Table of Contents

Executive Summary.............................................................................................................................3
Introduction .........................................................................................................................................4
Overview of the Hotels ........................................................................................................................5
Methodology......................................................................................................................................25
Limitation ..........................................................................................................................................25
Findings and Analysis .......................................................................................................................26
Customer Response .........................................................................................................28
Employee Response .........................................................................................................34
Response of Society.........................................................................................................39
Suppliers Response ........................................................................................................45
Summary of findings .........................................................................................................................48
FORMULATION OF CODE OF BUSINESS CONDUCT AND ETHICS FOR HOTELS ............49
Conclusion .........................................................................................................................................75
References .........................................................................................................................................76
Appendix ...........................................................................................................................................77

2|Page

Executive Summary
The objective of this paper was to formulate an ethical code of conduct for organization in a
particular industry. The industry we chose for our term paper was hotels and hospitality. We chose
5 different hotels to compare their service rules. The hotels are Radisson Water Garden, Pan Pacific
Sonargaon, Lake Shore Hotel, Hotel Washington, and Paradise Garden Hotel. We conducted
Survey on four categories of stakeholders: customers, employees, suppliers, and residents living in
nearby area where the hotel is situated. It was evident from our analysis that some of the hotels did
not maintain any service rule or ethical code of conduct, leaving door for possibility of violation of
ethics. In the end we formulated our own policy after analyzing these results. Some important
aspects of the code of conduct covered the topics of abiding by rules and regulation, preventing
conflict of interest, conducting business ethically, harassment and keeping confidentiality.

3|Page

Introduction
According to the stakeholders model, an organization has responsibility towards its stakeholders.
A business organizations stakeholders include its customers, suppliers, employees, Society,
Government, and its competitors. Stakeholder theory is a theory of organizational management and
business ethics that addresses morals and values in managing an organization.
In the traditional view of the firm, the shareholder view, the shareholders or stockholders are the
owners of the company, and the firm has a binding fiduciary duty to put their needs first, to
increase value for them. However, stakeholder theory argues that there are other parties involved,
including governmental bodies, political groups, trade associations, trade unions, communities,
financiers, suppliers, employees, and customers. Sometimes even competitors are counted as
stakeholders - their status being derived from their capacity to affect the firm and its other morally
legitimate stakeholders. The nature of what is a stakeholder is highly contested with hundreds of
definitions existing in the academic literature.
The objective of this paper was to determine the commitment a business organization from one
industry out of four, which includes hospital, education, hotels, and textile. The industry chosen for
this term paper is hotel. We chose 5 different hotels to compare their service rules and conduct
survey on. The hotels are Radisson Water Garden, Pan Pacific Sonargaon, Lake Shore Hotel, Hotel
Washington, and Paradise Garden Hotel. We conducted Survey on the customers, employees,
suppliers and residents nearby the hotel and in the end we formulated our own policy after
analyzing these results.

4|Page

Overview of the Hotels

Radisson Water Garden Hotel

5 Stars

LOCATION
The Hotel is conveniently located on airport road leading to the main city, and adjacent to the
diplomatic enclave and upcoming blue chip commercial hub of Baridhara, Gulshan & Banani, only
5km from the main international airport. Comprising 204 rooms & suites including Radisson Club
Executive floors, all rooms feature king, queen or twin size beds, large work areas with HighSpeed Internet, direct control air-conditioning, in-room safe, mini bar, tea/coffee making facilities
and ironing facilities. The Radisson Water Garden Hotel Dhaka offers a variable feast for the
senses. Their 7 food & beverage outlets include a selection of the finest cuisine, a wide selection of
imported premium cigars & beverages and live entertainment. Revitalize and rejuvenate the mind,
body & soul in Dhaka's first internationally
ACCOMMODATION:
5|Page

The Radisson Water Garden Hotel Dhaka features 204 stylish rooms and suites with work desk,
complimentary high-speed Internet, direct control air-conditioning, in-room safe, mini bar and
ironing facilities. All of their comfortable Dhaka hotel rooms and suites are set up for you whether
you are traveling for business or leisure.
Deluxe Rooms
Deluxe Rooms are stylish, well appointed rooms with a queen bed or two twin beds, moveable
work desk, armchair and wardrobe with drawers. The average size is approximately 28 square
meters with double glazed windows and three point bathrooms.
Atrium Rooms
Atrium Rooms are contemporary in style and generous in size - approximately 36 square meters.
Rooms have either one king bed or two double beds, a moveable work desk, armchair and
wardrobe with drawers. All the rooms have double glazed windows with four point bathrooms.
Radisson Club Rooms are similar in style to the Atrium Rooms and include complimentary access
to the Radisson Club Lounge. Located on the 6th and 7th floors of the hotel, these rooms feature
additional complimentary amenities.
Executive Suites
Located on the 7th floor of the hotel, these two-room suites feature a large living area with separate
bedrooms. The suite includes complimentary access to the Radisson Club Lounge and includes all
of the complimentary amenities included with the Radisson Club Rooms.
FEATURES

Adjoining rooms available

Bathrobes
Complimentary internet facilities
Corporate rates available
English newspaper - complimentary
Full length mirror
Handicap rooms available
In-room safe
6|Page

Iron/ironing board
Laundry and dry cleaning facilities
Luggage rack
Mini-bar
Moveable work desk
Non-smoking floors and non-smoking rooms available
Radisson Club Floors with Club Lounge facilities
Remote controlled television with satellite channels
Room service (24 hour)
Self controlled air-conditioning
Suites available
Tea/coffee maker
Telephone with direct international dialing

HOTEL FACILITIES & SERVICES:

Delicious On-site Dhaka Hotel Dining Radisson Water Garden Hotel Dhaka offers a variable feast
for the senses. Our on-site Dhaka hotel dining includes seven food and beverage outlets, including
the Radisson Club Lounge. Our restaurants in Dhaka, Bangladesh serve the finest cuisines plus a
wide selection of imported premium cigars and beverages and provide live entertainment.

Room service (24 hours)

Group accommodations

Reservations

The Blaze Entertainment Lounge & Bar

Situated on the ground level with its own entrance, The Blaze Entertainment Lounge & Bar is a
swinging lounge where you can enjoy a game of billiard with friends or just enjoy the evening
listening to the live entertainment or socializing in this casual atmosphere. Hours: open Sat-Thu
6:30pm-12:30am (closed Fridays)
Chit Chat

7|Page

Adjacent to the pool deck and the Health and Fitness Center, Chit Chat is a place to enjoy with
friends. While relaxing around the hotel's pool, enjoy a refreshing ice tea, fresh lime frappa or
milkshake accompanied by light snacks such as home-baked quiche, chicken pie, salad or
sandwiches and a wide selection of pastries and cakes. Guests can dine in or take away. Hours:
11am-9pm daily
The Cigar Bar
The Cigar Bar is an intimate, private retreat to relax and unwind. Our members and hotel guests
enjoy the finest refreshments and a range of the world's premium cigars, beverages and small
snacks. Hours: Sat-Thu 6:30pm-12:30am (closed Fridays)
Spice & Rice
For an oriental mood, try Spice & Rice, a fun restaurant featuring Asian cuisine and a taste of the
Orient. Sample a range of regional influences and specialty cuisine. Spice & Rice is a
contemporary restaurant within a relaxed setting - sit at our action kitchen and let the chefs
entertain you for the evening with their culinary skills. Hours: 6:30pm-11pm daily
Sublime
A modern and yet elegant restaurant, Sublime is our hotel's premier restaurant featuring the very
best of Bangladesh produce with an emphasis on its finest - fresh, tasty, inventive and wholesome
cuisine. Sublime is the ideal choice for a superb evening out for any occasion. Hours: 6:30pm11pm daily
Water Garden Brasserie
Offering all day dining, the Water Garden Brasserie is a place for a hearty breakfast, quick snack,
lavishly displayed international buffet and cook-to-order food stations for lunch and dinner. Relax
and sit around the water feature room and watch the activity in the hotel's busy lobby lounge.
Hours: 6:30am-11pm daily
The Radisson Club Lounge

8|Page

The Radisson Club Lounge on level eight is for the exclusive use of Club guests. Hours: 6:30am10pm daily (breakfast 6:30-10:30am, cocktails and hors d'oeuvres 5pm-7pm)
Desirably located and exquisitely appointed, Radisson Water Garden Hotel Dhaka boasts a
comprehensive range of facilities and amenities that are sure to make your stay memorable. Guests
can enjoy the atmosphere of an exclusive Dhaka resort and the conveniences of a business hotel in
Dhaka, Bangladesh at the Radisson, which offers wireless Internet access in public areas, a
Business Centre with boardrooms and secretarial services, the largest conference, meeting and
function facilities in Dhaka and undercover and outdoor car parking facilities.
Terms and Conditions:

These rates are nett inclusive of all taxes and are not available at the hotel . This is only
applicable if prepayment is made thru greenchannelbd.com and these are subject to change
without prior notice, surcharges impose by hotels during special events.

Cancellation, No Show, Child Policy, Extra bed, Meal Rates, Check in & Check out time
and other benefits as well as Terms & Conditions of Bookings will be advise by our
Reservation Agents

Advertised Rates are only applicable to specific market category according to your country

9|Page

Pan Pacific Sonargaon

5 Stars

LOCATION

Pan Pacific Sonargaon Dhaka is a magnificent business-class hotel, ideally located in central
Dhaka close to the Motijheel commercial area, Dhaka's diplomatic area of Baridhara and Gulshan,
Parliament House and the Prime Minister's Office. The hotel is within easy access of several Dhaka
attractions, and Zia International Airport is just 18 kilometres from the hotel.
Here at the Pan Pacific Sonargaon Dhaka, both the business and leisure traveller to Dhaka will
enjoy all that a five-star international hotel can offer, from first-class surroundings to world-class
hospitality, in the Pan Pacific style.
The hotel's 304 luxuriously appointed rooms, including 25 magnificent suites, provide comfort and
superb facilities, combining to make your stay at Pan Pacific Sonargaon Dhaka truly memorable.
The hotel's Pacific Floors offer extensive facilities and privileges, including butler service and a
private lounge for discerning hotel guests.
The restaurants, lounge and bar of Pan Pacific Sonargaon provide a wide selection of food and
beverage facilities, from Italian to the finest international cuisine in Dhaka at the hotel's Cafe
Bazar. 24-hour Room Service is also available at the hotel.

10 | P a g e

Guests wishing to retain their health regime will find Pan Pacific Sonargaon Dhaka's Health Club
offers a fully equipped gymnasium, sauna, steam room and massage treatments. For recreation, Pan
Pacific Sonargaon Dhaka offers an impressive swimming pool, tennis and squash courts. All the
hotel's extensive health and leisure facilities are tailored to meet guests' individual needs, with
professional hotel staff on hand to assist.
The hotel's Grand Ballroom can accommodate up to 1200 guests and is the perfect setting for your
Dhaka conference or social event. The hotel also has a fully equipped Business Centre. Pan Pacific
Sonargaon's team of professional meeting planners is always at your service, providing the ideal
venue in Dhaka for corporate meetings, seminars, family functions, birthdays and wedding
ceremonies.
ACCOMMODATION:
The Pan Pacific Sonargaon Dhaka Hotel offers 304 luxuriously appointed rooms, including 25
magnificent suites. To cater for your business needs, we offer exclusive floors with butler service.
Guest room facilities include: Air conditioning, Satellite television, Music system, Full bathtub and
shower, Bathrobe,
A pair of slippers, Hairdryer, International direct dialling facility, Voicemail, Minibar, Electronic
safe, Complimentary daily newspaper, In-room Internet and e-mail service is available on request
from the Business Centre, Laundry service, Check-in: 3:00 pm and Check-out: 12:00 noon.
Guest Rooms

Courtyard Rooms - located at the Courtyard building and are single rooms only.

Deluxe Rooms - offer either one large bed or two beds.

The Pacific Floors

The top two floors at the Pan Pacific Sonargaon Dhaka are the exclusive Pacific Floors, offering
extensive facilities and privileges to make an enjoyable stay for our business-class guests.
The Pacific Floors provide Concierge services, butler service and a private Pacific Lounge, with
Pan Pacific flair and flavour for our discerning guests.
11 | P a g e

The following privileges are complimentary: VIP treatment, Escorted check-in at the Pacific
Lounge, located on the top floor, Exclusive butler service at the Pacific Lounge, Breakfast and
evening cocktails at the Pacific Lounge, Daytime tea, coffee, soft drinks and snacks at the Pacific
Lounge, Laundry, dry-cleaning and pressing, Extended check-out time till 6:00 pm (subject to
availability), Business magazines and daily local and international newspapers, Electronic safetydeposit box in room, Fruit basket upon arrival, Complimentary local telephone calls, Pacific Floor
Executive Room.

12 | P a g e

HOTEL FACILITIES & SERVICES:

For those seeking a healthier lifestyle in the most sumptuous of surroundings, The Health Club
offers a fully equipped gymnasium, sauna and steam room, along with massage treatments.
Recreation enthusiasts will enjoy the impressive swimming pool, tennis and squash courts.
Savvy, Pan Pacific Sonargaon Dhaka's chic beauty and barber salon, offers an extensive range of
hair and beauty treatments. The Shopping Arcade features an array of gifts and accessories.
The Pan Pacific Sonargaon offers extensive fitness facilities at The Health Club including: Fully
equipped gymnasium, Sauna, Massage, Hot / cold shower, Steam bath, All-season, outdoor, junior
Olympic swimming pool, Wading pool for children, Tennis court, Squash court and Swimming,
tennis and squash lessons for children and adults are conducted by our professional and skilled
instructors.
Savvy Beauty and Barber Salon- Beauty packages, bridal make-up, skincare, haircuts, facials,
manicures, pedicures and other beauty treatments are available on the 3rd floor of the Courtyard
building. Guests are provided with complimentary tea and coffee.
The following facilities are available within the hotel: Airline, travel agencies, Banks, Souvenir and
handicraft shops, Carpet shop, Jewellery shop, Bookstall, Art gallery, Photography shop, Business
offices, Concierge, Limousine rental, Medical centre, Laundry service, Shopping Arcade, Golf
course nearby, Short-term rental offices, Service One - pick up the phone in your room and press
the Service One button. You will have access to every hotel amenity available. You can be sure
that all requests will be handled promptly and efficiently and Credit card guarantee: MasterCard,
Amex, Visa, Diners and JCB.
Dining at the Pan Pacific Sonargaon Dhaka Hotel is a great delight. In its setting of mosaic pools
and cool fountains, the Jharna restaurant features superb oriental and seafood specials. An
exclusive Italian delicacy awaits your pleasure in our Ciao restaurant. Cafe Bazar offers the finest
international cuisine. The buffet breakfast, lunch and dinner include international and Bangladeshi
cuisine. And la carte menu is also available. The spacious Lobby Lounge offers snacks and drinks
13 | P a g e

all day long, giving you a choice of light conversation or a business meeting. The Pool Cafe
restaurant features a wide selection of snacks and drinks, which can be enjoyed beside the
swimming pool. The Balcony is an oasis for quiet relaxation with friends. Our popular in-house
pastry and confectionery shop, Aromaz, offers the best selection of quality bakeries. Or relax in the
privacy of your own room and dine with 24-hour Room Service.
The Pan Pacific Sonargaon Dhaka Hotel has a 1200-capacity Grand Ballroom and a fully equipped
Business Centre, providing an ideal venue for corporate meetings, seminars, family functions,
birthdays, wedding ceremonies, etc. A team of professional meeting planners is always at your
service, and a complete outdoor catering service is available for large or small functions in and
around the city.
Facilities for guests' use include simultaneous interpretation systems for up to six people,
secretarial services, facsimile, telex, e-mail, photocopiers, shredders, dictaphones and a fully
trained staff of professionals and technicians.

Terms and Conditions:

These rates are nett inclusive of all taxes and are not available at the hotel . This is only
applicable if prepayment is made thru greenchannelbd.com and these are subject to change
without prior notice, surcharges impose by hotels during special events.

Cancellation, No Show, Child Policy,Extra bed, Meal Rates, Check in & Check out time
and other benefits as well as Terms & Conditions of Bookings will be advise by our
Reservation Agents

Advertised Rates are only applicable to specific market category according to your country

14 | P a g e

Lake Shore Hotel

4 Stars

LOCATION

The Hotel is 12Km from Zia International Airport. The journey take approximately 15 minutes by
car. Complimentary Airport Pick & Drop and Limousine service is available on request. Located at
Gulshan Diplomatic Zone, Dhaka.

ACCOMMODATION:

You will find our rooms and apartments to be of International standard with impeccable service
and attention to details, to make your stay comfortable. 60 elegantly well equipped rooms , place of
relaxation and comfort forming the infrastructure of modernized living, with business desk in every
room, having internet connectivity and two phones with international direct dialing , mini bar ,
electronic safe and for safety smoke detectors , fire sprinklers and electronic door key.
The rooms availible are:

Deluxe Room

Executive Deluxe Room

Executive Suite Room

15 | P a g e

Studio Apartment

Presidential Suites

HOTEL FACILITIES & SERVICES:

Restaurant
The Hotel's Restaurant offers a wide selection of Local and International cuisines . Our Menu
offers a diversified variety of Continental, Thai, Japanese and Indian dishes with regular buffets
and a la Carte dishes. Enjoy a fabulous dining experience with personalized service with of course
great food.
Conference and Banquet Facilities
La-Vita Banquet Room: Can accommodate from 150 up to 200 guests dining and theatre style or
professional sales staff meetings and social gatherings. We will arrange your special events to meet
your individual needs.
Other Conference Rooms: There are adequate arrangements for all your business meetings and
board room conferences at our hotel. The Tropical and Victoria Boardrooms has all the required
facilities to make your meeting a successful one accommodating up to 20 people. The Fortuna
Conference hall can accommodate up to 120 people. They have the following facilities:

Multimedia

OHP

Screen

Flip- chart

Podium

IDD phone facilities

Fax facilities

HOTEL FACILITIES & SERVICES

Business Center:
16 | P a g e

Board meeting room with conference facilities

Common meeting room in each floor

Rental mobile phone

Laptop on rental

24 hours business centre

Secretarial service

DVD, CD machines

Rental office

Other Facilities:

All service apartments with modern kitchen facilities

Electronic safety locker in all rooms

Fire alarm with fire sprinkler & fire hydride

International calling facilities in-room

Mini bar

Hair dryer

Limousine service

Non smoking room and facilities are available

Centrally Air Conditioned

Bathrobes and room slippers

Satellite Television with 65 channels

Concierge service

Emergency Doctor on cal

Shoe shine service

Complementary Services:

Ving card system electronic door locker

Master control board in all rooms

Spacious car parking zone inside hotel premises

Continuous power supply by full backup generator

17 | P a g e

Air port shuttle service

Buffet breakfast

Complimentary newspaper

24 hours room service

24 hours security services

24 hours broadband internet service in-room

Airline and travel desk, Sightseeing tour

Laundry service

Terms and Conditions:

These rates are nett inclusive of all taxes and are not available at the hotel . This is only
applicable if prepayment is made thru greenchannelbd.com and these are subject to change
without prior notice, surcharges impose by hotels during special events.

Cancellation, No Show, Child Policy,Extra bed, Meal Rates, Check in & Check out time
and other benefits as well as Terms & Conditions of Bookings will be advise by our
Reservation Agents

Advertised Rates are only applicable to specific market category according to your country

18 | P a g e

Washington Hotel
3 Stars

LOCATION

Washington Hotel is a Three Star Hotel in the Heart of Gulshan - 1, Dhaka, Bangladesh. Luxurious
Business Class Hotel with Majestic Colorful Architecture Designed. Superbly Located in The
Heart of Dhaka's Prestigious Business area and Diplomatic Zone, just 7 Kilometers from The Zia
International Airport and 01 Kilometers from the Major Embassies and Foreign Offices.

ACCOMMODATION:

Washington Hotel with 75 Rooms including Ambassador Suites and President Suites, Banquet
Hall, Rosebud Restaurant Club and other facilities of the highest standards. We are ensuring a
world class food and environment and we have become most popular with Business Class
Travelers and Expatriates, whether you are on a Business, pleasure or a Short Trip just step in
Washington Hotel and feel the Touch of Comfort and Bangladeshi Hospitality.

19 | P a g e

Please note that all our Rooms at Washington Hotel have an identical outfit of individually hand
crafted to our specifications in select tropical hardwoods for comfort, quality and beauty. All our
furniture are hand polished with country style motives and decorations.

All our Rooms have an identical outfit in country style furniture:

On both sides of bed a night stand - with house phone and table lamp

A large wardrobe to keep your dresses safe, with mirror on the opposite side built in solid.

A combo table - optionally used as storage for your suitcase and luggage or ideal as
personal desk for your laptop with Internet access in your room.

A small triangle design table with a big comfortable sofa - for your coffee, tea or dinner in
your room.

Two side tables with 2 dimmer lamps.

The remote control color TV for your selection of cable TV channels. In the lower section
of the table - you find a fridge with your personal Mini Bar filled with various soft drinks,
mineral water, fruit juices and chocolates.

All our hotel rooms have a spacious bathroom with bathtub shower and abundance of hot
and cold water.

We are at your disposal with our laundry and ironing services as well.

24 hour room service available.

The only difference between the rooms of our 4 categories:

Premier Single

Deluxe Twin

Ambassador Suite

President Suite

is the size of the hotel rooms resulting in a small difference in our hotel room rates for the different
sizes of our lovely furnished rooms of equal luxury outfit. Our spacious, lovely furnished hotel
rooms make your stay a real pleasure.

20 | P a g e

HOTEL FACILITIES & SERVICES:

We use silent split-type air-conditioning in all our rooms to assure a pleasant silence in your rooms
for greatest living comfort. The thick curtains will keep the morning sun out, for those who like to
sleep a little longer... Have a drink from our Minibar while watching one of the cable-TV channels,
or rent a DVD player and watch your favorite movie in the privacy of your room.
To enjoy unique luxury, please take a look at our suites.
Restaurant:
Come to Suruchi and turn your evening into an event. Eat in style with friends and family. Great
food - Bangladeshi, Oriental or Continental.
Services & Facilities :

Buffet Breakfast

Airport Pick up

Daily Newspaper

Safe Deposit Box Local Tel & Fax 1st 5 min.

Internet free 1st 10 min.

Sauna

Terms and Conditions:

These rates are nett inclusive of all taxes and are not available at the hotel . This is only
applicable if prepayment is made thru greenchannelbd.com and these are subject to change
without prior notice, surcharges impose by hotels during special events.

21 | P a g e

Cancellation, No Show, Child Policy,Extra bed, Meal Rates, Check in & Check out time
and other benefits as well as Terms & Conditions of Bookings will be advise by our
Reservation Agents

Advertised Rates are only applicable to specific market category according to your country

22 | P a g e

Paradise Garden
3 Stars

LOCATION
Situated in Dhaka's prestigeous Baridhara diplomatic enclave. Closer to the Diplomatic missions of
America, China, U.K. Japan, Korea and Malaysia. 7 Kilomitres from the Zia International Airport.
ACCOMMODATION:
The hotel provides Deluxe Room, Super Deluxe Room and Paradise Garden Suite with the
following amenities:

The hotel provides Deluxe Room, Super Deluxe Room and Paradise Garden Suite with the
following amenities:

40 tastefully decorated AC rooms including 10 suites with imported bed, attached bathroom
with bathtub.

24 hours hot & cold water, Mini refrigerator with amenities, Bed room slipper & Haridryers

Physician on Call, Smoke Detector in each room

Laundry & dry cleaning service, 24 hour room service

23 | P a g e

Safe diposit box, IDD phone and Internet facilities

Daily English Newspaper & Magazine, VCP & CD Player on request

RESTAURANT

A beautifully decorated lobby and Restaurant having sitting capacity of 50 persons, this
elegant restaurant offers you a truly gracious lunch, dinner and different kind of dishes.

BUSINESS AND CONFERENCE FACILITIES

Conference room having capacity of 150 persons with required facilities. Open 24 hours, This
comprehensive business center offers you secretarial services, Fax, e-mail and internet, word
processing, photo copying, spiral binding & courier service.
HOTEL FACILITIES & SERVICES:

Safety And Security: The entire hotel is fitted with fire extinguisher and also exit staircase
in case of fire. Our trained security personnel vigilant 24 hours.

Air Transport: We offer a very comfortable shuttle service to pick up/drop the guest from/
to Zia International Airport.

Continental Breakfast

Local phone calls Welcome Expressions

Daily English newspapers Hairdryer Shoe shine

Airport pickup and drop

A well equipped fitness center

Terms and Conditions:

These rates are nett inclusive of all taxes and are not available at the hotel . This is only
applicable if prepayment is made thru greenchannelbd.com and these are subject to change
without prior notice, surcharges impose by hotels during special events.

Cancellation, No Show, Child Policy,Extra bed, Meal Rates, Check in & Check out time
and other benefits as well as Terms & Conditions of Bookings will be advise by our
Reservation Agents

Advertised Rates are only applicable to specific market category according to your country.
24 | P a g e

Methodology
In our survey, we considered a sample size of 31 people (n= 31). Among this we divided our
overall sample survey based on the four category which are
Customer
Employee
Resident
Supplier
In our survey we selected the sample survey randomly in each individual unit. Our questionnaire
was designed in a way where the respondents felt free to answer the question. This is one of the
reasons to shorten our survey questionnaire. In selecting our sample size we took 11 customers, 5
employees, 10 residents near the hotel and 5 suppliers to conduct the survey based on satisfaction
and ethical issue although the result may show different result if only we can take large amount of
respondent to survey the research.

Limitations

The sample size was small as the time frame was short for the term paper.

A larger sample could have had a different conclusion on some questions.

Many respondents were not truthful about their response. Especially the question asking the
respondents whether they were subject to any harassment by their owners. This is probably
because they feared the correct response would result in job loss. As a result there was a
bias in the result.

25 | P a g e

Findings and Analysis

Frequency table
Frequency shows the frequency of the respondent answer to particular question. Since our
respondents were divided in four main categories thus our graph are based on frequency not
percentage. We used SPSS software to factor out our analysis. We conducted the survey for
different hotel in different geographic location.
Demographic
In demographic factor we took into account of all of the respondent and their demographic factor.
We conducted the survey on 22 male respondents and 9 female respondents. In our data collection
gender distribution is 71% to 29%. As shown in the table below.

Table: gender
Frequency

Percent

Valid Percent

Cumulative
Percent

Valid

male

22

71.0

71.0

71.0

female

29.0

29.0

100.0

Total

31

100.0

100.0

26 | P a g e

Table: occupation
Frequency

Percent

Valid Percent

Cumulative
Percent

A customer of this hotel

11

35.5

35.5

35.5

An employee of this hotel

16.1

16.1

51.6

32.3

32.3

83.9

100.0

A
Valid

resident

neighborhood

of
where

this
the 10

hotel is located
A supplier to this hotel

16.1

16.1

Total

31

100.0

100.0

In our occupation section we divide our segment of respondent for survey and data collection.
Since getting internal data is hard we have only take 5 respondent of employees and 5 respondents
in suppliers to conduct the research. Although we have includes in our stakeholder status that our
27 | P a g e

stakeholder is consist of both customer and resident living near the hotel is respectively 11
respondent and 10 respondents. And then we divided our survey on following respondent category
and answer the data presented in simpler way.

Customer response
In customer section we take the survey based on 11 respondents we asked them four basic
questions to satisfy our findings.
First of all we asked our customers of their frequency in staying in the hotel. Among the
respondents more than half of the respondent stayed in the hotel for frequently. They stayed in
the hotel frequently. Among 11 respondent 6 of the respondent stayed frequently in the hotel
that we are concern about.

Table: Do you stay in this hotel frequently?

Frequency

Percent

Valid Percent

Cumulative Percent

28 | P a g e

Valid

Missing
Total

yes

19.4

54.5

54.5

no

16.1

45.5

100.0

Total

11

35.5

100.0

System

20

64.5

31

100.0

29 | P a g e

Then we asked the respondent about their satisfaction level in the staying in the hotel.
None of the respondents were totally satisfied or dissatisfied in staying in the hotel. The
reason could be that of price charge or service quality. But among the survey 7 out of 11
respondents were satisfied with the service quality of the hotel.

Table: Are you satisfied about the overall service quality of this hotel?
Frequency

Percent

Valid Percent

Cumulative
Percent

Valid

Missing
Total

Dissatisfied

12.9

36.4

36.4

Satisfied

22.6

63.6

100.0

Total

11

35.5

100.0

System

20

64.5

31

100.0

30 | P a g e

After the satisfactory level, we wanted to estimate the ethical behavior happening in case of
hotel authority and staff. When we asked whether the customers were victim of any wrong
doing in the hotel. 8 out of 11 respondent said they are not seeing the wrong doing in the hotel.
The reason of this is answer can high supervision of employee and quality of the hotel.
Table: Have you experienced any wrongdoing by the hotel authority or the staff?
Frequency

Percent

Valid Percent

Cumulative Percent

Yes

9.7

27.3

27.3

No

25.8

72.7

100.0

Valid

31 | P a g e

Missing
Total

Total

11

35.5

System

20

64.5

31

100.0

100.0

After that we asked our customer about the respond of the consumer in case of
occurrence of any. Since the quality of the hotel is good we have found that partially
10 out of 11 respondent replied that the respond is partially good. This indicates that
the hotel is highly promoting customer orienting service in the hotel.

How will you rate the service recovery of this hotel? (for instance; the response of
hotel authority to your complaints)
Frequency

Percent

Valid Percent

Cumulative
Percent

32 | P a g e

Poor

3.2

9.1

9.1

Good

22.6

63.6

72.7

very good

9.7

27.3

100.0

Total

11

35.5

100.0

System

20

64.5

31

100.0

Valid

Missing
Total

33 | P a g e

Employees response

We ask the employee of the hotel that weather the organization encourage ethical behavior
in the hotel. Partially 5 out of 5 respondent replied they are partially satisfied with the
encouragement. The result also shows the biasness in the process reason of such comment
is that on employee would expose bad behaving of their work place.

Do you agree that your organization encourage ethical behavior?

Frequency

Percent

Valid Percent

Cumulative
Percent

Valid

Missing
Total

Satisfied

9.7

60.0

60.0

Very Satisfied

6.5

40.0

100.0

Total

16.1

100.0

System

26

83.9

31

100.0

34 | P a g e

Then we asked the employee about the approach to tackle these problems if arises, in this
case all of the employee are partially satisfied with the approach taken by the hotel. The
high rated hotel will obviously take corresponding action in tackling this problem as it is
expected from the hotel.
How will you rate your organizations approach to tackle these problems?
Frequency

Percent

Valid Percent

Cumulative
Percent

Valid

Missing
Total

Satisfied

9.7

60.0

60.0

Very Satisfied

6.5

40.0

100.0

Total

16.1

100.0

System

26

83.9

31

100.0

35 | P a g e

Then we ask discrimination in hiring process in this case only one female says that
there is discrimination in hiring process but all the male respondent replied that there
is no discrimination in hiring process. The result indicates that there could be
discrimination in between gender.
Table: Have you experienced any discrimination in hiring?
Frequency

Percent

Valid Percent

Cumulative
Percent

Valid

Missing
Total

Yes

3.2

20.0

20.0

No

12.9

80.0

100.0

Total

16.1

100.0

System

26

83.9

31

100.0
36 | P a g e

When we talked about the discrimination we should concern about the harassment in
job. In our research we found that there is no harassment in doing job. Giving
meaning that hotels are well organized in avoiding harassment while at Job.
Table: Have you ever faced harassment while at job?
Frequency

Percent

Valid Percent

Cumulative
Percent

Valid

No

16.1

Missing

System

26

83.9

31

100.0

Total

100.0

100.0

37 | P a g e

When we talk about the tackling the problem all of the respondent agreed that it is well
manageable and also good in tackling the problem, in this case the result backed by the
satisfactory level of employee.
How will you rate your organizations approach to tackle these problems?
Frequency

Percent

Valid Percent

Cumulative
Percent

Valid

Missing

good

9.7

60.0

60.0

very good

6.5

40.0

100.0

Total

16.1

100.0

System

26

83.9
38 | P a g e

Total

31

100.0

Response from Society

Resident has different thought regarding the presence of hotel adversely impacting the
neighborhood. In this case 3 out of 10 people think that the totally disagree with the thought where
5 out of 10 peoples also disagree partially that its adversely affect the society. On the other hand
partially 2 people where 1 person agree and 1 person strongly agree that the hotel is adversely
impacting the neighborhood.

39 | P a g e

Do you agree the presence of this hotel is adversely impacting your neighborhood?
(for instance; increased solicitation, gambling, drug etc)
Frequenc

Percent

y
strongly

Valid

Cumulative Percent

Percent

9.7

30.0

30.0

disagree

16.1

50.0

80.0

agree

3.2

10.0

90.0

strongly agree

3.2

10.0

100.0

Total

10

32.3

100.0

Missing System

21

67.7

Total

31

100.0

disagree

Valid

40 | P a g e

Both agree and disagree occur when we ask that whether if there is any vicinity have
taken enough initiative to help the community to tackle its various problem. The
results indicate that hotels should take more care about the neighbor in this case.
Table: Do you agree the hotel in your vicinity have taken enough initiative to
help the community to tackle its various problems?
Frequency

Percent

Valid Percent

Cumulative
Percent

Valid

Missing

disagree

12.9

40.0

40.0

agree

19.4

60.0

100.0

Total

10

32.3

100.0

System

21

67.7
41 | P a g e

Total

31

100.0

Then we ask that if there any relation with traffic jam and hotel over 80% of the
respondent agreed that there is traffic jam arise for the hotel. In this case for little
case hotel are affecting economy and it increase traffic rate around the hotel for
frame and image.
Table: Does the presence of this hotel cause unwanted traffic jam in your
neighborhood?
Frequency

Percent

Valid Percent

Cumulative
Percent

yes

25.8

80.0

80.0

no

6.5

20.0

100.0

Valid

42 | P a g e

Missing

Total

10

32.3

System

21

67.7

31

100.0

Total

100.0

Resident are not satisfied about the traffic jam arises due to existent of the hotel but some
of the resident are happy cause it is economically helping the society and neighbor.
Therefore both satisfied and dissatisfied resident exist in the research data.
Are you satisfied with the steps they have taken to tackle the problem?
Frequency

Percent

Valid Percent

Cumulative
Percent

Valid

dissatisfied

19.4

60.0

60.0

43 | P a g e

Missing
Total

Satisfied

12.9

40.0

Total

10

32.3

100.0

System

21

67.7

31

100.0

100.0

44 | P a g e

Suppliers response
In next content we surveyed 5 respondents to find out the relationship of its
collaborator and the hotel. The hotel is somewhat providing the ethical behavior in
the organization but not totally providing the ethical action as 3 out of 5 respondent
dont agree that the hotel is enforcing ethical behavior in the organization.
Table: Does your business partner encourage you to enforce ethical behavior in
your organization?
Frequency

Percent

Valid Percent

Cumulative
Percent

Valid

Missing
Total

yes

6.5

40.0

40.0

no

9.7

60.0

100.0

Total

16.1

100.0

System

26

83.9

31

100.0

45 | P a g e

Then we ask to rate the engagement of activity regarding ethical behavior in the
hotel. 3 out or 5 respondents are happy with the engagement but 2 of the respondent
are not totally or partially happy with the engagement.
How will you rate their engagement activity to enforce ethical behavior in your
organization?
Frequency

Percent

Valid Percent

Cumulative
Percent

Valid

Missing
Total

Poor

6.5

40.0

40.0

Good

9.7

60.0

100.0

Total

16.1

100.0

System

26

83.9

31

100.0

46 | P a g e

Then we ask our supplies of the hotel respondent to respond on ethical action to be
taken by hotel is favorable or unfavorable. Despite of the previous result more than
half of respondent think that hotel are more aggressive in approaching to aid in
ethical behavior. The result is indicating that banks are more customers oriented.
How will you rate the hotels approach to aid you in any ethical problem you
may be facing?
Frequency

Percent

Valid Percent

Cumulative
Percent

Valid

Missing
Total

Poor

6.5

40.0

40.0

Good

9.7

60.0

100.0

Total

16.1

100.0

System

26

83.9

31

100.0

47 | P a g e

Summary of findings

Most customers are satisfied with the level of service. However, due to the fact that very
few samples were chosen and customers of only 2 out of 5 hotels were surveyed, the result
may be biased.

Employees were most likely dishonest with their answers that no discrimination existed, or
that they never faced harassment. This is probably because they were concerned about their
jobs. That is why we have seen positive results in their response in regard to ethical
behavior of the hotel authority.

The people of the society were vocal about their sufferings and rightly pointed out the fact
that the hotel authority at times did not do enough to tackle the problems they caused. These
include traffic jam, increased solicitation, gambling, drug abuse in parties etc.

There were not much enforcement of ethical behavior on its suppliers and the suppliers
were dishonest with their answers as well, as they tried to portray a better image of their
organization.

48 | P a g e

FORMULATION OF CODE OF
BUSINESS CONDUCT AND ETHICS
FOR HOTELS

49 | P a g e

50 | P a g e

1. INTRODUCTION
The collection of policies and guidelines established in this Code of Business Conduct
and Ethics applies to all officers, directors and employees of Hotel Hotels & Resorts, L.P., Hotel
Hotels & Resorts, Inc. and its consolidated subsidiaries (Hotel or the Company). In addition
to this Code, directors of Hotel Hotels & Resorts, Inc. are subject to the Code of
Business Conduct and Ethics and Conflict of Interest Policy for Members of the Board of
Directors. We believe long-term, trusting business relationships are built by being honest, open
and fair. We promise to uphold the highest professional standards in all business operations.
We also expect that those with whom we do business will adhere to our Code of Business
Conduct and Ethics standards.

The fundamental principle underlying the way we do business is good judgment. An

understanding of our legal and ethical parameters enhances that judgment.

We have a

responsibility to pay constant attention to all legal boundaries and to comply with all applicable
laws and regulations of the jurisdictions where we conduct business at all times. We have the
same obligation to the communities where we do business, to the clients and business partners
with whom we do business, and to the stockholders who have invested in us. For everyone at
Hotel, this means following the spirit of the law and doing the right, ethical thing even when the
law is not specific.

This Code outlines the broad principles of legal and ethical business conduct embraced
by Hotel. It is not an exhaustive list of legal or ethical questions an officer, director or employee
might face in the course of business, and therefore, this Code must be applied using common
sense and good judgment.

Officers, directors and employees should refer to the Companys

Insider Trading Policy Statement and Foreign Anticorruption Policy and Manual. Officers and
employees should also refer to the Charitable Contribution Policy and other Company policies
and procedures regarding equal employment opportunity, sexual harassment, loss prevention,
51 | P a g e

and similar topics, which are posted by Human Resources on the Companys intranet and which
supplement this Code. All officers and employees must conduct themselves according to these
policies and avoid even the appearance of improper behavior.

Although we realize no two situations are alike, we aim for consistency and balance
when encountering ethical issues.

It is essential that we all keep an eye out for possible

violations of our business ethics - whether these violations occur in dealings with the government
or the private sector, whether they occur because of oversight or intention, and whether the
persons involved are top management or rank-and-file employees.

Outstanding officers, directors and employees are key to our success. Everyone is part of
the Hotel team, and each of us deserves to be treated with dignity and respect. In addition, every
officer, director and employee is responsible for his or her own conduct. No one has the
authority to make another officer or employee violate this Code, and any attempt to direct or
otherwise influence someone else to commit a violation is unacceptable.

Officers and managers, in particular, set an example for other employees.

Hotel

requires all employees, including officers and managers, to know and understand this Code, as it
applies personally to the officer or manager and to those under his or her supervision.

Those who violate the policies in this Code will be subject to disciplinary action, up
to and including discharge from Hotel and, when appropriate, civil liability and criminal
prosecution. If you are in a situation you believe may violate or lead to a violation of this
Code, follow the policies described in Sections 15 and 16 of this Code.

If you have any questions regarding business conduct or possible violations, please
contact the Law Department. Hotel will not tolerate retaliation for reports made in good faith.

52 | P a g e

2. ETHICAL BUSINESS CONDUCT

It is essential that we watch for possible violations of Hotels business ethics whether
these violations occur in dealings with the government or the private sector or whether they
occur because of oversight or intention.

Officers and employees who have knowledge of

possible violations should notify Human Resources, the Law Department or call or email the
ethics hotline at www.hotelname.com. Any questions or concerns regarding accounting, internal
controls, or auditing matters will be forwarded to the Audit Committee.

To assist officers and employees in the day-to-day protection of our business ethics, we
have compiled a list of some areas where breaches commonly may occur:

Improper or excessive payments of any of the following:

o Consulting fees or payments to directors or officers;
o Expense reports; or
o Loans

Questionable payments to agents, consultants or professionals whose backgrounds

have not been adequately investigated, who do not have signed contracts or letters of
engagement, or whose association with the Company would be embarrassing if
exposed;

Payments violating the BANGLADESH Foreign Corrupt Practices Act or

other applicable anticorruption laws or conventions;
Payroll-related expenditures, bonuses, awards and non-cash gifts given to or by
employees without proper approvals or adequate documentation;

53 | P a g e

Payments made in cash or checks drawn to cash or bearer or bank accounts not in
Hotels name;

Transfers to or deposits in the bank account of an individual, rather than in the

account of a company with which we are doing business;

Billings made higher or lower than normal prices for fees, at a third partys request;

Payments made for any purpose other than that described in supporting
documentation;

Payments made to employees of vendors, contractors, consultants, operators or

agencies through intermediary persons or organizations, or that seem to deviate from
normal business transactions;

Any large, unusual, unexplained or individually approved contracts, or expenditures

made without review of supporting documentation;

Unusual transactions occurring with nonfunctional, inactive or shell subsidiaries or

undisclosed or unrecorded assets or liabilities;

Use of unethical or questionable means to obtain information, including information

about competitors;

An employment, consulting or business relationship between a Hotel employee

and another company, that creates a conflict of interest; and

Frequent trading (buying and selling over short intervals) in Hotel stock or the stock
of a company with which we do business.

These are some examples of possible violations. Officers and employees should feel free
to discuss any concerns about this policy or any issues that may arise with the Law Department.

54 | P a g e

3. COMPLIANCE WITH LAWS, RULES AND REGULATIONS;

HUMAN RIGHTS
Obeying the law, both in letter and in spirit, is one of the foundations on which our
ethical policies are built. All officers and employees must respect and obey the laws of the
cities, states and countries in which we operate, including without limitation, laws relating to
alcoholic beverages, antitrust, unfair competition, political contributions, civil rights, copyright
protection, environmental protection, employment discrimination, health and workplace safety,
foreign corrupt practices, securities and taxes. No officer or employee should at any time take
any action on behalf of the Company that he or she knows or reasonably should know would
violate any law or regulation. Although not all officers or employees are expected to know the
details of these laws, it is important to know enough to determine when to seek advice from
supervisors, managers or other appropriate personnel.

As a global company, we support and respect the protection of human rights within our
sphere of influence and we endeavor to conduct our business operations accordingly.

We

condemn all forms of human trafficking and exploitation of children and support all laws issued
to prevent and punish such crimes. We will comply with all applicable laws and regulations
regarding the prevention of child exploitation.

55 | P a g e

4. CONFLICTS OF INTEREST
We respect the rights of officers and employees to manage their personal affairs and
investments and do not wish to intrude upon their personal lives. At the same time, offices and
employees must act in the best interests of the Company and avoid situations that present a
potential or actual conflict between their interests and the interests of the Company.

A conflict of interest exists when an officers or an employees private interest

interferes (or even appears to interfere) in any way with Hotels interests. A conflict can arise
when an officer or an employee takes actions or has interests that may make it difficult to
perform his or her Company work objectively and effectively. Conflicts of interest also arise
when an officer or an employee or a member of his or her immediate family receives improper
personal benefits as a result of the officers or the employees position in or with the Company.

Conflicts of interest are generally prohibited as a matter of policy. Exceptions may only
be made after review and approval of specific or general categories of conflict by the Board of
Directors, a duly authorized committee of the Board of Directors or an officer of the Company.
Conflicts of interest may not always be clear cut, so if you have a question, you should consult
the Law Department. Any officer or employee who becomes aware of a conflict or potential
conflict should bring it to the attention of the Law Department or refer to Sections 15 and 16 of
this Code.

The following policies address some situations in which conflicts of interest may arise:

56 | P a g e

Relationships with a Competing Business and Certain Other Entities:

Engaging in a competing business while employed by Hotel is a conflict of interest.

In addition, certain relationships with a competing business or an entity that has a material
financial or adverse relationship with the Company are also conflicts of interest.

For that

reason, no employee may, without prior approval:

Engage in any competing business with Hotel; or

Engage in the following activities with a competing business, an entity that has a
material financial relationship with the Company or an entity whose interests are
adverse to or conflict with, in a material respect, the Companys interests:
o serve as a director, officer or key personnel;
o own more than 10% of the stock or other equity interest; or
o provide consulting, legal, advisory or other services.

The determination of whether a material financial relationship exists or whether an

interest is adverse to (or in conflict with) our interests will be made on a case-by-case
basis by the General Counsel.

Outside or Additional Part-Time Work:

While the best policy is to avoid any direct or indirect business connection with
our contractors, vendors, consultants, operators, managers or competitors, except on our
behalf, officers and employees may wish to take on additional part-time work with
organizations that are not our competitors, customers or suppliers. While such work in
itself does not constitute a conflict of interest, the second job must be strictly separated
from your job at Hotel and is subject to the following restrictions:

Outside work must not be done on Company time and must not involve the use of
57 | P a g e

Company equipment or supplies;

You should not attempt to sell products or services from the outside work to
Hotel or its employees; and

Performance of the outside work must not interfere with or prevent you from
devoting the time and effort needed to fulfill your duties and obligations as an
employee of the Company.

Favors, Gifts, Meals and Entertainment:

You and members of your family may not offer, solicit, give or accept gifts, other
than as noted below, to or from any person associated with the Companys business,
including current or prospective vendors, contractors, consultants, operators, managers or
business partners.

This includes gifts of products, services, equipment, discounts,

favored personal treatment, personal entertainment or extravagant meals.

This is not intended to preclude the Company from receiving or evaluating

appropriate complimentary products or services. Nor is it intended to preclude Hotel
from making a gift to a company or organization, provided that the gift is openly given,
with full knowledge by the company or organization, and is consistent with applicable
law. In rare circumstances, local customs in some countries may call for the exchange of
gifts having more than nominal value as part of the business relationship.

In these

situations, gifts may be accepted only on behalf of Hotel (not an individual) with the
approval of the Law Department. Any such gifts received should be turned over to
Human Resources for appropriate disposition or donated to a nonprofit, charitable
organization.

In all cases, the exchange of gifts must be conducted so there is no

appearance of impropriety. Gifts may only be given in accordance with applicable laws,
including the BANGLADESH Foreign Corrupt Practices Act.

58 | P a g e

Gifts, including advertising or promotional materials, novelties, favors and nonbusiness related meals and entertainment, are allowed when the following conditions are
met:

they are consistent with our business practices;

they do not violate any applicable law, including state and federal
procurement laws and regulations, the Employee Retirement Income Security
Act or any other federal or state law or regulation;

they are of limited value ($150.00 or less); and

public disclosure would not embarrass Hotel.

Under no circumstances may an officer or an employee accept a gift of cash or cash

equivalents in any amount.

Any gift not meeting these conditions may be accepted only with the prior
approval of Human Resources or the Law Department.

Travel and Expense Reports:

Requests for reimbursement of business-related expenses, including travel and

meal costs, must be fully documented in compliance with the Companys Business
Expense Reimbursement Policy.

Only business-related expenses will be reimbursed;

charges for personal entertainment or extravagant meals are not business expenses.
When in doubt regarding the appropriateness of a business-related expense, officers,
directors and employees should consult the Law Department.

Direct Reporting to Spouse, Partner or Immediate Family:

The potential for conflict of interest clearly exists if your immediate family
59 | P a g e

member (i.e., spouse, sibling, child, or parent) or someone with whom you have a
romantic relationship also works at Hotel and is in a direct reporting relationship to you.
Employees should not directly supervise, report to, or be in a position to influence the
hiring, work assignments or evaluations of an immediate family member or someone
with whom they have a romantic relationship. If you have any questions, please consult
the Executive Vice President of Human Resources.

Political, Civic and Charitable Activities:

We respect and support your right to participate in political activity, but

involvement and participation in political activities must be on an individual basis, on
your own time, and at your own expense. These activities may not be conducted on
Company time or involve the use of Company resources, such as telephones, computers
or supplies.

Further, should you speak on public issues, it must be made clear that

comments or statements made are your own and not those of the Company.

Your

participation in political activities in a country where you are not a citizen may jeopardize
your continued right to live and work in such country. Accordingly, such participation is
prohibited. Any questions concerning participation in political events should be directed
to the General Counsel.

We have a strong sense of responsibility to the communities in which we do

business and, as a Company, we often participate in charitable activities.
welcome and encouraged to join in these activities.

You are

However, you should not use

Company resources to approach other employees or our vendors, operators, managers or

business partners to solicit a charitable contribution. In addition, you may never use your
position in the Company to pressure employees into charitable giving. If you have a
charitable cause you believe we should support, please discuss it with Human Resources.
All charitable contributions must comply with the Companys Charitable Contribution
Policy.

60 | P a g e

5. INSIDER TRADING
The federal securities laws strictly forbid officers, directors and employees from buying
or selling Company securities while in possession of material nonpublic information about Hotel.
Likewise, officers, directors and employees may not tip a family member, friend or other
person by providing that person with material non-public information about Hotel. Any of these
actions may amount to insider trading and are strictly prohibited.

Officers, directors and

employees should refer to the Insider Trading Policy Statement, which contains more detailed
policies and rules relating to transactions in Hotels securities. If you have any questions, please
consult the Law Department.

6. CORPORATE OPPORTUNITIES
As an officer or employee of the Company, you have an obligation to advance the
Companys interests when the opportunity to do so arises. If you discover or are presented with
a business opportunity related to the Companys business activities through the use of corporate
property, information or because of your position with the Company, you should first present the
business opportunity to the Company before pursuing the opportunity in your individual
capacity. No officer or employee may use corporate property, information or his or her position
with the Company for personal gain, nor may any officer or employee compete with the
Company.

61 | P a g e

7. COMPETITION AND FAIR DEALING

We seek to outperform our competitors fairly and honestly.

We seek competitive

advantages through superior performance, never through unethical or illegal business practices.
Stealing proprietary information, possessing trade secret information that was obtained without
the owners consent, or inducing such disclosures by past or present employees of other
companies is prohibited. Our officers and employees should endeavor to respect the rights of and
deal fairly with our contractors, operators, managers, business partners and competitors. No
officer or employee should take unfair advantage of anyone through manipulation, concealment,
abuse of privileged information, misrepresentation of material facts or any other intentional
unfair-dealing practice.

62 | P a g e

8. PROTECTION AND PROPER USE OF COMPANY ASSETS

All officers and employees should protect Company assets and ensure their efficient use.
Theft, carelessness and waste have a direct impact on our profitability. All Company assets
should be used for legitimate Company business only. Any suspected incident of fraud or theft
should be immediately reported for investigation. Company equipment should not be used for
non-company business, though reasonable incidental personal use is permitted.

The obligation to protect Company assets extends to Hotels proprietary information.

Proprietary information includes intellectual property such as trade secrets, patents, trademarks
and copyrights, as well as business, marketing and service plans, engineering and manufacturing
ideas, designs, databases, records, salary information and any unpublished financial data and
reports. Unauthorized use or distribution of this information would violate our policy. It could
also be illegal and result in civil or even criminal penalties. Officers and employees who have
access to proprietary and confidential information are obligated to safeguard it from
unauthorized access in accordance with Hotels policy on confidential information (see Section 9
of this Code).

63 | P a g e

9. CONFIDENTIALITY
Officers and employees must maintain the confidentiality of information entrusted to
them by the Company, its operators, managers, contractors and business partners except when
disclosure is either expressly authorized by Hotel or required by law. Confidential information
means all non-public information, entrusted to or obtained by an officer or employee by reason
of his or her position as an officer or employee of Hotel, including, without limitation,
information that might be of use to competitors, or harmful to the Company or its partners if
disclosed, financial information, marketing and sales programs, development efforts, trademarks,
trade secrets, information about relationships with our customers, contracts and agreements,
forecasts and analyses, strategic and business plans, offers and proposals for acquisitions,
dispositions and other transactions, analyses and information concerning our assets, material
company information, and any other documents and analyses related thereto.

Officers and

employees are required to keep confidential all confidential information and may not disclose,
reveal or discuss this information with persons outside of Hotel or use this information for their
own direct or indirect benefit or for the direct or indirect benefit of any family member, friend,
relative or other recipient of the information. It is important to use discretion when discussing
company business in public places such as elevators, restaurants and airplanes, or when using
public or cellular phones, the internet and fax machines. Should any officer or employee have a
question as to whether certain information is considered confidential information, that person
should consult with the General Counsel.
Upon leaving Hotel, officers and employees must return all copies of confidential
information in their possession.

The obligation to keep Company information confidential

continues following the termination of ones employment or other relationship with Hotel. We
will take appropriate steps to protect our confidential information.

64 | P a g e

10. SPECIAL ETHICS OBLIGATIONS OF EMPLOYEES WITH

FINANCIAL REPORTING OBLIGATIONS
We require honest and accurate recording and reporting of information in order to make
responsible business decisions. All of our books, records, accounts and financial statements
must be maintained in reasonable detail, must appropriately reflect the Companys transactions
and must conform both to applicable legal and accounting requirements and to our system of
internal controls. Unrecorded or off the books funds or assets may not be maintained under
any circumstances.

The accurate and timely reporting of our financial results and financial condition requires
that all financial information be recorded promptly and accurately, and that our systems for
recording and reporting that information be properly functioning and subject to regular and
thorough evaluations. While not all of us may be familiar with accounting procedures, we need
to make sure every business record is accurate, complete and reliable.

All officers and employees are responsible for reporting any concerns regarding
questionable accounting or auditing matters. This policy also applies to all operating reports or
records prepared for internal or external purposes, such as environmental data, product test
results, quality control reports or sales projections. False, misleading or incomplete information
impairs the Companys ability to make good decisions, undermines trust in the long term, and
may in some cases be illegal.

Business records and communications often become public, and officers and employees
should avoid exaggeration, derogatory remarks, guesswork or inappropriate characterizations of
people and companies that can be misunderstood. This applies equally to e-mail, internal memos
and formal reports. Records should always be retained or destroyed according to the Companys
Records Management and Retention Policy.

In accordance with that policy, in the event of

litigation or governmental investigation, please consult the General Counsel.

65 | P a g e

The Treasury and Accounting Departments bear a special responsibility for promoting
integrity throughout the organization, with responsibilities to stakeholders both inside and
outside of Hotel. The Chief Executive Officer, Chief Financial Officer, and members of the
Treasury and Accounting Departments have a special role both to adhere to these principles
themselves and also to ensure that a culture exists throughout the Company that ensures the fair
and timely reporting of our financial results and condition.

Because of this special role, the Chief Executive Officer, Chief Financial Officer,
Treasurer, Corporate Controller and all other members of the Treasury and Accounting
Departments are bound by the following Financial Officer Code of Ethics, and by accepting the
Code of Business Conduct and Ethics, each agrees he or she will:

Act with honesty and integrity, avoiding actual or apparent conflicts of interest
involving personal and professional relationships;

Provide officers, employees or agents of Hotel, and include in reports

and documents filed with the Securities and Exchange Commission, information
that is full, fair, accurate, complete, objective, timely and understandable;

Comply with rules and regulations of all governmental entities, as well as other
private and public regulatory agencies to which Hotel is subject;

Act at all times in good faith, responsibly, with due care, competence and
diligence, and without any misrepresentation of material facts;
Act objectively, without allowing his or her independent judgment to be
subordinated;
Respect the confidentiality of Company information, except when authorized or
otherwise required to make any disclosure, and avoid the use of any Company
information for personal advantage;
Share

his

or

her

knowledge

and

skills

with

others

to

improve

Hotels communications to its constituents;

Promote ethical behavior among employees under his or her supervision at Hotel;
and
66 | P a g e

Achieve responsible use of and control over all assets and resources of
Hotel entrusted to him or her.

Violations of this Financial Officer Code of Ethics, including failures to report potential
violations by others, will be viewed as a severe disciplinary matter that may result in personnel
action, including termination of employment, and, where appropriate, civil liability and criminal
prosecution. If you believe that a violation of the Financial Officer Code of Ethics has occurred,
please contact the General Counsel. You may also contact the Audit Committee of the Board of
Directors through the hotline at 1-866-384-4277. You may also report a violation by logging on
to www.ethicspoint.com.

It is against our policy to retaliate against any officer or employee for good faith
reporting of violations of this Financial Officer Code of Ethics or for participating in any
investigation relating to a reported violation.

67 | P a g e

11. PUBLIC DISCLOSURES

Hotel Hotels & Resorts, although not a listed company in the Dhaka Stock Exchange, does
affect the public significantly.. As a result, Hotel is obligated to make various disclosures to the
public, and we are committed to full compliance with all requirements applicable to our public
disclosures. Hotel has implemented disclosure controls and procedures to assure that its public
disclosures are timely, compliant and otherwise full, fair, accurate and understandable.

All

officers and employees responsible for the preparation of Hotels public disclosures, or who
provide information as part of that process, have a responsibility to assure that such disclosures
and information are complete, accurate and in compliance with Hotels disclosure controls and
procedures.

12. HARASSMENT AND OTHER UNACCEPTABLE CONDUCT

Hotel is committed to maintaining a workplace free from harassment, intimidation and
Hotelility. Harassment on the basis of age, color, race, religion, gender, marital status, ancestry,
sexual orientation, national origin, disability, veteran status or any other characteristic protected
by law is prohibited.

Hotel will not tolerate undue influence, offensive behavior, sexual

harassment, intimidation, or other disrespectful conduct by one officer, director or employee

toward another. No one may harass an employee, customer, vendor, supplier, visitor or any
other person on the Companys premises or while doing business regardless of location. You
should refer to the Harassment Policy, which contains more detailed policies relating to
harassment and examples of unlawful harassment.

68 | P a g e

13. POLITICAL CONTRIBUTIONS

We recognize an officers and an employees right to provide personal financial support
to political organizations or candidates.

Officers and employees, however, shall not make

political contributions to any organization, party or candidate using, directly or indirectly, any
Company funds or assets. This includes, but is not limited to, gifts of money or property to
political parties or candidates, sponsorship of events for political parties or candidates,
subscriptions or other fees paid for affiliation or membership in any political party or party
organization, money spent in reimbursement of expenses incurred directly or indirectly by
political parties or candidates, provision of any property, services, or facilities for the use or
benefit of political parties or candidates (other than on commercial terms), or the purchase of
tickets for fundraising events for political parties or candidates. The Company may from time to
time express its views on local, national and international issues that affect its operations. In
such cases, Company funds and resources may be used, but only when permitted by law and by
our strict Company policies. Hotel may also make limited contributions to political parties or
candidates in jurisdictions when it is legal and customary to do so. No officer or employee may
make or commit to make political contributions on behalf of Hotel without approval from the
General Counsel. All questions concerning donations to political parties or candidates should be
directed to the General Counsel.

69 | P a g e

14. WAIVERS OF THE CODE OF BUSINESS CONDUCT AND

ETHICS
Any waiver of this Code for executive officers may be made only by independent
directors of the Board of Directors or a Board committee comprised solely of independent
directors and will be promptly disclosed as required by law or regulation of the New York Stock
Exchange.

15. ADVICE ON ETHICS QUESTIONS

Officers and employees who have questions about this Code should first consult their
immediate supervisors. Our open door policy gives you the freedom to approach any member
of management with ethical questions or concerns in good faith without fear of retaliation. If
you are not comfortable discussing the matter with your supervisor, you should consult the
Executive Vice President of the Human Resources Department or the General Counsel.

70 | P a g e

16. REPORTING ILLEGAL OR UNETHICAL BEHAVIOR

If you believe that actions have taken place, may be taking place or may be about to take
place that violate or would violate this Code or any laws, rules or regulations, you must bring the
matter to our attention.

You are encouraged to talk to your supervisor, manager or other

appropriate personnel when in doubt about the best course of action in a particular situation.
Any supervisor or manager who receives a report of a potential violation of this Code or any
laws, rules or regulations must report it immediately to the General Counsel or the Executive
Vice President of Human Resources.

Officers and employees are required to communicate any violations of this Code or any
laws, rules or regulations to the Human Resources Department or the General Counsel, by any of
the following methods:

In writing either by internal mail or standard mail;

By e-mail; or

By telephone.

Hotel maintains a confidential hot line which can be accessed by telephone and e-mail.
Officers and employees who use the hot line are guaranteed confidential treatment. All officer or
employee communications made in good faith will be treated promptly and professionally and
without risk of retribution. You may also report a violation by logging on to
www.ethicspoint.com. Any use of these reporting procedures in bad faith or in a false or
frivolous manner will be considered a violation of this Code. In addition, you should not use
the ethics hotline for personal grievances not involving this Code.

We would prefer you identify yourself to facilitate our investigation of any report.
However, you may choose to remain anonymous. We will use reasonable efforts to protect the
identity of any person who reports potential misconduct in good faith and any retaliation for
71 | P a g e

reports of misconduct by others made in good faith will not be tolerated. Indeed, any officers or
employees who engage in retaliation are subject to discipline, up to and including termination,
and in appropriate cases, civil and/or criminal liability. We will also use reasonable efforts to
protect the identity of the person about or against whom an allegation is brought, unless and until
it is determined that a violation has occurred.

Any person directly or indirectly involved in any investigation of possible misconduct

must not discuss or disclose any information to anyone outside of the investigation unless
required by law or when seeking his or her own legal advice, and is expected to cooperate fully
any investigation. It is against our policy to retaliate against any employee for participating in
any investigation of possible misconduct.

17. COMPLIANCE PROCEDURES

We must all work to ensure prompt and consistent action against violations of this Code.
However, in some situations it is difficult to know right from wrong. Since we cannot anticipate
every situation that will arise, it is important that we have a way to approach a new question or
problem. These are the steps to take when faced with a potential violation of this Code:

Have all the facts. In order to reach the right solutions, we must be as fully

informed as possible.

Ask does the conduct being requested or demanded seem unethical or improper?

Focus on the specific situation and alternatives being presented.

Use judgment and

common sense; if something seems unethical or improper, it probably is.

Clarify responsibilities and roles.

In most situations, there is shared

72 | P a g e

responsibility. Which colleagues are aware of the situation? It may help to get others
involved and discuss the problem.

Discuss the problem with a supervisor. In many cases, your supervisor will be

more knowledgeable about the question, and will appreciate being brought into the
decision-making process.

Remember it is a supervisors responsibility to help solve

problems.

Seek help from Company resources. In situations where it may not be appropriate

to discuss an issue with a supervisor, discuss it with Human Resources or the Law
Department.

Report ethical violations in confidence and without fear of retaliation. If your

situation requires that your identity be kept secret, your anonymity will be protected. We
do not permit retaliation of any kind against employees for good faith reports of ethical
violations.

Always ask first, act later. If you are unsure of what to do in any situation, you

should seek guidance before acting.

73 | P a g e

18. ADMINISTRATION
Board of Directors.

The Board of Directors, through the Nominating and Corporate

Governance Committee, will help ensure this Code is properly administered. The Nominating
and Corporate Governance Committee will be responsible for the annual review of the
compliance procedures in place to implement this Code and will recommend clarifications or
necessary changes to this Code to the Board of Directors for approval. Any changes to the Code
will be immediately disclosed and disseminated to employees via electronic means.
Officers and Managers. All officers and managers are responsible for reviewing this
Code with their employees and ensuring their employees have signed the attached certification.
Officers and managers are also responsible for the diligent review of practices and procedures in
place to help ensure compliance with this Code.

74 | P a g e

References:
Freeman, R. Edward (1984). Strategic Management: A stakeholder approach. Boston: Pitman.
Miles, Samantha (2012). "Stakeholders: essentially contested or just confused?". Journal of
Business Ethics 108 (3): 285298.
Miles, Samantha (2011). "Stakeholder Definitions: Profusion and Confusion". EIASM 1st
interdisciplinary conference on stakeholder, resources and value creation, IESE Business
School, University of Navarra, Barcelona.
http://www.radissonblu.com/hotel-dhaka\
http://www.washingtonbd.com/
http://www.panpacific.com/en/Dhaka/Overview.html
http://www.lakeshorehotel.com.bd/
http://www.paradisegardenhotel.net/

75 | P a g e

Appendix
This questionnaire is being used for educational purpose only.
Gender:
Male

Female

You are:
A customer of this hotel
An employee of this hotel
A resident of this neighborhood where the hotel is located
A supplier to this hotel

This segment is for the customers of this hotel only.

1. Do you stay in this hotel frequently?
Yes

No

2. Are you satisfied about the overall service quality of this hotel?
Not satisfied

dissatisfied

Satisfied

Very Satisfied

3. Have you experienced any wrongdoing by the hotel authority or the staff?
76 | P a g e

Yes

No

4. How will you rate the service recovery of this hotel? (for instance; the response of hotel
authority to your complaints)
Very Poor

Poor

Good

Very Good

This segment is for the employees of this hotel only.

1. Do you agree that your organization encourage ethical behavior?

Strongly Disagree

Disagree

Agree

Strongly Agree

2. How satisfied are you with the way the organization treats you?
Not satisfied

dissatisfied

Satisfied

Very Satisfied

3. Have you experienced any discrimination in hiring?

Yes

No

4. Have you ever faced harassment while at job?

Yes

No

5. How will you rate your organizations approach to tackle these problems?

77 | P a g e

Very Poor

Poor

Good

Very Good

This segment is for the residents nearby the hotel only.

1. Do you agree the presence of this hotel is adversely impacting your neighborhood? (for
instance; increased solicitation, gambling, drug etc)
Strongly Disagree

Disagree

Agree

Strongly Agree

2. Do you agree the hotel in your vicinity have taken enough initiative to help the community
to tackle its various problems?
Strongly Disagree

Disagree

Agree

Strongly Agree

3. Does the presence of this hotel cause unwanted traffic zam in your neighborhood?
Yes

No

4. Are you satisfied with the steps they have taken to tackle the problem?

Not satisfied

dissatisfied

Satisfied

Very Satisfied

This segment is for the Suppliers of this hotel only.

1. Does your business partner encourage you to enforce ethical behavior in your
organization?
Yes

No
78 | P a g e

2. How will you rate their engagement activity to enforce ethical behavior in your
organization?
Very Poor

Poor

Good

Very Good

3. How will you rate the hotels approach to aid you in any ethical problem you may be
facing?

Very Poor

Poor

Good

Very Good

79 | P a g e