Vendor Code of Conduct

1. Labour:

1.1 Freedom of Association and Collective Bargaining: COMO Hotels and Resorts expects its vendors to recognise and respect the rights of employees to freely associate, organise and bargain collectively in accordance with the laws of the countries in which they are employed. COMO Hotels and Resorts recognises the importance of open communication and direct engagement between workers and management and vendors are to respect the rights of workers to associate freely and communicate openly with management regarding working conditions without fear of harassment, intimidation, penalty, interference or reprisal.

1.2 Forced Labour: COMO Hotels and Resorts expects its vendors to prohibit any use of forced, bonded or indentured labour or involuntary prison labour, and embrace employment practices consistent with International Labour Organization conventions pertaining to forced labour. All work, including overtime work, will be voluntary and workers should be free to leave upon reasonable notice. Vendors should also not mandate that workers hand over government-issued identification; passports or work permits as a condition of employment.

1.3 Child Labour: COMO Hotels and Resorts expects its vendors, at a minimum, not to engage in any practice inconsistent with the rights set forth in the Convention on the Rights of the Child. The minimum admission to employment or work shall not be less than the age of completion of compulsory schooling, normally not less than 15 years or 14 where the local law of the country permits, deferring to the greatest age. Additionally, all young workers must be protected from performing any work that is likely to be hazardous or to interfere with the child’s education or that may be harmful to the child’s health, physical, mental, social, spiritual or moral development. All vendors should also adhere to legitimate workplace apprenticeship programs and comply with all laws and regulations governing child labour and apprenticeship programs.

1.4 Discrimination: COMO Hotels and Resorts expects its vendors to follow hiring and employment practices in accordance with the laws of the countries in which they operate.

1.5 Working Hours: COMO Hotels and Resorts expects its vendors to comply with all applicable working hour requirements as established by local law. Vendors must ensure that all overtime work is voluntary and compensated at the prevailing overtime rates.

1.6 Compensation: COMO Hotels and Resorts expects its vendors to comply, at a minimum, with all wage and hour laws and regulations, including those pertaining to minimum wages, overtime wages, piece rates, other elements of compensation and to provide legally mandated benefits

2. Human Rights:

2.1 Human Rights: COMO Hotels and Resorts expects its vendors to support and respect the protection of internationally proclaimed human rights and to ensure that they are not complicit in human rights abuses.

2.2 Harassment, Harsh or Inhumane Treatment: COMO Hotels and Resorts expects its vendors to create and maintain an environment that treats all employees with dignity and respect and will not use any threats of violence, sexual exploitation or abuse, verbal or psychological harassment or abuse. No harsh or inhumane treatment coercion or corporal punishment of any kind is tolerated, nor is there to be the threat of any such treatment.

2.3 Health and Safety: COMO Hotels and Resorts expects its vendors to follow all relevant legislation, regulations and directives in country in which they operate to ensure a safe and healthy workplace or any other location where production or work is undertaken. At a minimum, vendors should strive to implement recognised management systems and guidelines such as the ILO Guidelines on Occupational Safety and Health (ILO-OSH-2001) which can be found at ILO's website and ensure at a minimum, reasonable access to potable water and sanitary facilities; fire safety; emergency preparedness and response; industrial hygiene; adequate lighting and ventilation; occupational injury and illness and machine safeguarding. Vendors will also ensure these same standards apply to any dormitory or canteen facilities.

3. Environment:

3.1 Environmental: COMO Hotels and Resorts expects its vendors to have an effective environmental policy and to comply with existing legislation and regulations regarding the protection of the environment.

3.2 Vendors should wherever possible support a precautionary approach to environmental matters, undertake initiatives to promote greater environmental responsibility and encourage the diffusion of environmentally friendly technologies implementing sound life-cycle practices.

3.3 Chemical and Hazardous Materials: Chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, recycling or reuse and disposal.

3.4 Wastewater and Solid Waste: Wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be monitored, controlled and treated as required prior to discharge or disposal.

3.5 Air Emissions: Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterised, monitored, controlled and treated as required prior to discharge.

3.6 Minimise Waste, Maximise Recycling: Waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.

4 Bribery and Corruption:

4.1 Corruption: COMO Hotels and Resorts expects all vendors to adhere to the highest standard of moral and ethical conduct, to respect local laws and not engage in any form of corrupt practices, including extortion, fraud, or bribery, at a minimum.

4.2 Conflict of Interest: COMO Hotels and Resorts vendors are expected to disclose to COMO Hotels and Resorts any situation that may appear as a conflict of interest, and disclose to any COMO Hotels and Resorts official or professional under contract with COMO Hotels and Resorts that may have an interest of any kind in the vendor's business or any kind of economic ties with the vendor.

4.3 Gifts and Hospitality: COMO Hotels and Resorts has a “zero tolerance” policy and does not accept any type of gift or any offer of hospitality beyond that of a representational nature.

4.4 Provenance: COMO Hotels and Resorts requires that all vendors are able to produce full documentation, showing all details relating to origin, history and authenticity of all products supplied.

5. Confidentiality:

5.1 COMO offers our guests and homeowners sanctuary and comfort. As such, part of our service is to protect their privacy with utmost discretion. Hence, vendors must not disclose, publish, disseminate, sell or exploit confidential information relating to guests, nor should they ever threaten to do so.

5.2 Vendors must not take photographs, nor request or approach guests for an autograph, interview, photograph, favour, personal question or similar requests. Any interactions with guests should be directly related to the service we are offering only.

5.3 Vendors may learn, acquire, or become aware of information, and/or tangible things relating to or concerning personal and/or business information of guests. These should all be kept strictly confidential.

5.4 Vendors may only produce images, photographs, information, documents, audio or video recordings relating to guests if given express permission. They may not do so for personal purposes.

5.5 If Vendors have access to or produce any images, photographs, information, documents, audio or video recordings or any other private information relating to guests, this must be kept strictly confidential.

5.6 Vendors must never participate in forums, social networking sites, or interviews referring to guests. This includes never referring, confirming or denying any information of any kind (including rumours) relating to guests.

5.7 Upon termination of service, vendors must return all personal and confidential information regarding guests and permanently erase digital records of such information on their personal devices.