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Travelport code of business conduct and ethics

Policy and code guidance

Compliance and Ethics

Dear Travelport Colleague

Travelport is subject to legislation around the world such as the UK Bribery Act, the US Foreign Corrupt Practices Act and other laws and regulations. This Code of Business Conduct and Ethics gives guidance to all Travelport employees to ensure they understand the expectations of the Senior Leadership Team. It covers both how we conduct ourselves as well as the right way to act in our daily lives at Travelport.

Fostering a culture that inspires and empowers every employee to do the right thing – even when it is not the easy option – is also one of the responsibilities of the Travelport Senior Leadership Team. You can be confident that any issues you bring to our attention will be resolved, and any concerns you raise in good faith will be taken seriously without any fear of retaliation.

Whatever role you play in the company, when it comes to ethics, it is the responsibility of each and every one of us to take the lead. Being a good ethical leader means recognizing Travelport’s Code of Business Conduct and Ethics principles, making good decisions based on these principles and demonstrating these principles in what we say and do. It’s all about how we conduct ourselves and the ethical standards to which we hold ourselves.

Our principle of acting with integrity every day promotes our good reputation, and we are committed to this in both words and actions. I firmly believe that if we always keep to our principles of integrity, fairness, honesty and respect, then we are far more likely to make the right decisions in our day to day work for Travelport. These principles are clearly outlined in further detail in this Code and in the Code Guidance documents.

Sincerely,

Travelport Senior Leadership Team


Introduction

Travelport is committed to the highest standards of compliant and ethical conduct in its business dealings. The Code of Business Conduct and Ethics (“Code”) and its Guidance documents set forth the company’s expectations of its employees and are the foundation of our Compliance and Ethics Program (“Program”). The Code and its Guidance documents supersede any and all previous codes of conduct and similar documents of Travelport, its subsidiaries and their predecessors. Unless otherwise required by law, to the extent any Travelport enterprise, business or local policies, customs or practices conflict with the Code, the Code shall prevail.

Does the Code Apply to Me?

The Code applies to everyone

The Code is designed to assist Travelport employees, officers and directors in conducting their daily activities ethically and legally. A large part of the Code is based on the legal obligations of either Travelport or its employees (or both), and as such, compliance with the Code may assist in protecting an individual should an investigation by the relevant authorities occur. However, as a global company, we must recognize that there are differing laws throughout the world, and employees are expected to comply with the Code only to the extent that applicable law allows. You should take the opportunity to check with your manager or Legal if you are at all unsure. The Code represents part of Travelport policies and procedures, and to this extent, it is binding on all Travelport employees. The Code does not, in any way, constitute an employee contract or an assurance of continued employment and is not intended to and does not give rise to any contractual rights. For additional requirements specific to countries or regions, please consult regional guidance posted on Homeport.

Will the Code Tell Me Everything I Need to Know?

The Code is not intended to cover every situation that might arise, nor will it take account of every legal requirement but is intended to help employees make the right decisions and ask the right questions.

What Happens if I Don’t Comply with the Code?

It is the responsibility of all employees to know, understand, and comply with the Code, subject to applicable law. Each new and current Travelport employee will be required to certify annually that he or she has read, understood and will comply with the Code and all Guidance documents, as well as the Cyber Security and Risk policies.

Subject to applicable law, failure to comply with the Code may result in disciplinary action, including termination of employment, and in certain instances, referral to appropriate authorities.

For example, disciplinary action may be taken against any of the following persons:

  • any employee who violates the Code or applicable law, or who directs others to do so;
  • any employee who deliberately withholds relevant information, or knowingly provides false information, concerning a violation of the Code or applicable law;
  • any employee who retaliates, directly or indirectly, against another employee for reporting or investigating a suspected violation of the Code or applicable law.

Where Can I Go for Help?

If you observe or become aware of an actual or potential violation of any law, regulation, or provision of the Code, whether committed by Travelport employees, by a contractor or others associated with Travelport, it is your responsibility to report the circumstances in an appropriate and timely manner and cooperate with any investigation that might ensue. The Program is designed to foster open communications and give employees the means to report in good faith any potential violation of law or business ethics.

For assistance with compliance and business ethics matters, you should contact your immediate supervisor or manager. If he or she is unable to resolve the issue or if you are uncomfortable discussing the issue with your supervisor or manager, the General Counsel is available to assist you. You may also seek assistance from Human Resources or Legal, by contacting complianceandethics@travelport.com, or by calling the “Integrity Line.”

What Is the Integrity Line?

The Integrity Line is a service established by Travelport to enable employees to make confidential reports of possible violations of the Code.

While the Integrity Line does not replace the existing reporting channels, it may be used to report matters you believe are not being resolved through existing channels as outlined above. The Integrity Line’s number is +1 855 224 4258. All countries can dial the number directly. The Integrity Line is available 24 hours a day, seven days a week and is staffed by an outside, independent organization. Calls are answered in local languages where possible.

You may place calls to the Integrity Line to report actual or potential violations of the Code, including concerns regarding accounting, auditing and financial reporting matters. If an employee calls the Integrity Line, a call specialist will listen to the report or inquiry, make a detailed summary of the call and forward the information to the appropriate individual(s) within Travelport to look into the matter. Every effort will be made to keep the identity of anyone reporting an actual or potential violation confidential to the extent permitted by law, unless doing so will prevent Travelport from fully and effectively investigating suspected misconduct or taking appropriate action in response. The Integrity Line will not record calls or use call identifiers.

You may also report possible violations via the internet at the following webtext address:

https://iwf.tnwgrc.com/Travelport.

All reports in to the Integrity Line are investigated. Where malicious claims are made, appropriate disciplinary action will be taken where appropriate.

What is complianceandethics@travelport.com?

complianceandethics@travelport.com is a mailbox that is available to all employees. Use this mailbox to ask questions or get advice on Compliance and Ethics related matters. The mailbox is monitored by the Compliance and Ethics team, who will respond to your query or engage someone who will be able to help.