Human Rights Policy Statement

At Hilton Grand Vacations (HGV), we’re committed to protecting the rights of our team members, owners and guests. We subscribe to the principles set forth in the United Nations Universal Declaration of Human Rights and have established policies and procedures that adhere to those guidelines. Our Code of Conduct and Procurement Policy lay out clear guidelines for our team members and suppliers, and we’ve established a robust training and auditing program to ensure continued compliance. Within our workplace, we strive to create an environment of inclusion for our team members that promotes diversity to strengthen our core values and competitiveness.

We’re in the business of people serving people. Upholding and respecting the human rights of all people is a cornerstone of our mission. We’re committed to continuous improvement through an annual review process, and to engaging with all of our stakeholders – including owners, team members, and shareholders – as we pursue our mission.

Human Trafficking

We condemn all forms of human trafficking, and we educate our team members on how to spot and report the signs of such activity through rigorous training and annual re-certification programs. Developed with the guidance of the American Hotel & Lodging Association and leading anti-trafficking organizations such as ECPAT and Polaris, our training program is available via our UFirst education platform and is an annual requirement for all front-line team members and managers. In addition, all property general managers must certify that their reporting team members have completed their annual training requirements. This training is reinforced with posted reminders in team member areas highlighting key indicators of potential human trafficking, and we provide numerous resources for reporting suspected activity including in-person with property management, our EthicsPoint hotline, and the National Human Trafficking Hotline.

We fully support the fundamental rights of all people as laid out in our Code of Ethics:

• We won’t employ individuals under 15 years of age or the lawful age of employment (whichever is higher) in any country in which we operate. We expect our suppliers and business partners to commit to the same threshold.
• We comply with all wage and compensation requirements as defined under applicable local laws and regulations, including those relating to minimum wages, and provide legally mandated benefits at a minimum.
• We won’t exceed maximum hours of work defined by applicable law and will appropriately compensate overtime.
• We won’t use forced labor, including prison, bonded or debt labor.
• We won’t allow physical punishment or abuse of any team member.
• We respect the ability of team members to exercise their lawful right of free association.
• We respect the lawful rights of our team members to choose (or not choose) collective bargaining representation.

We’re committed, in each market in which we operate, to protecting individuals from all forms of abuse and exploitation. We expect our team members as well as our business partners to help us meet this commitment. Sex trafficking and sexual tourism is a large and growing problem worldwide, and HGV won’t allow any of its properties, products, or services to be used in any manner that supports or enables any form of abuse and exploitation.

Diversity and Inclusion

We seek to understand the communities in which we work while developing culture, talent and marketplace strategies that cultivate a work environment of inclusiveness. We’re an Equal Opportunity Employer and believe that we’ll only maintain our competitive position by valuing and leveraging the diversity of our team members and applying our core values to attract the best and brightest talent. Since our inception, we’ve been an Equal Opportunity Employer and have taken steps to ensure that:

• People are recruited, hired, assigned and promoted without regard to race, religion, color, national origin, citizenship, sex, gender identity, veteran status, military status, age, disability, genetic information or any other protected group status.
• All other personnel actions such as compensation, benefits, transfers, layoffs and recall from layoffs, access to training, education, tuition assistance and social recreation programs are administered without regard to race, religion, color, national origin, citizenship, sex, gender identity, veteran status, military status, age, disability, genetic information or any other protected group status.
• Team members and applicants won’t be subjected to harassment, intimidation, threats, coercion or discrimination because they have: (1) filed a complaint; (2) assisted or participated in an investigation, compliance review, hearing or any other activity related to the administration of any federal, state or local law requiring equal employment opportunity; (3) opposed any act or practice made unlawful by any federal, state or local law requiring equal opportunity; or (4) exercised any other right protected by federal, state or local law requiring equal opportunity.

Our commitment to diversity goes beyond our requirements as an employer and a public company. We’re in the business of serving people and believe that fostering diversity and inclusion helps to provide the best levels of service to our diverse base of members and guests.

We have established Team Member Resources Groups (TMRGs) as an integral component of HGV’s culture of inclusion, representing a broad range of perspectives. Our empowered TMRG team members foster respect, openness, integrity and a sense of fun in the workplace. The TMRGs are sponsored by our executive leadership and are committed to working with the HGV family and serving their communities to celebrate the diversity of our workforce.

Current HGV TMRGs:

• African American
• Asian and Pacific Islander
• Hispanic/Latino
• LGBTQ and Friends
• Military
• Women’s

Supplier and Partner Requirements

We hold our partners and suppliers to the same high standards we’ve set for ourselves. To that end, all suppliers are required to maintain the same labor standards laid out in our Code of Ethics and detailed above. Specifically, our suppliers and business partners:

• Won’t employ individuals who are under 15 years of age or the lawful age of employment (whichever is higher) in any country in which we operate.
• Must comply with all wage and compensation requirements as defined under applicable local laws and regulations, including those relating to minimum wages, and provide legally mandated benefits at a minimum.
• Won’t exceed maximum hours of work defined by applicable law and will appropriately compensate overtime.
• Won’t use forced labor, including prison, bonded or debt labor.
• Won’t allow physical punishment or abuse of any employee.
• Will allow the ability of employees to exercise their lawful right of free association.
• Will respect the lawful rights of their employees to choose (or not choose) collective bargaining representation.

In addition, the HGV Procurement strategy supports the use of qualified, competitive diverse suppliers. It is the policy, privilege and practice within HGV to build relationships with diverse suppliers capable of providing quality materials and services at competitive prices. Subject to the laws and customs to the regions in which we operate, we expect our suppliers to not tolerate any discrimination, harassment or retaliation against any individual or group on the basis of ethnic, gender, racial, religious or cultural factors, or any other characteristic protected by applicable law. We maintain a Supplier Diversity Program for our U.S. suppliers and, where appropriate for the goods and services involved, every effort is made to include at least one qualified woman and minority business enterprise supplier if identified in the bidding process.