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What Must I Do to Support the Code?

Integrity Everyday!

Leaders at all levels of the organization must:

• Create a culture of compliance in which employees understand their responsibilities and feel comfortable raising concerns without fear of retaliation.
• Encourage ethical conduct and compliance with the law by personally leading compliance efforts.
• Consider compliance efforts when evaluating and rewarding employees.
• Ensure that employees understand that business results are never more important than ethical conduct and compliance with policies.

All employees represent the Company and must behave in a manner that does not damage the Company’s reputation. The Code describes how Travelport expects its employees to behave and as such, represents the standards that employees must observe. In addition, all third parties that do business with Travelport will be expected to observe the principles of the Code.

Any request for a waiver from a provision of the Code by an Executive Officer or Board Member of Travelport must be made in writing and sent directly to the Chief Compliance & Ethics Officer, who will refer the waiver request to the Board of Directors or a designated Committee, which has sole responsibility for granting or denying such waivers. Any other requests for an exception on ethical provisions of the Code must be directed to the Office of the Chief Compliance & Ethics Officer.