Code of Business Conduct and Ethics  •  Hyatt Gift Policy

Hyatt is committed to ethical and transparent business activities. This means not only compliance with laws, but following the standards of business integrity in Hyatt's Code of Business Conduct and Ethics (the "Code").

But if we are to do this, we need the commitment of every employee. We are therefore asking for your personal assurance that you have read the Code, understand what is expected of you, and will follow the Code. You have an obligation to ask questions if there is something you don’t understand, if you are concerned about any ethical or legal subject, or you are uncertain about how to answer the Compliance Commitment and Disclosure Form.

Remember, in addition to the other compliance and ethics subjects covered by the Code, Hyatt employees and associates must avoid conflicts of interest. These can occur when your personal interests might interfere or conflict with the interests of Hyatt. A conflict of interest may arise if you (or any member of your family) receives personal benefits as a result of your position with Hyatt. But situations that may be a conflict of interest may not be obvious. And in some cases, a conflict of interest can be resolved by disclosure and adjustment of business responsibilities. But we can’t resolve a potential conflict unless we know about it. Therefore, it is important to remember that whenever you suspect that you might have a conflict of interest, or something that might appear to others as a conflict of interest, you should report it on this form and to your supervisor. You may also report it directly to the General Counsel or Associate General Counsels listed at the end of the Code. Very often these conflicts can be resolved to everyone's satisfaction – but only if disclosed up front.

Items marked with a red diamond ♦ are required fields and must be completed before submitting the report.

Your Information

 

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♦ First Name:

M.I.

♦ Last Name:

 

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♦ Job Title:

 

♦ Global Employee ID:

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Conflict of Interest Disclosure Statement (Definitions are listed at the end of the Disclosure Form)

♦ Question 1:
 

Did you or your Family, directly or indirectly, own any interest in, or participate in the profits or income of, any Third Party, or in any way result in financial compensation based on Hyatt’s business activities? (You do not need to list your or your Family's ownership interest of any publicly traded entities if you or your Family's ownership interest is less than 5% of the total shares outstanding.)

Yes No
 

♦ Please provide a detailed explanation

♦ Question 2:
 

Did you or your Family directly or indirectly receive any loans from Hyatt or did you or your Family have outstanding loans from Hyatt? (Do not report loans from 401K plans, or advances for business travel or commuting expenses received from Hyatt.)

Yes No
 

♦ Please provide a detailed explanation

♦ Question 3:
 

Were you or any member of your Family an officer, director, partner, employee, advisor, representative, agent, auditor or consultant of, or otherwise employed or retained in some other capacity by or affiliated with any Third Party, or firm seeking to become a Third Party (see definition below)?

Yes No
 

♦ Please provide a detailed explanation

♦ Question 4:
 

Did you have any Family member employed at a Hyatt hotel, including Hyatt owned, franchised or managed hotels under any brand name (e.g. Hyatt Place or Miraval) or in a corporate, divisional or regional office in a position as an Assistant Manager, Manager or higher?

Yes No
 
 
 

♦ Please provide a detailed explanation

♦ Question 5:
 

Were you asked to use or reveal Confidential Information concerning Hyatt or its businesses without first obtaining specific authorization from the Senior Financial Officer, General Counsel or another executive officer of Hyatt? (Do not include information shared with owners, asset managers, Hyatt colleagues or the appropriate entities with whom you conduct business in the normal course of employment.)

Yes No
 

♦ Please provide a detailed explanation

♦ Question 6:
 

Did you use, permit others to use or have knowledge of other's use of funds, materials or equipment (including vehicles) belonging to Hyatt, or any clients for which Hyatt has a custodial obligation, for personal purposes which were unrelated to, or were not intended to further the business of Hyatt or Hyatt's clients? (Do not include hotel stays or other items within the guidelines of Hyatt's employee benefit plans.)

Yes No
 

♦ Please provide a detailed explanation

♦ Question 7:
 

Did you pay, authorize or otherwise have knowledge of direct or indirect payments made by or on behalf of Hyatt from Hyatt funds or any funds for which Hyatt has a custodial obligation as (i) political contributions; (ii) other payments to government officials and personnel; or (iii) commercial bribes, "kickbacks," or facilitating payments, including any payments or gifts you have identified to your supervisors under the Hyatt Hotels Corporation Gift Policy since your last Disclosure Form was completed?

Yes No
 

♦ Please provide a detailed explanation

♦ Question 8:
 

Do you serve on any boards of directors, as an executive officer, or in an advisory role, of any company, whatsoever (other than Hyatt) [Note: You do not need to disclosure nonprofit or charitable groups unless you are serving at the request of Hyatt or otherwise feel that such service may appear to be a conflict of interest]?

Yes No
 

♦ Please provide a detailed explanation

♦ Question 9:
 

Do you serve on any industry related advisory councils or groups including trade associations, vendor related organizations or similar entities?

Yes No
 

♦ Please provide a detailed explanation

♦ Question 10:
 

Did you receive or accept any business gifts (other than nominal promotional items), direct or indirect payments made by or on behalf of a business partner, vendor, client or guest, or received entertainment that was more than required or appropriate as part of a normal business contact, since your last Conflict of Interest Disclosure was completed? If yes, please describe the nature of the gift or entertainment and how you complied with the Hyatt Gift Policy.

Yes No
 

♦ Please provide a detailed explanation

♦ Question 11:
 

Are you aware of any agreement with a Third Party which did not go through the required approval process at your location or where you believe there was improper influence by a colleague?

Yes No
 

♦ Please provide a detailed explanation

 
 

Disclosure or Confirmation and Acknowledgement

 
 

♦ By providing my e-signature, I certify that I have read and understand the Code and this Questionnaire and that my answers (and any explanations) are complete and accurate to the best of my knowledge. My answers apply to the period from my date of employment or my last submission of this form if later.

Submission Date: [ May 21, 2024 ]

 

Definitions of terms used in this form:

"Hyatt" means Hyatt Hotels Corporation, all of its subsidiaries (such as Hyatt International Corporation, Hyatt Corporation, Hyatt Residential Group), and any firm in which Hyatt Hotels Corporation or a subsidiary has a business interest.

"Client" means any person or entity that buys, rents or otherwise receives any products, real estate or services from Hyatt, including joint venture partnerships.

"Competitor" means any person or entity that offers or sells the same or similar types of products and services as Hyatt.

"Confidential Information" means confidential and proprietary information including, but not limited to, Hyatt's financial information, investment opportunities, investment positions, business plans and strategies, business track record, acquisition information, prospect information, due diligence files, sales plans, marketing plans, information concerning actual and prospective customers and suppliers, pricing information, personnel information, trade secrets, and other secret or confidential operational, management, personnel, financial, accounting, marketing or tax information and any compilations thereof relating to the business or operations of Hyatt ("Confidential Information")

"Family" with respect to any individual means that individual's spouse, domestic partner, parents, children, siblings, mothers- or fathers-in-law, or brothers- or sisters-in-law or anyone (other than domestic help) who shares such individual's home.

"Third party" means any Client, franchisee, hotel owner, Competitor, Vendor, supplier, customer, or business partner of Hyatt.

"Vendor" means any person or entity, including independent contractors, that sells, rents agrees to furnish, or has sold, rented or agreed to furnish any goods, materials, merchandise, supplies, machinery, equipment, real estate, credit, or insurance to Hyatt. "Vendor" also includes any person or entity that is performing or has performed any services for Hyatt including Hyatt Hotels Corporation's independent audit firm, Deloitte & Touche, LLP.

Reporting Wrongdoing

If you suspect improper conduct on the part of another employee, supplier, customer, or government representative, you may report it

Manager's Responsibilities

Every employee is responsible for following the Code, but if you supervise employees, you are responsible for ensuring that they also follow the Code. This means that you must establish the proper environment of ethics and mutual respect. You should ensure that your employees receive the proper training in compliance subjects related to their job. You should also make sure that they are comfortable in asking questions or reporting suspected wrongdoing.

 

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