WIXLIB

IHG Modern Slavery Statement 2020 6Our Code and PoliciesAs part of our commitment toresponsible business, we have a numberof group-wide policies and proceduresin place that help govern our approachto human rights and modern slavery. It isvery important to us that our policies areaccessible, which is why we havetranslated them into multiple languagesand made them available to all IHGbranded hotels via our companyintranet. The policies are also publiclyavailable at www.ihgplc.com.OUR VALUESDo theright thingAimhigherShowwe careCelebratedifferenceWork bettertogetherCode of ConductThe IHG Code of Conduct, available in 10languages, sets out the principles we must all workby at IHG, wherever we are in the world. The Ethicsand Compliance Team oversee the Code ofConduct, which provides information on our keyprinciples and global policies, including humanrights, diversity and inclusion, respect in theworkplace, information security, anti-bribery andthe environment.All colleagues working in IHG corporate offices,reservation centres and managed hotels mustcomply with the Code and the policies andprocedures it refers to. Violations are treatedseriously, and they may result in disciplinary actionbeing taken which, in some cases, may includedismissal in accordance with our internal policiesand local labour and employment laws. Theprinciples, spirit and purpose of the Code arerelevant to all of IHG and we expect those we dobusiness with, including our franchisees, to upholdsimilar standards.The Code reinforces our values – a set of everydaybehaviours based on principles that are importantto our colleagues and our guests. It also sets outour zero-tolerance approach to human rightsabuses, including forced labour, any form ofmodern slavery or the exploitation of children.Our Code of ConductThe way we workat IHG, whereverwe are in the world Click to view our Code of Conduct.Human Rights PolicyIn 2019, with assistance from a specialist businessand human rights consultancy, Article One, wesignificantly updated our Human Rights Policy.IHG’s Human Rights Policy sets out ourcommitment to respecting human rights inaccordance with the Universal Declaration ofHuman Rights, the International Covenant on Civiland Political Rights and the International LabourOrganisation’s (‘ILO’) Declaration on FundamentalPrinciples and Rights at Work. Our approach is alsoinformed by the Guidelines for MultinationalEnterprises of the Organisation for EconomicCooperation and Development (‘OECD’), the UNGlobal Compact and the UN Guiding Principles onBusiness and Human Rights (‘UN GuidingPrinciples’).We recognise that human rights due diligence isan ongoing commitment, and our Policy identifieskey risks and areas where IHG has an opportunityto help develop and influence the protection ofhuman rights.IHG’s Human Rights Policy condemns andprohibits any form of human trafficking, includingthe commercial sexual exploitation of children, andemphasises our commitment to compliance withall applicable laws and regulations regarding theprevention of human trafficking.

IHG Modern Slavery Statement 2020 7Our Code and Policies continuedFollowing IHG’s public commitment in 2018, theSustainable Hospitality Alliance’s (‘SHA’) Principlesof Forced Labour have also been explicitlyincorporated into our Human Rights Policy. ThePrinciples are:Human Rights Brand StandardIHG’s Brand Standards are rules relating to each ofIHG’s brands that enable hotels to deliver aconsistent guest experience. In 2014, we introduceda Human Rights Brand Standard for all IHG-brandedhotels, requiring implementation of a Human RightsPolicy. To reflect the evolution of IHG’s HumanRights programme, in 2020 we updated theresources supporting the standard to focus on thosehuman rights areas most relevant to hoteloperations, key responsible recruitment practicesand principles to combat forced labour andanti-human trafficking. The materials are available inover 20 languages to enable colleagues, includingmigrant workers, to more easily understand andreview them. To raise awareness of labour sourcingrisks, we have made the SHA’s ‘ResponsibleRecruitment’ e-learning and ECPAT USA and Polaris’‘Preventing Human Trafficking’ e-learning availableto all IHG-branded hotels (in 12 languages).1. Every worker should have freedom ofmovement. The ability of workers to move freelyshould not be restricted by their employerthrough abuse, threats and practices such asunlawful retention of passports and valuablepossessions.2. No worker should pay for a job. Fees and costsassociated with recruitment and obtainingemployment should not be paid by workers.3. No worker should be indebted or coerced towork. Workers should work voluntarily, beinformed of their employment terms andconditions in advance withoutmisrepresentation and paid regularly as agreedand in accordance with any applicable laws andregulations.In addition, in response to Covid-19 we developedguidance for hotels to specifically address migrantworker risks, in particular in relation to hotel staffaccommodation. Supplier Code of ConductIHG’s Supplier Code of Conduct was updated in2019 and sets out the standards under which IHGsuppliers are expected to operate. Where hotelscontract directly with suppliers, they areencouraged to seek adherence to similarprovisions to those set out in the Supplier Code ofConduct.Under the Supplier Code of Conduct, IHGsuppliers are expected to support the protection ofhuman rights through their business activities withrespect to forced labour and human trafficking,child labour, freedom of association, nondiscrimination, and safety and security of theworking environment.IHG expects suppliers to adhere to these standardsboth within their own business and across theirsupply chains. Whilst we aim to work with suppliersto resolve any issues identified, material breachesof the Supplier Code of Conduct may lead totermination of a supplier’s contract with IHG. Oursuppliers are required to confirm their acceptanceto our Supplier Code of Conduct at the supplieronboarding stage, in addition to it being acontractual requirement.Human ResourcesWe value our colleagues as unique individuals whobring different ideas and perspectives, and IHG iscommitted to providing equality of opportunitywithout discrimination. For more details, see the section ‘Risk Assessment’. Click to view our human rights policy.Our Human Resources practices include a set ofinternal principles – the IHG Way of Hiringguidelines – which support both corporate andmanaged hotel colleagues to recruit newcolleagues. We clearly state on our careers websitethat IHG does not ask candidates for any feesassociated with the recruitment process. To furthersupport candidates in avoiding recruitment scams,we provide additional details on how to spot andreport anything suspicious.

IHG Modern Slavery Statement 2020 8Our Code and Policies continuedReporting concernsIHG is committed to proactively avoiding humanrights infringements within our sphere of influence.However, where we have caused or contributed toadverse human rights impacts, we are committedto providing effective remedy.It is important that our colleagues and any personthat has a relationship with IHG, including oursuppliers and their workers, feel comfortablereporting ethical concerns. To facilitate this, wehave a confidential reporting channel to share anyethical concerns or breaches of the IHG Code ofConduct, including in relation to human rights andmodern slavery. We do not permit retaliationagainst employees making good faith reports ofsuspected breaches of the IHG Code of Conductor IHG policies, even if it may result in a loss ofbusiness to IHG.This channel is available to all IHG-branded hotelsand corporate colleagues and can be used by anyperson with a relationship to IHG, including ourthird party suppliers and contractors. We take allallegations concerning modern slavery issueswithin our hotels and supply chains very seriouslyand encourage third parties, including mediachannels, civil society organisations and others, tocontact us directly with any concerns, either viaour confidential reporting channel (ihgethics.com)or via the Ethics and Compliance team’s emailaddress (ethicsandcompliance@ihg.com). IHGcommits to undertaking inquiries for all receivedreports, which are reviewed and investigated by agroup of dedicated personnel.In August 2020, IHG was contacted by an externalhuman rights organisation, requesting a responseto allegations that workers employed by a securitycompany providing services to an IHG-brandedhotel in Doha, Qatar, were being housed in poorconditions. We reviewed the allegationsthoroughly, including checks undertaken by thehotel, and engaged directly with the supplier,including an on-site visit of the accommodation.Whilst the majority of the allegations have not beensubstantiated, we continue to engage with thesupplier on some areas of the complaint, includingcafeteria food quality and diversity, workercommunication and grievance mechanisms.Other IHG policies which are relevant to ourhuman rights programme include: Anti-bribery Policy; Global Diversity and Inclusion Policy; Supporting Our Communities Policy; and Global Procurement Policy.

IHG Modern Slavery Statement 2020 9Our due diligence processesSupply chainTo help manage and monitor our corporate supplychain, an automated procurement system is usedacross many of our large corporate offices. Inaddition to acknowledging adherence to IHG’sSupplier Code of Conduct, new suppliers beingonboarded to the system are required to completedue diligence questionnaires, which includeinformation on human rights, labour, environment,and anti-corruption.To further strengthen our commitment to growingour business sustainably and delivering long-termvalue for our owners, hotels and guests, in 2020we introduced a new set of responsibleprocurement criteria for prospective suppliers. Thepre-contract assessment is part of IHG’s tenderingprocess and includes questions about suppliers’governance, human rights and environmentalpractices relevant to suppliers’ own operations andsupply chains. The Strategic Supplier ManagementOffice (SSMO) continues to support strategicsuppliers, identified for their contractual andoperational value, via business performancereviews to promote value realisation, risk mitigationand create healthy supplier partnerships. Wecontinue to collaborate with our prospective andexisting suppliers, managing supply chain risksrelated to sustainability issues.Third-party hotel ownersWe also carry out risk-based due diligence andcompliance checks on new third-party hotelowners with whom we are entering hotelagreements. These checks include the use ofautomated screening and monitoring tools and theprovision of guidance for our legal, franchiseadministration and development teams. Escalationcriteria ensure a central committee of senior IHGdecision-makers consider and review any materialissues. This explicitly includes human rightsconcerns or allegations such as those related tohuman trafficking or forced or child labour.Contingent on any risks or concerns identified,external legal or consultancy expertise may also beutilised, including with respect to entry into newmarkets where necessary.In 2020, with the assistance of our third-partyprovider, we successfully trialled and launched anenhanced version of our due diligence riskmanagement platform, resulting in increasedautomation of internal escalation processes, fastercounterparty searches and improved adversemedia screening.Our own operationsTo continue developing our human rights duediligence approach in our own operations, in 2020we conducted a high-level mapping of theworkforce employed by our hotels in Oman andQatar to assess the potential impact of recruitmentand labour practices. In Oman we reviewed thehotels’ existing relationships with recruitmentagencies and liaised with external stakeholdersto understand the migrant worker journey ofour colleagues. For more details, see the section ‘Oman market levelassessment’.

IHG Modern Slavery Statement 2020 10Risk assessment and managementSupply chain auditsDuring 2020, we continued to progress oursupplier risk assurance programme. As part of theintroductory roll out, which began in 2018, weissued a desktop-based risk assessmentquestionnaire, made up of 65 questions, to over260 key suppliers to help us understand theirgovernance, human rights and environmentalpractices.In 2019, we reviewed responses and categorisedthem based on their risk profile, and continued thiswork in 2020, identifying key questions for whichadditional follow-up was needed. A majority of thekey questions relate to human rights risks,encompassing the topics of working hours, hiringpractices, freedom of association, health andsafety practices, working with recruitmentagencies, safekeeping employees’ original identitydocuments and freedom of movement. Werequested additional information related to thesetopics from a number of suppliers to betterunderstand their practices in certain areas. Due toCovid-19, we paused our risk assuranceprogramme to enable our suppliers and ourcolleagues to address challenges of the pandemic.We expect to re-commence our risk assuranceprogramme in 2021.Risk assessmentAs set out in our 2019 Statement, in 2018 weundertook a human rights impact assessmentacross IHG’s operations – covering our supplychains, our hotels and our corporate offices. Whilstthe assessment found that IHG has systems inplace to manage multiple human rights risks, it alsoidentified areas where IHG can improve itsmanagement of these risks. These areas included:focusing on further due diligence related to themanagement of labour risks and, in particular,migrant labour and responsible recruitment risks;and human rights risks present in the wider IHGbusiness ecosystem, including those related tohotel construction and development.In light of the unprecedented impact that Covid-19has had, and continues to have, on our businessand the hospitality and tourism sector morebroadly, in 2020 we have undertaken a review ofhow the global pandemic affects IHG’s humanrights risks and strategy, flowing from the 2018impact assessment. This review has includedobtaining input from different IHG teams,particularly those who directly support hotels, suchas Human Resources, Operations, Hotel Safety &Security, and Risk and Assurance teams; utilisingexternal sources such as the SHA; monitoringguidance published by governments and NGOs;and reviewing media on this topic to track riskareas and identify any emerging best practice.Whilst the risks identified in the 2018 impactassessment (and IHG’s strategy to mitigate them)still remain salient, the operational impact ofCovid-19 has necessitated a re-prioritisation ofcertain areas of IHG’s human rights programme inorder to address the more immediate impacts ofCovid-19. For example, migrant labour risk wasidentified as the highest priority area in relation toCovid-19, as set out further below. Some areas,such as responsible recruitment, have been lessimmediately relevant due to the impact of Covid-19on hotel operations, although it continues toremain a risk area for the industry, particularlythroughout recovery and in the medium tolonger term.

IHG Modern Slavery Statement 2020 11Risk assessment and management continuedMigrant worker riskCovid-19 has heightened risk areas relating tomigrant workers, particularly where the pandemichas resulted in temporary hotel closures or whereworkers are unable to return to their homecountries due to travel restrictions. Across theindustry, migrant workers can be particularlyvulnerable to certain human rights risks as theyoften live in staff accommodation in dormitories orshared rooms and may have less knowledge oflocal language or laws. As a result, they will beparticularly reliant on their employer forinformation and support through a crisis such asthe Covid-19 pandemic.To address the increased risks in response toCovid-19, IHG re-prioritised the development ofadditional guidance to support hotels andoperations teams to address migrant workers’needs to prevent and mitigate impact.In light of the pandemic’s impact,we increased our focus onidentifying and addressing humanrights risks for migrant workersthrough increased guidance andresources for our hotels in this area.In 2021, we will maintain our focuson working and living conditions formigrant workers, as well as topicssuch as responsible recruitment.We will also continue to engage oncollaborative industry initiatives,which are addressing these risks.Helen JonesVice PresidentEthics and Compliance, IHGThe IHG Hotel Staff Accommodation Guidancesets out health and safety considerations in thecontext of Covid-19 for IHG-branded hotels andthird-party labour providers that provide staff livingaccommodation for workers at IHG-brandedhotels. We have also produced an IHG MigrantWorker Checklist, which sets out broaderconsiderations on topics such as taking intoaccount language difficulties and ensuringeffective communications, enablingcommunication with families, repatriation andother considerations in the event of hotel closures– for example, the provision of return assistancesuch as payment of flights/travel costs for acolleague’s return to their home country.Both sets of guidance are available to GeneralManagers across all IHG hotels and hotel supportteams and have been communicated via IHG’sregional senior leadership and operations teams.The Hotel Staff Accommodation Guidance hasbeen downloaded 2,914 times (May – December2020), and the Migrant Worker Checklist 128 times(October – December 2020). We continue toengage on this topic with regional teams thatsupport hotel operations, so they are better able toidentify and escalate issues and communicateexpectations in this area, as well as monitor andassess the migrant worker risk at hotel level via ourrisk management approach and the ongoingmonitoring of the confidential hotline.Health and Safety risksConcerns related to workplace conditions in thecontext of the Covid-19 pandemic, particularlyhealth and safety, continue to be addressed byenhanced measures and processes being put inplace as hotel operations and occupancy return tohigher levels. Our hotels are working to bestpractice Covid-specific training and operatingprocedures, aligned to regularly monitored advicefrom global health bodies. We have alsostrengthened our industry leading IHG Way ofClean programme, including introducing clear PPEstandards and rolling out ad

audit. In addition, the Commercial and Technology function oversees revenue management, property systems, and digital and voice sales which are managed by our reservation call centres in locations including Manila, Baguio, Guangzhou, Mexico City and Salt Lake City. We also have some areas w