bribery, Illegal Gratuities, and Gifts

Marriott strictly forbids giving or promising anything of value

to a government official or employee, whether to influence What is Considered Bribery?
that person in his or her official duties or to encourage Bribery could include the giving or promising of anything of value
unlawful conduct. with a corrupt intent, including but not limited to:
Money
In addition, you may not give things of value to a government official or Favorable loans
employee because of any official act performed or to be performed by Free goods or services
that person. Even a thank you gift for the performance of official duties Discounted goods or services
is not appropriate. Free upgrades
Such practices may be considered bribery and are illegal in many parts of Rebates
the world, including the U.S., and may seriously damage our reputation. Gifts
Associates involved in any form of bribery could be subject to serious Meals
employment consequences, including involuntary separation from Entertainment
employment or even criminal prosecution. Travel
These policies apply equally to former government employees and Job offers
someone who has been elected but has not yet assumed office. Donations to a charity suggested by an official
Campaign contributions
International Bribery Intangibles, such as valuable information
The United States Foreign Corrupt Practices Act (FCPA) applies to our
business conducted around the world. The FCPA and laws of many
countries forbid the giving or promising of anything of value, directly
or indirectly, to non-U.S. officials in order to obtain or retain business. Who is Considered a Government Official?
These laws apply to anything given for the personal benefit of a Elected or appointed government officials and their family
government official. members, including former and current officials and those waiting
to assume office
Employees of national, state, and local governments
Political party officials and employees of political parties
Candidates for political office
Employees of international treaty organizations, such as the
European Union and United Nations

continued on page 19

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 Business Conduct Guide Interacting Honestly with the Government

Bribery, Illegal Gratuities, and Gifts - continued from page 18

Involvement of Third Parties

Using a third party to make a corrupt or forbidden payment is just Examples
as wrong as making such a payment directly. Take care in selecting A Modest Boxed Lunch?
contractors, vendors, and suppliers who, in their work on behalf Marriott is hosting an industry conference to which various
of Marriott, may interact with government officials and government government officials will be invited as honorary guests. A modest
employees. Perform appropriate due diligence and make sure third boxed lunch will be provided to ALL guests of the conference,
parties agree to abide by Marriotts prohibition against corrupt payments. regardless of their position.
Further Investigation Correct Action: While the lunch is a modest item that is being
provided to everyone attending the conference, the associate
If there is reason to question the purpose or amount of a payment or the
responsible for the event should consult with Marriotts Office
integrity of another person working with or on behalf of Marriott, further
of Government Affairs before providing the free lunch to any
investigation may be required. Marriott and the responsible associates government official or staff.
could be held liable for consciously avoiding knowledge about the
corrupt conduct of others. A Customer Courtesy
The Ocean County Democratic Party holds a conference every year
at the same Marriott hotel. It has requested a free room for its key-
Information & Advice note speaker, a prominent governor.
In the U.S.: For more information about bribery and illegal gratuities, Correct Action: After consulting MIP-80, the General Manager
consult MIP-80 (Interaction with Government, Political Activity, (GM) correctly decides that the free room is being given based
and Political Contributions in the United States) or contact on the general practice of the hotel, which is to present a
Marriotts Office of Government Affairs. complimentary room to groups booking large events.
Outside the U.S.: For more information on interaction with government
officials and prohibitions on bribery, consult MIP-07 (Foreign Corrupt The Ritz-Carlton Rewards Membership
Practices Act and Foreign Economic Boycotts). Direct any While on vacation, a government employee and his family are
questions to the Marriott Law Department. checking in for a one-week stay at a Ritz-Carlton hotel. The
reservations agent offers the government employee membership in
The Ritz-Carlton Rewards program.
Gifts and Entertainment
Correct Action: The agent was correct to make the offer.
Even if done with honest intentions, giving things of value to Membership in The Ritz-Carlton Rewards program is offered to
government officials and employees may create the appearance of guests of Ritz-Carlton hotels in the ordinary course of business and
improper influence. is not based upon status as a government employee.
For these reasons, you must consider applicable rules and laws before
providing to government officials and employees even inexpensive
items of value that, if given in other circumstances, might be considered continued on page 20
common courtesies (e.g., paying for taxi fare or a meal).

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 Business Conduct Guide Interacting Honestly with the Government

Bribery, Illegal Gratuities, and Gifts - continued from page 19

Examples
Questionable Third-Party Negotiation congresswoman has retired, the associate considers sending a gift basket to
the congresswoman in recognition of her retirement and to thank her for her
Marriott is negotiating a contract with a representative of a Middle Eastern
country to provide meeting space and lodging for an OPEC meeting. A local hard work on the legislation.
company wants to act as Marriotts agent in the negotiations in exchange for Correct Action: The associate may not provide the gift basket because
a commission that seems excessive and inappropriate for the service. The it might appear to be a gratuity given because of an official action by the
company has told Marriott officials off the record that it has the inside edge congresswoman. It thus violates Marriott policy, regardless of whether the
for the meeting space and lodging contract. associate paid for the gift with Company or personal funds.
Correct Action: Immediately raise this high-risk issue with the Marriott Law Cash in Exchange for Permit Approval
Department, which will assist in determining how the situation should be
handled. A Marriott associate is responsible for obtaining a necessary land use
permit for a Marriott hotel. All of the legal conditions for the permit have
Suspected Corrupt Conduct of Agent been satisfied. The government official responsible for reviewing Marriotts
Marriott plans to build new hotels in a country where corruption is rarely application says he will approve it in exchange for $50 USD.
punished. A Marriott associate is planning to hire an agent and interpreter to Correct Action: Associates may not give or receive bribes no matter how
explain Marriotts plans to government officials in order to obtain necessary small the sum. The associate should seek guidance from the Marriott Law
permits. The agent insists upon meeting alone with government officials and Department.
recommends his fees be documented as a public relations campaign or
introduction services. The associate suspects that the agent may engage Government Officials Preferred Contractor
in corrupt conduct. A Marriott hotels General Manager in a Latin American country has been
Correct Action: Given the countrys reputation for condoning corruption, the told by the government official in charge of health inspections that a cleaning
associate should raise the issue with the Marriott Law Department. service company run by his cousin provides excellent services. The inspector
informs the GM that other hotels using his cousins service have never been
Thank You Gift for Retired Congresswoman charged with a local health violation.
A respected U.S. congresswoman recently retired. She had been instru- Correct Action: The health inspectors suggestion contains many red flags
mental in passing legislation of importance to Marriott and even met with a that require analysis by the Marriott Law Department. Even if competitive bid
Marriott associate to discuss Marriotts views on the legislation. Now that the procedures were followed, the propriety of the relationship is questionable.

continued on page 21

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 Business Conduct Guide Interacting Honestly with the Government

Bribery, Illegal Gratuities, and Gifts - continued from page 20

There are strict rules that govern political contributions and Be Aware of Laws Related to Government Contracts
personal political activities of Marriott associates. Managers must be mindful of so-called pay-to-play laws adopted
by numerous state and local governments and applicable to individual
Political Contributions government agencies. Such laws vary, but, in general, they prohibit
Corporate campaign contributions and expenditures given to political companies from receiving certain government contracts if the company
parties and candidates for federal office are prohibited under U.S. law. made contributions to the campaigns of that jurisdictions government
officials.
We lawfully participate in U.S. federal elections through our Political
Action Committee (PAC). Some states and localities even prevent companies from being awarded
government contracts if the companys directors, officers, and certain
Although other countries and some U.S. states and localities may permit
other associates personally contribute money to the campaigns of
political contributions from corporate treasury funds, our guidelines are
relevant candidates.
clear:
Be mindful of these laws when deciding to provide financial support to a
You may not make political contributions and expenditures on
candidate and when competing for government contracts on behalf of
behalf of Marriott or involve Marriott in political activities without prior
Marriott.
approval from Marriotts Office of Government Affairs.
Managers may not require political contributions or contributions to
the PAC as a condition of employment or any other job-related benefit. Seek Advice
Marriott may not reimburse you by any method (including direct For more information, refer to MIP-80. When in doubt about pay-to-
payment, increased bonuses, or inflated expense allowances) for play laws of a particular jurisdiction, consult with Marriotts Office of
political contributions. Government Affairs.

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 Business Conduct Guide Interacting Honestly with the Government

Political Contributions and Activities Lobbying

Personal Political Activities Marriott seeks to impact legislation and government

Marriott encourages your personal participation in elections and decision making solely through honest means and on the
government processes. However, you must conduct your personal merits of our proposals.
political activities on your own time and without use of Marriotts
resources (e.g., stationery, copying machines, or office supplies). Associates who interact with government officials must be familiar
with and obey all applicable lobbying laws and lobbying disclosure
You also must refrain from conducting personal political activities in a
requirements.
manner that might suggest sponsorship or approval by Marriott.
You should avoid even the appearance of improper influence. For
example, a promise of financial support from Marriotts Political Action
Examples Committee should never be made to an official in exchange for his
Improper Use of Marriott Resources for Political Activities endorsement of government policies favorable to Marriott.
A Marriott manager is supporting a senators re-election campaign. Without Similarly, never give a gift or other benefit to a government official for the
any improper coercion, he asks several other managers to contribute to purpose of gaining an improper advantage.
the campaign and asks his personal assistant to collect the contributions
and draft a cover letter to the campaign committee. The assistant drafts the
cover letter on Marriott letterhead.
Right or Wrong? The manager violated Marriott policy by soliciting
contributions. Also, requesting that the personal assistant collect
Even if the issue seems
contributions and using corporate stationery are both impermissible uses
of corporate resources for personal political activities. The circumstances
small never compromise
could give the impression that Marriott is sponsoring or illegally subsidizing
the contribution.
our values.
Arne M. Sorenson

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 Business Conduct Guide Interacting Honestly with the Government

Providing Information to the Government Trade Restrictions and Boycotts

Always be truthful in providing information to the Many countries, including the U.S., impose trade restrictions
government on behalf of Marriott. and boycotts that have underlying foreign policy objectives.
You may interact with various government agencies in many ways. Such restrictions typically prohibit certain business activities with and
Examples include: within certain countries or with particular persons or entities that are
Filing routine information with government agencies (e.g., tax returns, deemed a threat to security, human dignity, and human rights. These
lobbying disclosure reports, securities filings) restrictions include prohibitions on business activities with designated
narcotics traffickers, terrorist organizations, and proliferators of weapons
Participating in legal actions before agencies and courts of mass destruction.
Providing information in connection with special government inquiries In addition, U.S. law generally prohibits participation by U.S. citizens or
and investigations entities in unrecognized international boycotts. Because Marriott is
Making false statements in these circum-stances may harm Marriotts incorporated in the U.S., we abide by U.S. economic sanctions and
reputation and may result in severe penalties for both Marriott and the anti-boycott laws, regardless of where we do business. If you are
responsible associate. responsible for generating business outside the country in which you
work, you must be familiar with applicable trade restrictions.
Never attempt to obstruct a government inquiry or the administration
of justice, and immediately report any such activities by others. Tell a Export control laws may restrict certain business generation activities in
manager or use any of the other methods listed on page 5, Where to a country, including the transmission of data, submission of proposals,
Go for Help. or solicitation of business.
Remember, Marriott adheres to a policy of No Retaliation. See page 4.
Seek Advice
Information & Advice When in doubt about whether a trade restriction applies to Marriotts
business, consult the Marriott Law Department.
For more information about interaction with governments, political
activity, or political contributions in the U.S., consult MIP-80. Direct
your questions to Marriotts Office of Government Affairs.

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 Be Trustworthy.
Safeguard
Marriotts Assets.
Avoid Conflicts
of Interest.

24
Protecting Marriotts Assets and Reputation

All of our actions reflect who we are as individuals and

as representatives of Marriott. We must be responsible
in the way we use and handle Marriotts assets and
information never using them for personal gain and
in the way we spend our time on the job.
Additionally, unauthorized communication and the
disclosure or misuse of information may be damaging to
our customers, associates, and shareholders, as well as to
Marriotts reputation one of our most important assets.

Proper Use of Marriotts Assets.................................26

Protecting Confidential Information..........................27

Insider Trading...........................................................29

Protecting Marriotts Reputation...............................30

Use of Associate Time...............................................31

Conflicts of Interest...................................................32

Corporate Opportunities............................................33

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 Business Conduct Guide Protecting Marriotts Assets and Reputation

Proper Use of Marriotts Assets

As associates, we have a duty to protect Marriotts assets

as well as assets that are owned by others but that Marriott Examples
controls. Marriotts assets should be used only in the manner Business Rate vs. Pleasure Rate
intended and only for legitimate business purposes. While traveling on business for Marriott, a cost-conscious associate
notices that she can save a considerable amount for Marriott by booking
Unless authorized, you may not take or use for your personal benefit Marriott her hotel stay using the Marriott Associate Pleasure Rate.
products and services for which you have not paid. Thus, you are prohibited Correct Action: The associate cannot utilize the Pleasure Rate for
from giving or taking free or discounted products and services not available a business-related stay. This would misrepresent the purpose of the
to the public, unless proper authority has been granted by Marriott. trip and constitute improper use of the discount rate. It impacts the
profitability of the hotel and the operating results for the hotel owner. All
Avoid any practice that places Marriotts assets at risk for loss, waste,
reimbursable stays (including weekends) at Marriotts lodging properties
destruction, misappropriation, alteration, theft, abuse, or misuse.
should be at the Marriott Associate Business Rate.
Marriotts records, including information stored electronically on computers, Complimentary Room for a Friend
personal digital devices, or other media are considered Marriott assets.
A Marriott Guest Services Aide encounters a longtime friend checking
Safeguard all Marriott information and adhere to all record retention policies.
into a Marriott hotel for a one-night stay. It is late in the evening, and
the hotel has vacancies. The Aide would like to offer his friend a
What Is an Asset?
complimentary room.
Marriotts assets include: 1) tangible assets, both large and small, such Correct Action: Unless the associate has special authorization, the
as electronic equipment and office supplies; 2) intangible assets, such as giving of a complimentary room would be a misappropriation of a
Marriotts proprietary information, and; 3) other assets under Marriotts Marriott asset.
control, including assets of hotel owners.
Loan from the Cash Bank
Examples of Assets An associate who has access to a Marriott cash bank needs a short-
Tangible Assets Intangible Assets term loan. Without anyone elses knowledge, he takes $50 USD from
the cash bank and pays the money back the next day.
Money Confidential or proprietary
Products information Right or Wrong? Although the associate returned the money, the
Trademarks unauthorized loan is a theft of Marriotts property.
Vehicles
Meeting rooms Trade secrets Tickets for Personal Use
Guest rooms Copyrighted or patented As a marketing promotion, Marriott is offering complimentary tickets to
information an amusement park to potential customers at a timeshare property. A
Software/computer systems
Associate time hotel associate considers taking tickets for her familys use.
Equipment
Reputation Right or Wrong? The unauthorized personal use of the tickets is a
Associate-generated assets
and works for hire Corporate opportunities violation of Marriotts policies.

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 Business Conduct Guide Protecting Marriotts Assets and Reputation

Protecting Confidential Information

Everyone is responsible for protecting the confidentiality of

Marriotts proprietary information, except when disclosure is If you suspect that confidential information has been lost or misused,
authorized or legally mandated. contact your manager or report the concern to Information Protection
and Privacy at Privacy@Marriott.com.
This duty applies to all associates. It applies during both working and Remember, Marriott adheres to a policy of No Retaliation. See page 4.
nonworking hours and extends beyond your employment with Marriott.
Consult MIP-29 (Information Security and Confidentiality),
Do not share Marriotts confidential information with: 1) associates who Marriotts Information Security Manual, or department-specific standard
are not authorized to receive it or do not have a business need for the operating procedures, for more information.
information; or 2) persons outside Marriott, unless there is a legitimate
Consult MIP-25 (Public Information for News Media and Other
and authorized business purpose for the disclosure, or unless disclosure Parties) for guidance related to communications with news media
is required by law. and other outside parties and MIP-28 (Electronic Communications)
for guidance related to the protection of confidential information when
Confidential Information Includes:
using electronic communications.
Information that derives value from not being known to the public
Undisclosed or commercially sensitive information that might be of
use to Marriotts competitors continued on page 28

Information that might harm Marriott, our shareholders, our

customers, or our associates, if disclosed

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 Business Conduct Guide Protecting Marriotts Assets and Reputation

Protecting Confidential Information - continued from page 27

Examples of Confidential Information:

Personal and financial information concerning customers or associates Examples
Personnel matters Overriding Computer Security System
Associate usernames and passwords An associate has found a method for overriding Marriotts computer
security systems, making it faster and easier for the associate to access
Sales and marketing strategies
information needed for his job. He uses this method only to access data
Pricing strategies that he is authorized to view.
Corporate revenues and financial data Right or Wrong? Even if the associate accesses only data that he is
Proprietary methods of doing business (including all technical system permitted to view, it is a violation of Marriotts polices to evade Marriotts
security systems and may subject Marriotts confidential data to
information)
unauthorized disclosure or theft.
Standard operating procedures
Sharing Username and Password
Policy manuals
A Marriott associate will not have access to e-mail during an upcoming
Internal memos and e-mails vacation and asks her daughter to check her work e-mail periodically
Trade secrets for important messages. She discloses her Marriott username and
password to her daughter and impresses upon her the confidentially of
Business plans
all Marriott information.
Information about undisclosed mergers, acquisitions, and joint ventures
Right or Wrong? The associate has violated Marriotts policies by
Changes in Marriotts management sharing her username and password. Associates may not make
New product or service developments their own judgments regarding the sharing of Marriotts confidential
information.
Defer to Designated Persons
To protect Marriott and our shareholders and to ensure compliance
with the law, decisions related to disclosing commercially sensitive
business information and other nonpublic information should be made
only by designated persons and coordinated with the Communications
Department.
Never share information about Marriott with the news media, government
officials, shareholders, securities analysts, other interested persons, or
the public, without proper authorization or as required by law.

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 Business Conduct Guide Protecting Marriotts Assets and Reputation

Insider Trading

It is illegal to use material nonpublic information to make Policies for Trading in Securities
personal investment decisions to buy, sell, or trade in Marriott has established specific policies for associates trading in Marriott
securities such as stocks, bonds, and options. securities or the securities of entities with which we do business or are
likely to do business. If you trade in such securities, you must abide by
This is considered insider trading and applies to associates, officers,
these policies, which include the following:
and directors who have access to nonpublic information about Marriott
or our business partners, customers, contractors, and suppliers. Marriott directors, officers, and employees who are designated as
restricted associates, may trade in Marriott securities only at times
The ban on insider trading includes using material nonpublic information
permitted, as detailed in MIP-11 (Securities Trading).
to recommend investment decisions or to provide it to others to assist
them in their investment decisions. All associates, even those of you who are not designated as restricted,
are prohibited from engaging in insider trading.
Inside information may include, but is not limited to:
Even at times when trading is permitted, directors and certain officers
Information regarding upcoming mergers and acquisitions
must obtain pre-approval for certain transactions in Marriott securities.
Changes in critical management
You may not engage in derivative transactions (such as short sales or
Undisclosed financial results call or put options) in Marriott securities.
Development of new products and services
In the event of an inadvertent disclosure of inside information,
Information & Advice
immediately report the facts to the Marriott Law Department.
Consult MIP-11 for detailed information concerning prohibited trading
practices and passing of inside information to others. When in doubt,
seek advice from the Marriott Law Department.

All associates continued on page 30

are prohibited
from engaging
in insider
trading.

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 Business Conduct Guide Protecting Marriotts Assets and Reputation

Insider Trading - continued from page 29 Protecting Marriotts Reputation

The public perception of Marriott is one of our most

Restricted Associates important assets.
Restricted associates, who are notified by Marriott of their restricted
status, may trade in Marriott securities only during designated open You must avoid any communication, disclosure, or interaction that
trading windows. During a closed trading window, there is a list of might disparage, defame, or damage Marriotts reputation, associates,
activities that are restricted for these associates, as detailed in MIP-11. customers, vendors, or other business partners, or that might fail to
During a closed trading window, restricted associates may not: serve the best interests of our shareholders.
Buy or sell Marriott stock In particular, any public statement made on behalf of Marriott or our
Execute a same-day sale (i.e., cashless exercise) of an option divisions must present a consistent viewpoint and must not divulge
proprietary information.
Make any other trade in Marriott securities
Change Marriott Stock Fund allocations under Marriotts Retirement Official and Unofficial Communications
Savings Plan or other Marriott stock-based compensation plans
This duty to protect our reputation applies to communications and
Make an election of payroll-tax withholding method under Marriotts disclosures about Marriott in both official and unofficial contexts,
executive stock plans such as:
With friends and family
Via the Internet
Example
On social media
Sharing Nonpublic Information
In the news media (e.g., TV, radio, online)
The mother of a Marriott associate tells her son, who interacts with the
managers of a certain company, that she is considering buying stock During outside activities and speaking engagements
in that company. The son has learned, in the course of performing his In all situations, consider whether the personal thoughts you express
duties for Marriott, that there are nonpublic plans to sell the company
publicly may be misunderstood as expressing Marriotts official position.
to an international conglomerate, and he tells his mother he thinks her
purchase is a good idea because he believes the value of the companys Marriott has no desire to interfere with your private lives or your after-
stock will rise as a result of the merger. work activities, including social networking. However, where such
Right or Wrong? The associate engaged in insider trading. His conduct activities impact the work environment or Marriott in a negative manner,
was illegal and a violation of Marriotts insider trading policy. Marriott reserves the right to take whatever action is appropriate, at our
discretion, to protect Marriotts reputation and interests. Refer to Social
Media Guidelines For Associates for further details.
continued on page 31

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 Business Conduct Guide Protecting Marriotts Assets and Reputation

Protecting Marriotts Reputation - continued from page 30 Use of Associate Time

The Role of Public Relations Treat your time spent at work and the working hours of other
Public statements from and concerning Marriott must be coordinated associates as corporate assets.
with, approved by, and released through a central corporate public
Dedicate your full attention to your work every time you report for duty
relations source. The objective is to ensure that what we communicate
with Marriott, and avoid engaging in activities that detract from your
publicly is factual, serves our shareholders and our interests, is not
duties during working hours. Managerial associates also should ensure
misleading or confusing and meets all legal and regulatory requirements.
that associates are paid for all hours worked.
In general, all communications must comply with Marriotts Social
Media Guidelines For Associates and Marriotts other communications
policies. If an emergency situation could lead to publicity or media Example
inquiries, all management bears the responsibility for promptly alerting
Outside Business Ventures
the Communications Department.
After consulting with a manager and obtaining approval, a Marriott
Consider the Implications manager decides to pursue an outside business venture. A few times
per week, the manager asks her assistant, an associate of Marriott, to
If you would be uncomfortable seeing one of your communications or
devote one or two hours to working on documents related to her new
disclosures on the Internet or being overheard by a Marriott manager, venture. The manager reasons that the additional work will not interfere
ask yourself whether the disclosure is necessary and whether the with the assistants duties for Marriott, and the assistant does not mind
communication might result in broader disclosure, might be subject to assisting with the new venture.
misinterpretation, or might harm Marriott.
Right or Wrong? The managers new business is a personal activity.
Therefore, the manager should not ask a Marriott associate to devote
Information & Advice time to his venture. This is a misuse of an associates time.
For additional information, consult MIP-25, MIP-28, and the Social
Media Guidelines For Associates.

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 Business Conduct Guide Protecting Marriotts Assets and Reputation

Conflicts of Interest

As associates, you should avoid activities that might result in, Do not create the appearance that Marriott is sponsoring or supporting
or give the appearance of, a conflict between your personal personal outside activities unless proper approvals have been granted.
interests and the best interests of Marriott. Avoid serving on the Board of Directors of another company. Service
on boards of charitable and nonprofit organizations must conform with
A conflict of interest arises when personal interests interfere with a the standards of MIP-59 (Outside Business Activities).
persons ability to make objective business decisions or work effectively
Employment of relatives in direct or indirect supervisory roles is
on behalf of Marriott.
controlled by Marriott policy and could be inappropriate. Contact
Some of the rules designed to prevent conflicts of interest include: your Area or Regional Human Resources (HR) manager for further
Avoid selecting, on behalf of Marriott, contractors and suppliers owned guidance.
or operated by personal friends or family members. Marriott has established specific procedures for the disclosure and
Avoid personal investment decisions and outside business ventures approval of outside business activities, as detailed in MIP-59. If you wish
that might compromise your ability to make decisions in the best to engage in outside business activities, you must follow all required
interest of Marriott. For example, personal material investments in the procedures.
stock of a business partner, customer, supplier, or other entity with
which Marriott may do business, might give the appearance that your
decisions for Marriott may be affected by favoritism. Example
Avoid outside employment or business ventures that may interfere with Hiring a Relatives Business
your ability to perform your duties for Marriott in an objective, effective, An associate is hiring a landscaper for a new Marriott resort. In response
and timely manner. to an open request for bids, he receives a proposal from a landscaping
business in which his cousin has a significant but passive interest. The
Do not promote your employment with Marriott in connection with any cousins business has a good reputation, has offered a fair price, and
outside business activity, speech, presentation, or publication without satisfies all requirements.
authorization.
Correct Action: The associate should not select a landscaper until
he informs a manager of the potential conflict of interest in selecting
the landscaper. The manager may decide to transfer this decision to
another associate or take other measures to mitigate the appearance of
a conflict.

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 Business Conduct Guide Protecting Marriotts Assets and Reputation

Corporate Opportunities

As associates, you have a duty to act in the best interests of

Marriott and to advance our legitimate business interests. Example
Five Percent Stake in Contractors Business
Thus, you should not compete with Marriott and should never accept
for yourself business opportunities or investments that rightfully belong An associate has a business relationship with a contractor who performs
work for Marriott. The contractor offers the associate a personal
to Marriott or that might advance Marriotts interests.
opportunity to obtain a 5 percent interest in the contractors company.
You should disclose those types of corporate opportunities to Marriott
Right or Wrong? Investment in the contractors company could result in
and seek approval before pursuing any such opportunity for yourself. a conflict of interest. The Marriott associate may not take an investment
This policy applies to all associates, including officers and opportunity without first disclosing it to Marriott and seeking approval.
directors, and includes business or investment opportunities:
Offered because of your position with Marriott
Offered by an entity with which Marriott does business
Discovered through the use of Marriott resources or information, or
through your position with Marriott
Offered by a competitor
That, if pursued by Marriott, would likely advance Marriotts business
objectives
This list of examples is not exhaustive, and it can be difficult to
determine whether an opportunity is one that may belong to Marriott.

Seek Advice
When in doubt, seek guidance from the Marriott Law Department.

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 Provide a Fair and
Safe Workplace.
Treat Others with
Dignity and Respect.

34
Protecting and Respecting Customers and Associates

As a hospitality company with interests around

the globe, Marriott strives to create a safe, fair, and
harassment-free workplace for our associates and a safe,
secure, and hospitable environment for our customers.
Our Spirit to Serve our customers, associates, and
communities is an important part of our culture and is
based on respect and care for individuals and a belief in
basic human rights.

Fair and Harassment-Free Workplace.......................36

Health, Safety, and Security.......................................37

Customer and Associate Privacy...............................37

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 Business Conduct Guide Protecting and Respecting Customers and Associates

Fair and Harassment-Free Workplace

Marriott celebrates individual differences and strives to

create an inclusive environment that fosters mutual respect, Seek Advice
diversity, and equal opportunity for workplace advancement. If you observe instances of workplace harassment or unlawful
discrimination, you should report your concerns using any resource listed
Our greatest strength lies in the rich blend of culture, talent, and on page 5, Where to Go for Help.
experiences of our associates worldwide. We seek and embrace
Remember, Marriott adheres to a policy of No Retaliation. See page 4.
differences as a powerful creator of value that is achieved by welcoming
anyone to participate and be part of a team with common purpose and
opportunity for all. Our expectations are based on two guiding principles:
we strive to achieve our common purpose by leveraging our unique skills
and perspectives, and we work to ensure that our culture welcomes
contributions from all.
We are committed to providing equal opportunities in all aspects of
employment, regardless of national origin, age, religion, gender, gender We must embrace a
identity, gender expression, sexual orientation, genetic information,
disability, or veteran status. global mindset. Marriotts
Additionally, we strive to give reasonable accommodations to persons
with disabilities and promote a constructive working environment for all
greatest strength lies in the
associates.
You are entitled to a professional work environment free from harassment
rich diversity of culture,
and retaliation. To that end, treat one another with dignity and respect.
Avoid any conduct that might create an uncomfortable or hostile working
talent, and experiences of
environment for others. our guests and associates
around the world.
- J.W. Marriott, Jr.
& Arne M. Sorenson

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 Business Conduct Guide Protecting and Respecting Customers and Associates

Health, Safety, and Security Customer and Associate Privacy

Marriott strives to protect the health, safety, and personal There are strict policies concerning the disclosure of
security of those who visit our properties and who work information about Marriott guests and associates.
for us.
There are only limited circumstances in which the private information of
Providing a healthy, safe, and secure environment supports our associates or customers may be disclosed outside of Marriott.
mission to provide an excellent experience for our guests and to You are responsible for reviewing and understanding Marriott policies
protect our associates from harm. before you release information about Marriott customers and
You are expected to comply with all health, safety, and security associates. Other than the exceptions expressly identified in Marriott
requirements and to be alert for health and safety hazards and policies, you may not disclose records and information concerning
breaches of security. present or former customers or associates.
This private information includes any Personally Identifiable Information
(PII), which can be associated with or traced to an individual, such as:
Name, address, telephone number, e-mail address, government
issued identifications (e.g., Social Security number), health records,
credit card information, or other financial information
Information concerning customers and associates must be safeguarded
and should be used only for legitimate business purposes and should
not be shared, even within Marriott, except on a need-to-know basis.

More Information:
Consult MIP-47 (Personal Information Privacy) for more information
regarding PII.

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 Work for the Good of
the Community.
Support Human Rights.
Be Environmentally
Responsible.

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Promoting the Greater Good

Marriott is well known for our commitment to

diversity, social responsibility, and community
engagement.
We have responsibilities to give back to the
communities in which we operate and to
minimize our impact on the environment.

Giving Back to the Community..................................40

Supporting Human Rights and Human Dignity..........40

Environmental Responsibility....................................41

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 Business Conduct Guide Promoting the Greater Good

Giving Back to the Community Supporting Human Rights and Human Dignity

Marriott has a social responsibility to serve the Marriott supports human rights around the world and works
greater community. to protect human rights within our sphere of influence.
To have the most significant impact, our social responsibility and Ensuring that our property and services are appropriately used by
community commitment blends corporate financial contributions with others is an important element of our support of human rights.
in-kind giving and the volunteer service of Marriott associates around Our Human Rights Policy Statement aligns with government, business,
the world. and public concern about issues such as human trafficking and the
Our commitment to social responsibility not only benefits the exploitation of children.
communities in which we live and work, but it also: Adhering to these principles and doing business with those who
Strengthens the Marriott culture do the same will help us maintain a competitive advantage and the
Helps us attract and retain valued associates, customers, and respect and confidence of our associates, customers, and clients.
business partners If you suspect that our property is being used for illegal purposes or
Provides opportunities for development in a way that does not respect human dignity, or if you believe that an
associates conduct is inconsistent with this policy, report your
As Marriott associates, we should be guided by the principle of giving concerns immediately, using any resource listed on page 5, Where to
back more than we take. We are all expected to be kind, generous, and Go for Help.
charitable to others. Remember, Marriott adheres to a policy of No Retaliation. See page 4.

We need to stand together to

ensure that travel and tourism
are always a positive force for
good in the world.
- J.W. Marriott, Jr.

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 Business Conduct Guide Promoting the Greater Good

Environmental Responsibility

Marriott has a social responsibility to serve the

greater community.
We are all guests
Marriott is committed to minimizing the impact of on the planet.
our operations on the environment and to promoting
environmental sustainability in partnership with
- Arne M. Sorenson
conservation organizations around the world.
Our environmental commitment includes the reduction of energy
and water consumption in our facilities and the expansion of
reduce, reuse, and recycle programs across all
our properties.
Our commitment to environmental responsibility begins at the
executive level and extends to all associates. We encourage all
associates to engage in innovative and creative thinking to help us
do our part in protecting the environment.
All associates, especially managers, should consider how to
be environmentally responsible in their work for Marriott. You
should not create or ignore environmental hazards.
You are also encouraged to report any potential violations of
environmental laws and regulations, using any resource listed on
page 5, Where to Go for Help.

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Business Conduct Guide

Working together, we can sustain and

strengthen our worldwide reputation
for being a company of values, morals,
integrity, and excellence.
- Arne M. Sorenson

2013 Marriott International, Inc. O

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