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Starwood Hotels & Resorts Worldwide, Inc. does not condone nor permit
bribery, solicitation of bribery or the payment of kickbacks, even if permitted by local
custom or practice. Starwood’s Code of Business Conduct and Ethics (“Code”) and
Anti-Corruption Policy mandate compliance with applicable law, rules or regulations.
The key principles set forth in these policies include the following:
Approval is required for the hotel (or any of its associates) to offer or give
anything of value, even minimal value, to a government official or to someone
in a position to influence a government official, unless otherwise permitted
without such approval in the Anti-Corruption Policy.