Responsible Business Code of Conduct

Maybourne Hotels Limited is the operator of Claridge's, The Connaught, The Berkeley, The Emory, The Maybourne Beverly Hills and The Maybourne Riviera (together 'Maybourne' or 'we').

We are committed to operating sustainably and conduct our business according to core values that define both Maybourne's reputation and its brands, allowing us to operate in a way that minimises our impacts on the environment, respects human rights, promotes inclusion and respect, and supports local communities.

We recognise that the majority of our impact occurs in our value chain. Therefore, we must ensure that we not only conduct our own business responsibly and sustainably but develop a value chain that operates under the same principles. Maybourne is dedicated to working with suppliers, affiliates, contractors, sub-contractors and agents ("supplier/s") who share our commitment to responsible and sustainable operations and our core values.

This Responsible Business Code of Conduct ("Code of Conduct") is informed by the United Nations (UN) Global Compact, the UN Universal Declaration of Human Rights, the    Conventions of the International Labour Organisation ("ILO") and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Companies.

The Code of Conduct formalises the minimum standards and commitments expected by Maybourne from its employees and all suppliers in terms of ethics, respect for human rights, protection of employees' rights, environmental sustainability and compliance with all applicable laws and regulations. Maybourne expects all of its suppliers to comply with the principles of this Code of Conduct regardless of their location, the volume of business they have with Maybourne or the type of products or services that they provide.

Our Code of Conduct embodies our commitment to transparent, fair, and efficient procurement practices. It is guided by principles of compliance, competition, quality, and sustainability, as we strive to maximise value while upholding responsible conduct and fostering strong supplier relationships.

We also expect our suppliers to only select partners, contractors, sub-contractors and agents that meet the same high standards as Maybourne, in terms of respect for the principles set out in this Code of Conduct, in all of the countries where they operate.

Sustainable Procurement

Maybourne's objective is to drive sustainability and economic empowerment in our procurement practices. We aim to give preference to suppliers and products that meet sustainability and quality criteria, reflecting our dedication to responsible business practices that extend beyond profit generation.

We believe that we can efficiently meet our business needs and contribute positively to our communities and vulnerable populations, and reduce our environmental impact.

Identifying and Assessing Risks

Maybourne recognises the importance of identifying and assessing environmental, social, and ethical risks within our supply chain through risk assessments. We work collaboratively with our suppliers to understand and mitigate these risks.

Supplier Selection

Maybourne prioritises the selection of suppliers who demonstrate a clear commitment to sustainability, responsible sourcing, and ethical business practices. Our supplier evaluation process considers environmental certifications, social responsibility initiatives, and adherence to ethical standards, ensuring that our partners share our values.

Stakeholder engagement

Maybourne understands the importance of engaging with all relevant stakeholders to foster transparency, collaboration, and trust in our procurement processes. We acknowledge that our stakeholders, including employees, suppliers, customers, and the local community, play a pivotal role in shaping our procurement decisions and the overall sustainability of our operations. Maybourne seeks to build constructive relationships with our stakeholders and create an open and inclusive environment where their perspectives are valued.

Fundamental Principles

Compliance with laws and regulations

Maybourne operates within the boundaries of all laws and regulations across our entire geographical footprint. Suppliers are expected to comply with all applicable local, national, and international laws, statutes, rules, regulations, and codes in force in the countries where both the supplier and Maybourne source, operate, and supply ("Applicable Laws"). This includes, but is not limited to, laws related to labour, health and safety, the environment, ethics, animal welfare, confidentiality, cybersecurity and data protection.

Integrity in Business Conduct

Suppliers must act with the highest standard of integrity when conducting business. This includes complying with all Applicable Laws relating to business conduct, including trade sanctions, competition/antitrust laws, and data privacy/protection laws. Where Applicable Law conflicts with this Code of Conduct, suppliers are expected to comply with legal requirements while seeking to uphold the spirit of this Code of Conduct wherever possible.

International Standards

Suppliers are expected to follow generally accepted international standards relating to health and safety, the environment, human rights, ethics, and labour practices, as defined by the International Labour Organisation (ILO). Suppliers are also encouraged to exceed legal compliance to advance social and environmental objectives.

Systems and Policies

Suppliers are expected to have systems and policies in place to comply with this Code of Conduct. This includes establishing and implementing policies, employee education programmes, and whistleblowing procedures to receive complaints from workers, business partners, customers, and other relevant parties.

Health and safety

The mental and physical health and safety of our employees and contractors are paramount. We provide safe working conditions, comprehensive training, and the necessary resources to prevent accidents and injuries. Maybourne fosters a culture of safety, encouraging employees to report concerns and actively participate in safety initiatives. We will work collaboratively with our suppliers to promote safe practices within our value chain. We expect our suppliers to share our commitment to health and safety standards, working together towards a responsible supply network.

We maintain clear protocols for reporting and investigating health and safety incidents or violations, with immediate corrective action being taken to prevent recurrence. Suppliers are responsible for upholding a productive, safe, and healthy working environment and complying with all Applicable Laws pertaining to working hours, wages, benefits, working conditions, and occupational health and safety.

Suppliers must ensure that all training in health and safety matters is conducted in the relevant languages for their workers. Fire and evacuation procedures should be in accordance with relevant Applicable Laws. If the supplier is fined or prosecuted for any violations, warned for the same, or if there are injuries or fatalities of its workers, the supplier must notify Maybourne immediately.

Human Rights

Our objective is to create a value chain that upholds the highest responsible business standards and promotes the welfare of workers. We strictly prohibit the use of child labour and forced labour in any part of our value chain. We require all our suppliers to adhere to the same uncompromising standards. We define child labour in accordance with international conventions and laws, and we prohibit any form of forced or bonded labour, including debt bondage and involuntary prison labour.

Suppliers must only employ workers who are of the applicable minimum age for employment or the applicable age for completion of compulsory education. Suppliers are responsible for verifying the age of their workers and maintaining copies of their workers' proof of age. Suppliers shall ensure that young workers are not engaged in hazardous work that could cause physical or mental harm and ensure that they are protected from any form of exploitation including sexual exploitation. Suppliers may use properly-managed workplace apprenticeship programmes, such as student internships.

Maybourne does not tolerate any form of slavery and/or human trafficking, or any toleration of or contribution to such acts by the supplier. Any form of slavery and/or human trafficking, or any contribution thereto, is strictly prohibited. The supplier shall not charge recruitment fees or restrict workers' freedom of movement and shall comply with all Applicable Laws relating to anti-slavery and human trafficking.

Freedom of Association and Collective Bargaining

Where the right to freedom of association and collective bargaining is not restricted under law, the supplier shall not interfere with or obstruct workers from exercising those legal rights to freedom of association and collective bargaining or joining or forming trade unions.

Fair Wages and Employment

Suppliers should have employment contracts that contain clear and transparent information about working conditions, rights, responsibilities, and wages before workers are hired. Suppliers should select workers based on principles of fairness and merit, without any form of discrimination. In addition, suppliers should ensure all recruitment agencies contracted are compliant with all Applicable Laws and standards relating to labour including verification of identity and eligibility to work in the local jurisdiction.

Product safety and quality

The supplier shall demonstrate a commitment to ensuring the safety and quality of its products. All products must comply with all Applicable Laws and any additional safety criteria specified by Maybourne, and the supplier shall implement comprehensive safety procedures throughout all stages of production, from design and development to manufacturing, packaging, and delivery.

Anti-Corruption

Maybourne has a zero-tolerance approach to all forms of corruption, fraud, and money laundering. We are committed to complying with all applicable anti-bribery and money laundering legislation. Maybourne adheres to the standards of conduct set out in the applicable laws related to anti-corruption and anti-money laundering in the countries where we operate. This includes the Bribery Act 2018 in the United Kingdom, the U.S. Foreign Corrupt Practices Act (FCPA) in the United States, and Law No. 2016-1691 on Transparency, Fighting Corruption, and Modernising Economic Life (Sapin II Act) in France. The supplier must also implement and maintain adequate procedures designed to comply with these requirements.

The supplier shall not, directly or indirectly, offer, solicit, pay, or accept any form of unlawful advantages, including (but not limited to) bribes, kickbacks, secret commissions, rewards, favours, cash, gifts, loans, employment, facilitation payments, or any other thing of value to secure improper business advantages.
The supplier should not offer any employee or representative of Maybourne excessive business entertainment that could be seen to compromise their objectivity in making decisions, create the appearance of impropriety, or violate the law.

Conflicts of interest

The supplier must not attempt to gain improper advantage or preferential treatment, nor inappropriately influence the employees of Maybourne. The supplier shall not give, offer, promise or authorise anything of value to any person, including government official or its family members, to improperly influence official action or gain an improper advantage. The supplier must disclose actual, potential, or perceived conflicts of interest to Maybourne before entering any business relationships and immediately upon discovery of a perceived or actual conflict of interest. The supplier must avoid any situation or relationship that may involve an inappropriate conflict or the appearance of a conflict with Maybourne's interests.

Confidentiality and data protection

Maybourne prioritises the health and safety of its colleagues and guests, and this includes technological security. We have implemented robust data protection measures and adhere to the UK General Data Protection Regulation (UK GDPR). Cybersecurity is a top priority for Maybourne, and we expect our suppliers to uphold the highest standards of protection.

The supplier may have access to confidential information in its dealings with Maybourne, including the personal data of Maybourne's guests, customers and/or employees, as well as intellectual property. We expect the supplier to collect, use, handle, process, store, disclose and transfer such data in compliance with Maybourne's policies and all Applicable Laws relating to data protection and privacy in all applicable jurisdictions.

The supplier, including its employees, agents, and subcontractors, shall hold its suppliers and subcontractors accountable to these standards and to have procedures in place for the proper processing, collection, storage, use, disclosure, transfer anddisposal of confidential information and data. Such policies and procedures must be designed to prevent inappropriate access to or disclosure of confidential information, and further protect confidential information from fraud, theft, and destruction.

The supplier shall not use or disclose any such data or engage and/or authorise any third-party service providers to process any such data, without the prior written consent from Maybourne. The supplier must not use Maybourne confidential information for personal use and must notify Maybourne immediately of any actual or suspected data security breaches involving Maybourne's confidential information.

The supplier shall promptly notify Maybourne in the event of any unauthorised disclosure, leakage or use of data and work with us in good faith to mitigate the impact of any incident on us, our guest(s), customers and employees and in compliance with all Applicable Laws relating to data protection and privacy.

Diversity, inclusion and equal opportunities

Maybourne naturally has a highly diverse workforce and we invest in fostering an inclusive and equitable environment where our colleagues feel safe and that they belong.

We encourage the supplier to cultivate a work environment that promotes mutual respect, diversity and inclusiveness.

Maybourne does not tolerate bullying, harassment, and/or sexual harassment both within our own operations or of our team by third parties. Third parties who conduct themselves inappropriately through such behaviour may be warned, banned from our properties, and in some serious cases, reported to the police. To protect all our colleagues whilst at work, we reserve the right to share necessary information with our other properties.

The supplier must treat its workers with the same respect and dignity. The supplier must not tolerate violent conduct, threats of violence, workplace harassment, workplace sexual harassment, and any other form of legally prohibited form of harassment, retaliation and other disrespectful or inappropriate behaviour in the workplace.

Commitment to the environment

Maybourne is committed to upholding high environmental protection standards and strictly adhering to all relevant environmental laws and regulations. We continuously seek opportunities for improvement in these critical areas. We expect our suppliers to share our commitment to sustainability and adhere to environmental laws, regulations, and standards, working together towards a responsible value chain.

The supplier shall conduct its operations in compliance with all applicable laws relating to the environment. The supplier should help mitigate the risk of global warming and climate change by following the "3R" approach of reuse, reduce, and recycle and implement measures within its value chain to minimise the negative impact on the environment and communities, and conserve and maintain biodiversity where its facilities are located.

Maybourne encourages the supplier to surpass environmental regulations where feasible and demonstrate continuous improvement in reducing the environmental impact of operations, products, and services across all lifecycle stages. The supplier is encouraged to use machinery, equipment, vehicles, materials, and processes that maximise energy and resource efficiency, particularly by reducing single-use plastics and using sustainable alternatives, and seek to continually reduce the environmental impact of its operations, services provided, and products produced.

The supplier is encouraged to source materials locally whenever possible to support local economies, reduce environmental impact, and promote sustainability. The supplier shall maintain transparency in its sourcing and supply chain practices, provide information about the origin of materials and the distance they have travelled upon request, and work towards reducing the overall distance that products and materials travel as part of a commitment to environmental sustainability.

Animal welfare

Maybourne places a strong emphasis on animal welfare and suppliers are encouraged to implement humane procedures to prevent the mistreatment of animals, including when they are raised, cared for, transported, and processed. The supplier should recognise its responsibility for the ethical treatment of animals in its care and the care of its suppliers, workers, agents and contractors.

Supply chain engagement

The supplier should communicate this Code of Conduct or equivalent standards and principles to its suppliers and contractors and ensure that the relevant standards and principles are considered when selecting suppliers or contractors. By adhering to this practice, the supplier can ensure that its supply chain aligns with the standards set forth in this Code of Conduct.

Business continuity and contingency planning

Effective risk management is a critical aspect of Maybourne's governance and all suppliers are expected to have robust business continuity plans that are regularly reviewed and updated. We expect the supplier to develop, maintain, and test its own business continuity and disaster recovery plans by following applicable regulatory and contractual service level requirements.

Accurate books and records

Maybourne expects the supplier to comply fully with all its obligations concerning all taxes due within the jurisdictions in which the supplier operates. The supplier must report all pertinent financial information, product details, and invoices and maintain proper, accurate and complete books and records in accordance with all Applicable Laws and recognised accounting standards and practices. The supplier must not participate in tax evasion or facilitate tax evasion by others.

Maintenance and monitoring of compliance

The supplier shall monitor, record and benchmark its performance against this Code of Conduct regularly and ensure it maintains a complete set of records to trace the supply chain of all goods and services provided by it. The supplier authorises Maybourne as well as any duly qualified third party mandated by Maybourne, to conduct audits and inspections of the supplier's premises and records, and to meet the supplier's personnel to ensure compliance with this Code of Conduct.

Supplier confirmation

The supplier should take appropriate steps to ensure that the principles of this Code of Conduct are communicated to, adopted and applied by its workers and throughout its value chain. When violations are found, Maybourne and the supplier will agree on a corrective action plan that eliminates the problem promptly.

The supplier acknowledges that respecting the principles set out in this Code of Conduct is an essential element of the commercial relationship with Maybourne and if the supplier is not or is no longer able to respect any of these provisions, it must inform Maybourne immediately so that the corrective measures to be implemented can be agreed on together.

Failure by the supplier to respect any provisions of this Code of Conduct may constitute grounds for termination of the commercial relationship.

Reporting concerns

We expect and encourage stakeholders, including the supplier, to report concerns about any actual or suspected breach of this Code of Conduct whether the breach is regarding Maybourne or any supplier or third party that works directly with Maybourne.

Concerns should be reported promptly to either a known Maybourne contact or to the Chief Legal Officer at Maybourne (legal@maybourne.com).

It is essential for our suppliers to instil similar reporting practices within their organisations and to encourage their employees, customers, suppliers, and other stakeholders to report any instances of wrongdoing, unethical behaviour, or suspected violations of this Code of Conduct and relevant laws.