Ethics

Doing the right thing and acting with integrity isn’t just important, it’s who we are.

As part of our company culture, managers and employees are expected to use good judgment and behave professionally by:

Understanding and complying with the uCode of Conduct and the law Avoiding improper behavior or the appearance of it Not being a bystander and reporting violations if they are observed

We maintain a comprehensive and confidential reporting hotline for employees to raise concerns without fear of retaliation.

Our employees can confidentially report any concerns, which are then investigated in accordance with company policies and procedures. We have a zero-tolerance policy for retaliation, direct or indirect, against any employee who makes a goodfaith report or cooperates with investigations concerning misconduct, ethics-related issues, or illegal practice.

Employees have a variety of ways to seek further guidance or make a report of unethical behavior:

Speak directly with a manager, Human Resources

Business Partner, or any other appropriate member of management or Human Resources professional.

Make a toll-free call to the Integrity Helpline to report a concern confidentially and anonymously or to ask a question.

Report directly to the Vice President of Corporate

Audit Services or the General Counsel.

Online at uwww.expedia.ethicspoint.com. EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX Global to assist management and employees to work together in addressing unethical, illegal or unsafe activity, and other suspected misconduct in the workplace.

All reports remain secure and anonymous and are entered directly on its secure server to prevent any possible security breach.

For more information on our ethics policy, including how we ensure a culture of nondiscrimination, protect business and financial records, prevent money laundering and insider trading, avoid conflicts of interest, and more please see our uCode of Conduct.