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Human Resource Policy Applies To:  Hotels

Policy No: 0001 Effective Date: 02/2014

Starwood Cares for the Community Volunteer Policy

 CCC

 Corporate  Divisional & Regional Offices (including SVO) Page 1 of 7

Program Purpose and Scope: The Starwood Cares for the Community Program offers full-time and part-time Starwood associates the opportunity to engage in meaningful volunteer work that creates a positive difference in the communities where we operate. The program is designed to enhance associate engagement and foster company pride and personal enrichment. The following policy outlines the key aspects of the program for associates, including eligibility and program requirements. For questions or further information, please visit the Starwood Cares website (the “Starwood Cares for the Community Portal”) or reach out to your divisional Starwood Cares for the Community contact. 

Scope of Volunteering Activities - Definitions o “Individual and Group Activities”: Volunteer opportunities offered by a charitable organization to Starwood associates for individual or group engagement. Activities are optional and may be organized by an associate, hotel champion or Starwood Cares Committee member and offered through the Portal for associate sign-up. o “Department Community Service”: A Starwood department wide volunteer activity coordinated with an eligible charitable organization. Activities may be optional or mandatory and will be selected by the department. o “Starwood Volunteer Day(s)”: Company (or division) wide day dedicated to volunteer services with selected charitable organizations. Activities may be optional or mandatory and will be selected by the local Starwood Cares Committee in conjunction with local senior leaders.



Use of the Starwood Cares for the Community Portal o Use of the Starwood Cares for the Community Portal will be treated as compensable work time to the extent required by applicable law. o Managers retain discretion to limit the amount of time associates spend during work hours on the Starwood Cares for the Community Portal. o For non-exempt and/or hourly paid associates (meaning, associates eligible for overtime under U.S. and/or applicable state wage and hour laws, or otherwise paid on an hourly basis):  Non-exempt and/or hourly associates may access and use the Starwood Cares for the Community Portal only during regularly scheduled work hours, on Starwood-provided equipment, and with manager approval. All time

Human Resource Policy Applies To:  Hotels

Policy No: 0001 Effective Date: 02/2014

Starwood Cares for the Community Volunteer Policy

 CCC

 Corporate  Divisional & Regional Offices (including SVO) Page 2 of 7

spent by non-exempt associates on the Starwood Cares website must be recorded in the timekeeping system. By accessing and using the Starwood Cares for the Community Portal, non-exempt associates are acknowledging that their time spent on the website will occur only during scheduled work hours, on company-provided equipment, and will be recorded by them in the timekeeping system.  Volunteering During Work Hours While all associates may participate at their option in the volunteer opportunities through Starwood Cares for the Community during non-working hours, many properties and offices around the world offer volunteer activities for associates that occur during the work day as well. The availability of volunteer events during working hours varies by location, and is within the sole discretion of the location1. Where such opportunities are available, associate participation is optional, unless specifically noted otherwise by your manager. If you are interested in attending a volunteer activity that occurs during your regularly scheduled work week, speak with your manager to obtain approval and discuss coverage requirements. Volunteering in an activity during your normally scheduled business hours will be compensated as hours worked. Participation in such activities requires manager approval. Program requirements and eligibility are included below. o

Volunteer activities that occur during work hours must be planned with eligible charitable organizations (see “Charitable Organization Eligibility” requirements).

Program Requirements

1

For Corporate Office and CCC Associates, please click here to view Appendix A: Starwood Cares Corporate Office Volunteer Hour Program Reference for further detail.

Human Resource Policy Applies To:  Hotels

Policy No: 0001 Effective Date: 02/2014

Starwood Cares for the Community Volunteer Policy

 CCC

 Corporate  Divisional & Regional Offices (including SVO) Page 3 of 7



To participate in a volunteer activity that occurs during work hours, the following program requirements apply: o Participating in a volunteer activity should not incur hours in excess of your regularly scheduled work days. o Volunteer time must not:  conflict with the peak work schedule or other work related responsibilities  create need for overtime  cause conflicts with other associates’ schedules o Volunteer time during work hours must be approved in advance by an associate’s Manager to help with the coordination of other work related responsibilities. o Volunteer events must be selected through the Starwood Cares Community Portal, accessible through StarwoodOne, and hours spent volunteering for such events must be logged in the Portal to remain eligible for the program.



Associate Eligibility o All full-time and part-time associates globally are eligible to participate in the Starwood Cares for the Community Program and will have access to the Starwood Cares Community Portal. o Contractors and Temporary workers do not have access to the Starwood Cares Community Portal and are not eligible to participate in the Starwood Cares for the Community Program. In certain instances Contractors and Temporary workers may participate either on their own time, or during normal work hours, in an activity that is organized through the Starwood Cares for the Community Program. In order for a Contractor or Temporary worker to participate in any activity organized through the Starwood Cares for the Community Program that occurs during work hours, there must be a written agreement by both Starwood and the Contractor or Temporary worker’s actual employer, authorizing the participation, and defining whether the hours spent participating will be billable to Starwood. All participants must utilize the Starwood Cares Community Portal to sign up for volunteer activities and track hours to remain eligible for program benefits. 

Charitable Organization Eligibility

Human Resource Policy Applies To:  Hotels

Policy No: 0001 Effective Date: 02/2014

Starwood Cares for the Community Volunteer Policy

 CCC

 Corporate  Divisional & Regional Offices (including SVO) Page 4 of 7

o o



Organizations must be approved 501(c)(3) or international equivalent. The following types of organizations are not eligible for any group or individual community activity that occurs during work hours:  Fraternal groups  Organizations with religious affiliations  Organizations not open to the public  Organizations involved in political lobbying or political elections

Liability & Waivers o To be eligible to participate in volunteer activities, all participants must opt-in to the program acknowledging potential risks associated with volunteering and approving personal information to be shared with an external vendor for the Starwood Cares Community Portal. The risk liability waiver would not be applicable in jurisdictions in which injuries resulting from volunteer activities during work hours are covered under workers’ compensation laws.

Program Operational Details 

Volunteer Activity Funding o Some volunteer activities will require a small fee paid by an individual participant. In some instances, these costs may be covered by the Starwood Cares Committee, the location or the local department. It is the associate’s responsibility to ensure fees are understood and addressed appropriately prior to committing to participation in an activity.



Additional Programs o Award & Recognition Program:  To celebrate and highlight the volunteer efforts of Starwood associates, a recognition program has been created to showcase the dedication of individuals and teams making a difference in the community and those who have gone the extra mile to give back. More information is available on the Starwood Cares Community Portal resources page.

Human Resource Policy Applies To:  Hotels

Policy No: 0001 Effective Date: 02/2014

Starwood Cares for the Community Volunteer Policy

 CCC

 Corporate  Divisional & Regional Offices (including SVO) Page 5 of 7



Starwood Logo Items o In some locations, Starwood Cares apparel may be available. Apparel is for utilization during Starwood volunteer activities. You may be offered the opportunity to receive or purchase apparel such as a t-shirt and Starwood Cares pin upon signing up for a volunteer activity based on availability. It is the individual’s responsibility to wash and keep the items for additional volunteer efforts. Apparel is provided at the discretion of the Starwood Cares for the Community volunteer committee and may not be available for all volunteer activities or in all locations.

These policies are guidelines only and are subject to change or elimination at the sole discretion of Starwood, as are all other policies, procedures, benefits, and other programs of our Company. These policies are not a contract, express or implied, guaranteeing employment for any specific duration. Please understand that in the absence of any restrictions in an express written contract, either you or Starwood may terminate the employment relationship at any time, for any reason or no reason, with or without cause or notice. This is known as employment-at-will. No Supervisor, Manager, or Representative of Starwood other than its Executive Vice President, Human Resources has the authority to enter into any agreement with you for employment for any specified period of time or to make any promises or commitments contrary to the foregoing or that purport to alter the at-will nature of your employment. Further, any employment agreement entered into by Starwood’s Executive Vice President, Human Resources shall not be enforceable unless it is a formal written agreement and is signed by you and him/her.

Human Resource Policy Applies To:  Hotels

Policy No: 0001 Effective Date: 02/2014

Starwood Cares for the Community Volunteer Policy

 CCC

 Corporate  Divisional & Regional Offices (including SVO) Page 6 of 7

Appendix A Starwood Cares for the Community Contact Information Corporate Office Starwood Cares Committee Location (City, Country) Asia Pacific (APD) Bangkok, Thailand Guangzhou, China Gurgaon, India New Delhi, India Shanghai, China Singapore, Singapore Tokyo, Japan Europe, Africa & Middle East (EAME) Brussels, Belgium Cork, Ireland Dubai, UAE London, England Venice, Italy Vienna, Austria The Americas (NAD & LAD) Austin, USA Chicago, USA Fall River, USA Honolulu, USA Miami, USA Atlanta, USA Omaha, USA Orlando, USA Stamford, USA

E-mail Address [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected]

Human Resource Policy Applies To:  Hotels

Policy No: 0001 Effective Date: 02/2014

Starwood Cares for the Community Volunteer Policy

 CCC

 Corporate  Divisional & Regional Offices (including SVO) Page 7 of 7

St. Thomas, Canada Wichita, USA Corporate New York, USA (Varick & Digital) New York, USA (GSO) Braintree, USA Scottsdale, USA Tustin, USA

[email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected]

Starwood Cares for the Community Divisional Contact Information: Division Asia Pacific EAME The Americas Global Team

Contact Name Ritu Verma Sylvia Simar Sarah Cannon- Foster Jennifer Gibbs

Contact Email [email protected] [email protected] [email protected] [email protected]