ESG PROGRESS AT MARRIOTT INTERNATIONAL → 55 2021 SERVE 360 REPORT Business Ethics Marriott maintains policies and training programs targeting anti-corruption as a key component of our robust Global Ethics and Compliance program. We use a risk-based approach to perform anti-corruption risk assessments, determine proper internal controls, including policies and procedures, provide multilayered training and assess effectiveness through auditing and testing to update and enhance the program as needed. Policies and Procedures We strive to maintain our strong tradition of integrity, one of Marriott’s core values, in everything we do to provide associates, customers, and business partners with a fair, honest, and ethical environment. We have policies prohibiting commercial bribery and bribery of government officials. These policies require associates to comply with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (“FCPA”), the U.K. Bribery Act, the PRC Anti-Unfair Competition Law (China), and the laws of other countries where we have business operations. Our policies prohibit making or receiving improper payments or gifts, and further prohibit giving or offering anything of value to foreign officials for the improper purpose of influencing any decision to benefit the company or to encourage unlawful conduct. Additional guidance regarding our commitment to ethical conduct, honesty, fair dealing, and legal compliance is described in our Ethical Conduct Policy and Business Conduct Guide (BCG). The BCG provides an overview of key ethics and legal compliance policies, as well as guidance on not only what is legal but also what is right. Associates are required to read both documents and fully adhere to our ethics and legal compliance policies. It is vitally important for them to understand Marriott’s ethical and legal standards so they can make the right business decisions and uphold our tradition of integrity. Training and Awareness Marriott employs a multilevel approach to training and awareness, including in-person instructor-led training, online training courses, and instructor-led webinars. Our anti-corruption focused training includes all these modalities and most associates that are manager level and above at Marriott managed hotels globally are required to certify completion of online anti- corruption training annually. Our instructor-led webinar training program is delivered periodically to key managers in high-risk jurisdictions on a risk-based basis. In addition, new executive and leadership team members receive small group training sessions to promote discussion and full understanding of our anti-corruption policies. We reinforce our training and Marriott’s culture of integrity with awareness messages directly from our leadership to our global workforce. Additionally, all associates upon their hiring must review a mandatory Ethics and Compliance video, “How We Do Business,” that describes the company’s longstanding tradition of uncompromising ethics and integrity. On an annual basis, our Internal Audit Department also conducts two Legal and Ethical Conduct Surveys. The first survey is distributed to Marriott’s Top 250 leaders as well as the Board of Directors and select General Managers of managed hotels. The purpose of this survey is to certify their compliance with laws and regulatory requirements, and Marriott’s standards and policies. The second survey, which is an anonymous survey, is administered to all non-hourly associates, excluding those that participated in the first survey, and is designed to more broadly understand associate perceptions of Marriott’s ethical culture. As of year-end 2020, more than 29,000 managers have received global online anti-corruption training and thousands of other leaders attended instructor-led trainings in high-risk jurisdictions. In addition, as part of our business ethics training, approximately 11,000 associates have completed the annual online global trade sanctions training. Risk Assessments Marriott’s Internal Audit Department performs an annual risk assessment and identifies properties to be audited based on specific anti-corruption risk factors. The Internal Audit Department in coordination with Marriott’s Law Department developed and deployed a global anti-corruption property review program designed to detect issues and provide remediation actions as needed. Periodically, Marriott also issues property-level guidance to address anti-corruption risk, including protocols to mitigate third-party risk. We will continue to evaluate opportunities to improve Marriott’s compliance posture by continuously focusing on opportunities, methods, and tools for measuring, assessing, and auditing effectiveness of the compliance program (including periodically using third-party consultants and external benchmarking data). Reporting Concerns Associates are encouraged to report suspected legal, ethical, and policy violations through a number of reporting channels, including the Business Integrity Line or via email to Internal Audit. Marriott has a “No Retaliation” Policy and prohibits retaliation against associates who in good faith report suspected violations of our ethical standards or violations of law through any of our reporting channels or to government regulators or law enforcement agencies. Marriott also does not permit retaliation against an associate who refuses to participate in an activity that would result in a violation of our ethical standards, company policy, or a violation of law. Marriott’s Business Conduct Guide is made available in 15 languages globally at managed properties and to managers worldwide. An abridged, quick reference companion is also available in 31 languages globally at managed properties for nonmanagerial associates.
Serve360 ESG Report Page 54 Page 56