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Conflicts of Interest

All employees occupy a position of trust with the Company and, as a result, have a duty of loyalty to the Company both during and after the employment relationship. Employees are required to avoid any relationship or activity that might create or give the appearance of a conflict between their personal interests and the interests of Travelport or its subsidiaries. Travelport selects its suppliers, vendors and contractors in a non-discriminatory manner and based on appropriate quality, cost, service and ability to supply a range of goods and services. A decision to hire a supplier, vendor or contractor must never be based on personal interests or interests of family members, but must be in the best interests of Travelport.

Employees must disclose any relationship that appears to create a conflict of interest to their department manager for referral to the Chief Compliance & Ethics Officer for disposition. Employees must also obtain written pre-approval from the Chief Compliance & Ethics Officer before proceeding with any transaction, conduct or investment that creates or appears to create a conflict of interest, such as:

• Engaging in personal business transactions that arise from or are based upon an employee’s position of authority.
• Owning a financial interest (other than less than five percent of the capital stock of a public company) in a business that does business or competes with Travelport.
• Participating in an opportunity discovered from information provided by a competitor, customer or supplier.

Executive Officers of Travelport must disclose actual or potential conflicts of interest directly to the Chief Compliance & Ethics Officer or the Board of Directors or a designated Committee and obtain written pre-approval before engaging in any such transaction or conduct or making any such investment. 

In addition, an employee of the Company must seek prior written approval from the Chief Compliance & Ethics Officer before accepting an invitation to serve as a director or trustee of any other business. If such service existed at the time of hire or upon acquisition of a new company, the employee must promptly disclose the existence of such service and obtain approval to continue providing such service before doing so. Service as a director of a for-profit entity (other than Travelport and its subsidiaries) is strongly discouraged.

Here are additional examples of potential conflicts of interest that would require disclosure:

• Employee or immediate family member (includes employee’s spouse, parents, children, in-laws and anyone who shares employee’s home) acting as a director, partner, consultant or employee of a firm that provides goods or services to Travelport or is a competitor of Travelport or one of its subsidiaries.
• Holding a second job that interferes with employment duties at Travelport.
• Ownership by employees or members of their immediate family of a material financial interest, known to the employee, in a firm which is either a competitor of or vendor to Travelport or one of its subsidiaries.
• Using Travelport confidential information in any manner that violates the Company’s confidentiality policy (see Confidential and Proprietary Information).