Marriott Vacations Worldwide’s Human Rights Policy

Introduction

Marriott Vacations Worldwide Corporation (“MVW,” “Company,” “we,” or “our”) acknowledges and respects the principles contained in the United Nations’ Universal Declaration of Human Rights and United Nations’ Guiding Principles on Business and Human Rights. Our Human Rights Policy reflects our commitment to conduct business in all locations in a manner consistent with these principles and to protect human rights within the conduct of our business. Specifically, we expect our suppliers, service providers, associates, and business partners to support and uphold the Human Rights principles outlined in this policy.

We are engaged in responsible workplace practices and endeavor to conduct our business in a manner that is free from complicity in human rights abuses in all forms. Our core values and culture embody a commitment to ethical business practices and good corporate citizenship that are in line with our Business Conduct Guide.

Protection of Basic Human Rights

We strive to ensure our business operations do not impact basic human needs, such as access to food, water, sanitation, or healthcare in local communities.

Discrimination and Equal Opportunity

We support the elimination of discriminatory practices and provide equal employment opportunities for all individuals regardless of their race, color, ancestry, creed, national origin, ethnicity, religion, gender, pregnancy, sexual orientation, gender expression or identity, age, disability, immigrant status, or other classes protected by applicable law. We are committed to non-discrimination and fairness in our labor practices, including associate remuneration, recruitment, and promotions.

Human Capital Practices

We maintain a set of programs and initiatives, rooted in our Core Values, designed to attract, develop, retain, and engage associates. These programs and initiatives are focused on:

Inclusion and Diversity

We promote and embrace diversity and seek to provide an inclusive environment in all aspects of our business operations. We are committed to creating an environment of inclusion and equal opportunity for all individuals regardless of their race, color, ancestry, creed, national origin, ethnicity, religion, gender, pregnancy, sexual orientation, gender expression or identity, age, disability, immigrant status, or other classes protected by applicable law. The MVW Executive Inclusion Council is a representative group of executives and senior leaders dedicated to enabling and championing inclusion and diversity across the organization.

Human Trafficking

We are committed to being vigilant in identifying, reporting, and assisting in preventing human trafficking in all forms. We have developed a comprehensive human trafficking awareness program, which includes mandatory Company-wide associate training, in an effort to help our associates identify possible situations of human trafficking. Our human trafficking awareness program aligns with federal and state jurisdictional requirements, as well as guidance and recommendations issued by local organizations and law enforcement agencies.

Forced Labor

We prohibit the use of forced, bonded, or compulsory labor, and we are committed to ensuring that forced labor in all its forms is prevented from occurring as a result of our business activities. This includes the elimination of modern slavery, debt bondage, trafficking in persons, prison labor, compulsory labor, military work, and abuse of homeworkers, as defined by the International Labor Organization. We fully support the following principles from the Sustainable Hospitality Alliance’s Principles on Forced Labor:

Protection of the Rights of Children

We condemn all forms of exploitation of children. We only recruit individuals who are of lawful age to work in the applicable geographical location. We support laws enacted to prevent and punish the crime of exploitation of children.

Ethical Recruitment

We undertake associate recruitment with the highest of ethical standards. We have implemented a ‘no fees’ recruitment policy, and we do not ask for money or charge fees to applicants as part of the application process.

Freedom of Association

We support our associates’ freedom of association and the right to choose a collective bargaining representative, if desired.

Non-Harassment

We do not tolerate harassment in the workplace. Associates who observe instances of workplace harassment or unlawful discrimination should report their concerns to the contacts listed in the Business Conduct Guide.

Health and Safety

We consider safety and security to be an integral part of the responsibilities of all levels of management. It is our policy to attempt to minimize losses, injuries, and damages resulting from accidents through adoption of proactive measures, which include accident prevention training programs and safety and security guidelines and standards. It is also our policy to comply fully with safety and security regulations, codes, and laws in jurisdictions in which we operate or employ associates remotely.

A high standard of cleanliness is core to our activities, and the impact of COVID-19 has reinforced our commitment to cleaning protocols and training programs for associates on health and safety measures. We continue to monitor CDC and WHO guidance on a regular basis to ensure that our protocols are reflective of the latest requirements. All private vacation spaces undergo a robust regimen of cleaning protocols including use of hospital-grade disinfectants. Additionally, we have implemented:

Ethical Business Conduct

Our policies require us to conduct business with honesty and integrity and in full compliance with all applicable laws. Our policies establish clear ethical standards and guidelines for how we conduct business and establish accountability. All of our associates are required to obey the law and comply with specific standards relating to legal obligations, ethics, and business conduct. We have clear accountability mechanisms in place to monitor and report on compliance with these directives.

Reporting of Concerns

Associates who have concerns regarding this policy may contact the Business Integrity Line as outlined in the Business Conduct Guide. We prohibit retaliation against associates who report concerns to the Business Integrity Line.

Governance

This Human Rights policy is reviewed and, if necessary, updated annually.