Code of Conduct

Preface

As one of the leading German hotel groups, Maritim Hotelgesellschaft mbH (hereinafter referred to as Maritim) takes upon itself to observe its social and ethical responsibilities in every way. We are concerned about the people who are involved in compiling and disseminating our services worldwide within our service chain. It is therefore important to us that the trade name Maritim should always be associated with respect for human rights, fair working conditions and environmentally responsible business practices. Maritim is of the opinion that people who contribute to our success through their work have a guaranteed claim to basic human rights and must not be physically or mentally injured in the course of their work. Maritim expects an employer to respect basic human rights and to treat thier employees fairly and with respect.

This Code of Conduct applies to all Maritim departments and operating sites, and Maritim’s suppliers and business partners. As an internationally active company, we are obliged to ensure that this Code of Conduct is observed and applied worldwide.

1. Adherence to laws and ethical principles

Maritim's suppliers and other business partners adhere to the various legal systems applicable to them. They support the principles of the "Global Compact" of the United Nations, the UNO's General Declaration of Human Rights and the Declaration of the International Labor Organization on Fundamental Principles and Rights at Work in accordance with national laws and conventions.

This particularly applies to the content of the points discussed below.

Corruption and bribery forbidden

Maritim does not tolerate any form of corruption or bribery, including any illegal offers of payment or similar benefits with the aim of influencing decision-makers. Maritim expects its suppliers and other business partners to adhere to international anti-corruption standards as laid down in the "Global Compact" of the United Nations and in local anti-corruption and anti-bribery legislation.

Essentially, Maritim expects its suppliers and business partners to adhere to the following principles:

• Maritim's employees do not accept any payments in kind, monetary payments, loans, non-monetary gifts (such as holidays, invitations to events or other privileges), nor any services that would provide them with a personal benefit, from suppliers, business partners and other third parties. This rule also applies to family members of the employees and other associated persons, partners and close relatives. Promotional gifts of a low value constitute an exception. Any doubts should be discussed with the employee's supervisor.
• Samples and test products may not be offered or handed over for direct private gain of Maritim employees or their relatives.
• Gifts, favours and other payments in kind may only be offered and handed over by suppliers and business partners for the benefit of Maritim's business operations and business assets and then only within the legal framework constituted by the normal customs and conventions of day-to-day commercial life.

3. Invitations to Maritim events

Customer events are held several times a year to present Maritim's product portfolio. These promotions and/or events are of an official nature and their value is in keeping with the principle of "business norms". The relevant data-protection regulations must be strictly adhered to when inviting customers.

3a. Benefits for office bearers

Public servants and politicians are excluded from the above in principle and may not be invited unless the person in question has expressed a wish to the contrary, which has been duly documented.

4. Observance of basic rights of employees

Anyone who works directly or indirectly for Maritim has a claim to the protection of their basic human rights. No employee may be discriminated against on the basis of their age, race, sex, religion, sexual orientation, marital status, parenthood, political opinion or ethnic origin.

Maritim rejects child labour, forced labour or the employment of illegal labour as well as any psychological or physical disciplinary measures. Maritim condemns any type of harassment and/or bullying. Any occurrences of this kind will result in the immediate suspension of business relations with suppliers or business partners once they become known.

Maritim and its business partners and suppliers adhere to the various national laws and regulations governing working hours, salaries and wages and benefits offered by employers. In particular, this means that Maritim complies with statutory regulations and collective wage agreements. In addition to various occupational safety regulations, it also adheres to the minimum wage law in force since 1 January 2015 and pays at least the legal minimum wage.

5. Health and safety of employees

The health and safety of its employees constitutes the top priority for Maritim. It is thus expected that suppliers and other business partners will strive for the implementation of occupational health and safety regulations at a high level, will adhere to the relevant occupational health and safety regulations and will ensure a safe working environment that is conducive to good health, serving to maintain the health of employees and to avoid accidents, injuries and work-related illnesses.

6. Environmental protection

Maritim recognised at an early stage that the careful use of resources constitutes an important contribution to securing the future of our society. All our premises therefore take steps to save energy, avoid unnecessary waste and protect the environment. Maritim expects its suppliers and business partners to adhere to the legal requirements and international standards regarding environmental protection and to all relevant environmental legislation. You will find further information under the heading "Environmental Protection" at www.maritim.com

7. Planning corporate continuity

Maritim expects its suppliers and other business partners to be prepared for operating disruptions of any kind (e.g. natural catastrophes, terrorism, computer viruses, illnesses, pandemics, infectious diseases) and, in particular, to draw up contingency plans to protect their employees and the environment as far as possible against the effects of any catastrophies that may occur in their operating environment.

8. Dialogue with business partners

This Code of Conduct is a public document and is to be presented as such, so that everyone involved in compiling and marketing our services is familiar with the ethical principles set out in this document. Our suppliers and other business partners must ensure that employees and subcontractors involved with Maritim know these guidelines and adhere to the rules.

9. Confidentiality

Maritim business partners and employees are in possession of confidential and sensitive information or may acquire such information and in this respect are therefore obliged to maintain confidentiality. This information may concern business strategies, information about suppliers, personnel issues, procedures and methods, among other things. Proprietary, confidential and sensitive information about Maritim and its employees must be handled discreetly and may only be passed on to persons who need it for reasons related to their activities.

10. Adherence to Code of Conduct

Maritim reserves the right to check adherence to the requirements of this Code of Conduct for suppliers and business partners after giving appropriate notice. Maritim's suppliers and other business partners will in turn help their suppliers to adhere to the ethical standards, human rights, occupational health and safety and environmental standards on which these guidelines are based, within the framework of fulfilling their contractual obligations. The supplier / business partner is responsible for his own delivery chain. Any violation of the obligations mentioned in the Code of Conduct for suppliers and other business partners will be regarded as a substantial breach of contract on the part of the supplier or other business partner.

Revised: January 2014