영문 (ENG)
Introduction
In IHG, we believe that
strong ethics and good business should go together
naturally. We are committed to operating our company with
integrity and in accordance with the highest ethical
standards. Our reputation is built upon the trust and
confidence of all our stakeholders, and is an integral part
of our vision to make IHG one of the very best companies in
the world. This Code of Ethics and Business Conduct (‘The
Code’) sets out the principles and standards describing how
we should work and behave, wherever we are in the world. It
applies to all directors, officers and employees of IHG, and
should be read together with the company’s core values (our
‘Winning Ways’). We must all uphold our responsibility to
behave ethically and protect the reputation of our company.
These principles lie at the heart of who we are, and nothing
should ever compromise our commitment to honesty and
integrity.
Responsibility
for Compliance with the Code
All directors, officers and
employees are responsible for abiding by this Code. This
includes responsibility for the failure to exercise proper
supervision and the responsibility to report a violation by
subordinates. Disciplinary action may, when appropriate,
include dismissal. The standards set out in the Code are
necessarily general and do not address each and every
situation that may confront employees throughout the world.
Where appropriate, guidance should always be sought from
management. In addition, the Company Secretary and Group
Internal Audit are available on a confidential basis as
independent sources of advice.
Health
and Safety
We are all responsible for
helping to maintain a safe and healthy working environment
in line with local laws and regulations and in accordance
with our internal standards.
Equal
Opportunities
We recruit and promote
individuals based solely on their suitability for the job
without discriminating on the grounds of race, color, ethnic
or national origin, gender, sexual orientation, age,
religion, marital status or disability unrelated to the
role. In some countries these principles may be modified by
national legal requirements on affirmative action.
Harassment
We will not tolerate
harassment of any employee by any person, for any reason.
The
Environment
We are committed to
preserving and protecting the environment and to economic
growth and prosperity. These goals are not only consistent
but mutually reinforcing. Protecting the environment is an
investment in all our futures. We are also committed to
constructive participation with all stakeholders in the
ongoing process of sustainable growth.
Conflicts
of Interest
We must always act in the
best interests of IHG and avoid any personal preference or
advantage. This includes situations where personal, family
or financial interests conflict with those of IHG, or where
an employee holds an interest in an organization seeking to
do business with the Group. If you encounter a potential
conflict of interest you must disclose the details and stand
back from any related decision making process. In addition,
you should avoid apparent conflicts of interest which occur
where a reasonable observer might assume there is a conflict
of interest and, therefore, a loss of objectivity in your
dealings on behalf of the Group.
Relationships
with Business Partners
It is in IHG’s best
interests to establish mutually beneficial commercial
relationships with our guests, suppliers and business
partners. Offering or accepting gifts, entertainment or
personal favours is only acceptable if their value is modest
and the practice is consistent with local business culture.
You should not accept gifts, entertainment or favours which
might place you under any obligation or which would
reasonably be viewed as influencing business transactions.
Any gift or hospitality of more than token value must be
reported to senior management who will determine whether it
can be accepted.
Competition
The Group is committed to
open, free and fair competition in all our markets. We will
compete vigorously but honestly, observing all competition
and anti-trust laws. Guidance on competition and anti-trust
compliance can be found in regional competition law and
anti-trust compliance manuals and guidelines.
Fraud
We will not tolerate fraud
of any description. You have an obligation to report any
suspicions of fraud in accordance with the Disclosure
Procedures detailed at the end of this Code.
Property,
Assets and Resources
IHG resources must be
protected and must not be used for personal gain. This
includes tangible assets such as stocks, equipment and cash,
in addition to intangible items such as intellectual
property, computer systems and confidential information.
Information held within the Group such as business plans,
pricing, financial data and guest details remain the
property of IHG and must not be disclosed outside the Group
without prior permission. The storage and use of guest data
may be further subject to data privacy regulations which
must be complied with.
Political
Activity and Contributions
We are all free to take part
personally in political activities in our own time. However,
we must not create the impression that we represent the
Group in these matters. In dealing with regulatory and
public policy issues that affect the Group, we do not make
party political donations but deal with the government of
the day on matters which concern the business.
Records,
Disclosure and Communications
As a publicly listed Group,
we are required to comply with the rules relating to
disclosure of material and price-sensitive information under
the relevant UK and US legislation, and the rules and
guidance of the United Kingdom Listing Authority and the New
York Stock Exchange. In accordance with our disclosure
obligations, financial communications and reports will be
delivered in a manner that facilitates the highest degree of
clarity of content and meaning so that readers and users
will be able to quickly and accurately determine their
significance and consequence. Matters relating to the
activities and performance of the Group must not be
discussed with representatives of the media unless
specifically authorized as part of your role. Our Group
Communications department will co-ordinate any
announcements, statements or responses to questions from the
media, particularly those which relate to share price or
commercially sensitive information.
Insider
Information
If you are in possession of
confidential price-sensitive information which has not been
made public and could affect our share price you may not buy
or sell shares in IHG, or provide such information to third
parties for that purpose. In addition, certain employees may
not deal in IHG securities at any stage during pre-defined
‘close’ periods. The full details of this policy can be
found in the Code of Practice for Dealing in IHG plc
Securities.
Legal
Compliance
We are committed to
compliance with the laws and regulations of the countries
and jurisdictions in which we operate. In the unlikely event
that a local law or regulation conflicts with the Code, you
should continue to comply with the law but you must report
the circumstances of the conflict according to the
Disclosure Procedures detailed at the end of this Code.line
Disclosure
Procedures
The Group provides the following stepped approach for
raising questions or concerns over interpretation or
violation of the Code. We do not permit retaliation against
employees making good faith reports of suspected breaches of
the Code.
Human
rights policy
We support and protect human rights wherever we can. As a
responsible company with operations in nearly 100 countries
and territories, we believe that strong ethics and good
business go hand in hand and we are committed to complying
with the laws and regulations of the countries and
jurisdictions in which we operate.
To demonstrate our commitment in this area we:
• support the protection of human rights,
particularly those of our employees, the parties we do
business with and the communities where we operate
• respect our employees' rights to voluntary freedom of
association, under the law
• provide a safe and
healthy working environment
• do not support forced
and compulsory labour or the exploitation of children
• support the elimination of employment discrimination and
promote diversity in the workplace
• provide our
employees with remuneration and tools for growing their
careers, and take their wellbeing into consideration
• promote fair competition and do not support corruption
• conduct our business with honesty and integrity in
compliance with applicable laws
• develop and
implement company procedures and processes to ensure we
comply with this policy.