Table of Contents

1. Introduction
2. Labour and Human Rights
3. Business Integrity
4. Health and Safety
5. Environmental Sustainability
6. Protecting local Communities
7. Business Continuity Planning
8. Controls, Inspection and Audit
9. Supplier Grievance Mechanism
10.Reporting Violations

1. Introduction

Belmond Ltd. and its subsidiaries and affiliates (the “Belmond Group”) are a member – or “Maison” – of the LVMH Group and as such, attach great importance to ensuring that our suppliers, agents and partners (“Suppliers”) share with the Belmond Group (and wider LVMH Group) a set of common rules, practices and principles with respect to ethics, social responsibility and protection of the environment.

This Supplier Code of Conduct sets out the standards, behaviours and practices that the Belmond Group – and LVMH Group - expects from all of its Suppliers (and their supply chains). In addition to compliance with this Supplier Code of Conduct, all Suppliers (and their supply chains) are also required to operate in full compliance with all applicable laws and regulations of the countries in which they operate; and to comply (as a minimum) with the principles stipulated in the Conventions of the International Labour Organization, the Universal Declaration of Human Rights, the United Nations Global Compact, the OECD Guidelines for Multinational Enterprises and the United Nations Women’s Empowerment principles.

By becoming or continuing to be a Supplier, you hereby agree:

a. to abide by (and be responsible for ensuring that your sub-contractors and suppliers abide by) the terms of this Supplier Code of Conduct (as amended from time to time by an update to the Belmond Group’s website(s));
b. that failure to comply with this Supplier Code of Conduct entitles the Belmond Group (and wider LVMH Group) to review its business relationship with you and in its discretion require correction of the violations, suspend purchases, refuse to take delivery under any purchase order and return any goods from the Supplier until the non-conformities have been corrected, and terminate it in conformity with applicable law without penalty and without prejudice to the other rights of the LVMH Group or remedies available to such entity(ies) within the LVMH Group.

In the event of any conflict between the terms of this Supplier Code of Conduct and:

a. the terms of your contract with the Belmond Group, the terms of this Supplier Code of Conduct shall prevail;
b. applicable law, the applicable law shall apply.

If national legislation or other applicable regulations address the same issue(s) as this Supplier Code of Conduct, the highest standards or most restrictive provisions shall apply.

2. Labour and Human Rights

Forced Labour

The LVMH Group does not tolerate the use (by its Suppliers or at any stage in its or their respective supply chains) of forced labour which includes slavery, servitude, compulsory labour, indentured or bonded labour, human trafficking and any other forced labour which would contravene the UK Modern Slavery Act 2015 and/or the United Nations Universal Declaration of Human Rights and Labour Standards set by the International Labour Organisation. The LVMH Group is (and requires its Suppliers to be) committed to uphold the human rights of workers throughout their supply chains and to treat them with dignity and respect. This applies to all workers including temporary, migrant, student, contract, direct employees and any other type of worker.

All individuals’ work must be voluntary and workers must be free to terminate their employment in accordance with established laws and legislation. Workers must not be required to surrender any government-issued identification, passports, work permits or travel documents as a condition of employment by any Supplier (or supplier in its supply chain), or to work to repay a debt owed to a Supplier (or any supplier in its supply chain) them or to a third party.

Child Labour

The use of child labour by Suppliers (or their supply chains) is strictly prohibited. A child is defined as any person less than 16 years of age, unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age applies.

Suppliers (and their supply chains) must not allow anyone under the age of 18 to perform any overtime or hazardous work or work a night shift. Suppliers may use lawful, legitimate, properly-managed workplace apprenticeship programs, such as student internships.

Wage and Benefits

Suppliers (and their supply chains) must:

a. pay wages in legal tender in a timely manner and on a regular basis and no less than monthly;
b. follow and be in compliance with all applicable laws and mandatory industry standards pertaining to regular working hours, days of rest and overtime;
c. meet all legal requirements relating to worker’s benefits including ensuring that their workers receive the benefits stipulated in any applicable collective bargaining agreements, company agreements and other applicable negotiated individual or collective agreements.

If there is no legal minimum wage or rate for overtime pay in the country concerned, the Supplier (and their supply chain) must ensure that the wages are at least equal to the average minimum in the relevant sector and that overtime pay is at least the same as the usual hourly compensation. Wages must be sufficient to meet the workers’ basic needs and provide some discretionary income.

Suppliers must ensure (and take steps to ensure their supply chain provide) that all overtime is not excessive and workers receive adequate compensation, with entitlement to at least one day off in every seven day period.

Wage deductions must not be used as a disciplinary measure. Suppliers (and their supply chains) must communicate pay structure and pay periods to all workers.

Prohibition of harassment and abuse

The LVMH Group expects its Suppliers (and their supply chains) to treat their workers with respect and dignity. Suppliers (and their supply chains) must not tolerate or engage in any form of corporal punishment, physical, sexual, verbal or psychological harassment or any other kind of abuse.

Prohibition of Discrimination

The LVMH Group expects its Suppliers (and their supply chains) to treat all workers equally and fairly. Suppliers (and those in their supply chains) must not engage in discrimination whether based on race, nationality, colour, age, gender, sexual orientation, gender identity, ethnicity, disability, pregnancy, religion, political affiliation, union membership, marital status, social background or otherwise, in hiring, wages, access to training, promotion, maternity protection, dismissal and any other employment practices.

Freedom of Association

Each Supplier must (and take steps to ensure their supply chain) operate with dignity, respect and integrity in regards to the treatment of its employees or workers. Suppliers are to respect the rights of workers to associate freely with others, form and join (or refrain from joining) organisations of their choice, and bargain collectively, and communicate openly with management regarding working conditions without fear of harassment, intimidation, discrimination, penalty, interference or reprisal. When applicable, Suppliers (and their supply chains) must provide workers’ representatives with appropriate means to exercise their rights. Intimidation, threats or discriminatory practices against workers’ representatives are prohibited.

3. Business Integrity

The LVMH Group has a zero-tolerance policy concerning corruption. No Supplier (nor any of their supply chain) must ever, directly or through intermediaries, offer or promise any personal or improper advantage in order to obtain or retain, a business or other advantage, whether public or private. This includes a prohibition of so-called facilitation payments or other benefits provided to public officials for routine non-discretionary actions.

No Supplier will pay or accept bribes, arrange or accept kickbacks and shall not take any actions to violate, or cause its business partners to violate, any applicable anti-bribery laws and regulations including the US Foreign Corrupt Practices Act, the UK Bribery Act 2010, the French anti-corruption law (“Sapin II”) (each as amended or superseded from time to time), and the regulations and laws of the countries in which they operate.

The LVMH Group expects its Suppliers to take appropriate measures to prevent, detect, and discipline any corruption or influence peddling, directly or indirectly, across the scope of their activities.

Gifts and Hospitality

Gifts or invitations may be considered acceptable expressions of courtesy within the context of good business relations as long as they are limited in scope and value, given openly and transparently, permitted under applicable law and regulations, customary in the location in which they would be given, provided to reflect esteem or gratitude, and not offered with an expectation that something will be offered in return. In some cases, these practices might be subject to anti-corruption regulations or other legal requirements, making it essential for Suppliers to commit to comply with applicable rules and regulations within the scope of their business relationship with any member of the LVMH Group.

Suppliers should not provide any gift, meal or entertainment to a Belmond Group employee (or their family) in any situation in which it might influence or appear to influence any Belmond Group employee‘s decision in relation to that Supplier.

Conflicts of Interest

The LVMH Group requires all Suppliers (and their supply chains) to comply with all applicable laws concerning conflicts of interest and to make every effort to prevent the occurrence of situations that create (or could create) an actual, perceived or potential conflict of interest within the scope of their business relationship with the LVMH Group.

Each Supplier is expected to report to the LVMH Group any situation that may appear as a conflict of interest (with them or their supply chain), and to disclose to the LVMH Group if any employee or professional under contract with the Belmond Group may have an interest of any kind in the Supplier’s business or any kind of economic ties with the Supplier.

If a Supplier employee (or employee of their supply chain) is a family relation to any Belmond Group employee or if a Supplier (or their supply chain) has any other relationship to any LVMH Group employee that might represent a conflict of interest, the Supplier should disclose this fact to the Belmond Group (see contact details below) or ensure that the Belmond Group employee does so.

Suppliers must make the Belmond Group aware of any organisational conflicts of interest that could prohibit Belmond or the wider LVMH Group from pursuing future work with it.

Confidential Information and Intellectual Property

Each Supplier shall take appropriate steps to safeguard and maintain the LVMH Group’s confidential and proprietary information and use such information only for the purposes authorised by its contractual agreements with the LVMH Group.

In cases of sub-contracting (to the extent sub-contracting is permitted by the Supplier’s contract with the Belmond Group), sharing of confidential information should be made only with the prior written consent of the Belmond Group.

Suppliers (and their supply chain) must protect the personal information of the Belmond Group’s guests and employees (including personal credit card information and personally identifiable information) and must comply with all applicable privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted and shared. Suppliers (and their supply chain) must ensure that they have appropriate technical and security controls in place to protect such confidential information and may only disclose such information to their personnel with a need to know such information in the performance of their work for the Belmond Group and only if permitted to do so by their contract with the Belmond Group and applicable law. Without prejudice to the terms of their data processing agreement(s) with the Belmond Group, in the event of an unauthorized disclosure of such confidential information, or a breach of the Supplier’s (or their supply chain’s) network systems and/or such information, Suppliers (and their supply chain) must provide immediate notice to their account manager at the Belmond Group and by email to dpo@belmond.com and provide the Belmond Group with all such assistance as it may reasonably require to enable it to make such notifications as it is required to make to affected individual(s) and regulator(s).

Unless a member of the LVMH Group has duly granted permission to a Supplier to use any LVMH Group trade mark, logo, image or other intellectual property right (“LVMH IPR”), no Supplier may use or claim any right to any LVMH IPR.

Each Supplier with access to the IT resources and information systems of Belmond may only access them if expressly authorized in writing by the Belmond Group. Suppliers must (and must ensure their and their supply chain’s staff) protect and not disclose passwords, user IDs, PINs, or other access credentials; use only approved, authorised and properly licensed software and access methods when interfacing the IT resources and information systems; ensure that all appropriate security controls are in place prior to any IT resource and information system access; never attempt to circumvent security controls used in connection with such resources and systems; immediately terminate access for any employee or worker (of that Supplier or their supply chain) whose employment/engagement ends; and ensure the security and confidentiality of all information obtained through such access.

Competition and Anti-Trust

LVMH is committed to free and open competition in all the markets in which it operates. We compete fairly and ethically, and support laws that promote and protect competition. The LVMH Group requires that its Suppliers (and their supply chains) are also committed to complete compliance with competition law applicable in the countries in which they operate and in any case that they take all appropriate measures to prevent abuse of a dominant position, concerted practices, or unlawful agreements between competitors, such as the setting of prices or price ranges (price fixing) or market allocations or boycotts limiting the production of certain products.

Information Transparency

We expect that when our Suppliers are preparing proposals, bids or undertaking contract negotiations for the Belmond Group and our guests, they are certain that all statements, communications and representations regarding the methods and resources used, production sites and characteristics of the products or services supplied are accurate and truthful.

Prohibition of Money-Laundering

Money-laundering can occur where an action is taken to mask the true origin of money or assets that are connected to criminal activity. All Suppliers are required to take all appropriate measures to prevent their operations from being used as vehicles for money-laundering.

Prevention of Insider Trading

Shares in the capital of LVMH - Moët Hennessy – Louis Vuitton SE (“LVMH SE”) are listed on a recognised stock exchange and by performing services for the Belmond Group (or wider LVMH Group), Suppliers, their supply chains and their respective workers, officers and employees may acquire unpublished price sensitive “insider” information about LVMH SE.

Any dealing in shares (or linked derivative financial instruments including but not limited to shares in Christian Dior SE) of LVMH SE (“LVMH Stock”) by those with inside information breaches laws on insider dealing.

All Suppliers (and their supply chains) must comply (and have written policies in place to require all relevant employees, workers and officers to comply) with all applicable laws and legislation concerning insider trading and to refrain from selling, buying or otherwise dealing (either directly or indirectly) in any LVMH Stock, based on insider information.

Customs and Security Authorities

All Suppliers (and their supply chains) must comply with applicable customs laws, including those relating to imports and the ban on transhipment of merchandise, good and supplies to the importing country.

Trade Restrictions and International Sanctions

All Suppliers (and their supply chains) are required to respect and comply with international trade restrictions and economic and trade sanctions, taking into account any changes in these measures, as well as all laws and regulations concerning export and import controls.

The LVMH Group requires each Supplier (and their supply chains) to implement measures to ensure compliance with applicable sanctions (including but not limited to those imposed by the United Kingdom, United Nations, the EU and OFAC).

Public Statements

We expect our Suppliers to be extremely attentive to their public statements, particularly on the Internet and in social media, and to ensure that any none of those statements be attributed to any entity belonging to the LVMH Group or their shareholders, directors, officers or employees, and are consistent with Suppliers’ commitment to both confidentiality and respect of professional secrets.

4. Health and Safety

In line with the LVMH Health & Safety Policy, Suppliers (and their supply chains) are expected to provide their workers with a safe and healthy workplace environment in order to avoid accidents, bodily injuries, exposure to danger or illnesses which may be caused by, related to, or result from their work, including during the operation of equipment, handling/use of chemical products, or during work-related travel.

All Suppliers must (and must take steps to ensure their supply chain):

a. provide workers with a clean, safe and healthy working environment (and living environment where suppliers or their supply chains provide staff housing) in compliance with all legally mandated standards for workplace health and safety in the countries in which they operate;
b. implement procedures and training to detect, avoid and mitigate as much as possible any hazards that constitute a risk to the health, hygiene and safety of others and are required, at a minimum, to comply with all applicable local and international regulations and laws in this regard;
c. require their workers (whilst on-site providing services for the LVMH Group) to comply with health and safety instructions given by or on behalf of the Belmond Group;
d. ensure health and safety instructions are put in place and widely communicated. Compliance by workers must be regularly evaluated;
e. provide workers with protective equipment appropriate to their activities.

Emergency Procedures

Each Supplier providing services for Belmond Group staff or guests off Belmond Group property, must be prepared for emergency situations. This includes worker notification and evacuation procedures, emergency training and drills, appropriate first-aid supplies, appropriate fire detection and suppression equipment and adequate exit facilities.

Each Supplier shall regularly train its employees on emergency planning, responsiveness and first aid medical care.

5. Environmental Sustainability

Each Supplier shall regularly train its employees on emergency planning, responsiveness and first aid medical care.

The LVMH Group has established an environmental strategy and takes concrete measures to protect the environment within the scope of a specific program which includes cooperation with its Suppliers to ensure application of best practices throughout the supply chain.

The LVMH Group expects its Suppliers to share this commitment and encourages initiatives by its Suppliers (and their supply chains) to reduce the environmental impact of their activities, notably through the use of green technologies and to share environmental figures with the entities within the LVMH Group with which they have a business relationship when needed.

The LVMH Group requires its Suppliers (and their supply chain) to:

a. respect applicable local and international environmental laws, regulations and best professional standards;
b. obtain all requisite environmental permits; and
c. be able to demonstrate effective implementation of the following:

• application of an environmental management system (such as ISO 14001 certification);
• improvements in the environmental performance of their sites and production resources, in particular through proper waste management, elimination of air, waste water, and soil pollution (including aquifers), reduction of greenhouse gas emissions with an emphasis on use of renewable energies, reduction of water and energy consumption;
• measures to ensure that workers whose activities have direct environmental impact are trained, skilled, and have the resources required to effectively perform their work in consideration of these environmental commitments;
• contributions to continuous improvements in environmental performance throughout the lifecycle of the products of the LVMH Group. For instance, Suppliers are committed to share with the entity(ies) within the LVMH Group with which they have a business relationship the most responsible options (certified materials, recycled materials, materials sourced with regenerative agriculture practices….), when reasonably available. Finished or semi-finished products bearing distinctive trademarks, design rights or other intellectual property assets belonging to entities within the LVMH Group that have not been ordered or have been refused, should be managed as instructed by the relevant contact person within the LVMH Group;
• measures to ensure safe chemical management and chemical compliance of products and raw materials with either applicable national and international regulations and best professional standards, including REACH regulations and the LVMH Restricted Substances List (available upon request);
• measures to preserve biodiversity and ensure compliance with relevant environmental international standards and regulations such as CITES;
• measures to ensure a zero illegal deforestation and zero deforestation in high risk areas;
• measures to guarantee traceability, share information with regard to raw material origin, and compliance for raw materials and substances used;
• measures implemented across the supply chain to respect animal welfare and implementation of the requirements defined in LVMH Animal Based Raw Materials Charter (available upon request).

6. Protecting Local Communities

As a responsible and committed group present around the world, the LVMH Group strives to have a positive influence on the societies and regions in which it operates, prevent any damage to local communities and requires its Suppliers to apply the same behaviour. When operating with indigenous communities, as defined by the United Nations Declaration on the Rights of Indigenous Peoples, Suppliers must seek free, prior, and informed consent (FPIC) and ensure their human rights capacity.

7. Business Continuity Planning

The Belmond Group requires its Suppliers (and their supply chains) to be prepared for any disruptions to their businesses (e.g. natural disasters, terrorism, software viruses, illness, pandemic, infectious diseases). This preparedness should include written business continuity and disaster plans to mitigate the impact of such events.

8. Controls, Inspection and Audit

The LVMH Group expects its Suppliers to ensure that adequate and effective management systems, policies, procedures, and training are in place to ensure ongoing compliance with this Code.

Each of the entities within the LVMH Group reserves the right to control compliance with the principles set forth in this Code by Suppliers. These controls will be performed by such entities of the LVMH Group or duly mandated third parties. Any control or audit will be related to the business relationship between the relevant entity within the LVMH Group and the Supplier. If a Supplier is subject to specific professional obligations pursuant to law, any control or audit will be carried out taking into consideration these professional obligations. Suppliers must commit to improving or correcting any deficiencies identified. The entities of the LVMH Group may also support Suppliers in implementing and applying best practices in order to resolve non-conformity issues.

Suppliers shall provide upon request any supporting documentation or information attesting full compliance with this Code.

9. Supplier Grievance Mechanism

Suppliers must establish processes or mechanisms by which workers and stakeholders can raise issues of concern without fear of retaliation or negative impact.

10. Reporting Violations

Suppliers which become aware of violations (or risk of violation) of the LVMH Code of Conduct, guidelines, principles and policies and/or of applicable laws and regulations are invited to raise their concern to their contact person(s) in the entity(ies) within the LVMH Group with which they have a business relationship. Belmond Group Suppliers can report violations or concerns to compliance@belmond.com or to the Belmond Group’s Speak Up line via an independent third party website.

In addition to this channel for raising ethical and other concerns, Suppliers have access to the LVMH Alert Line, an online interface that provides a confidential and secure way of reporting in good faith violations (or risk of violation) of the LVMH Code of Conduct, guidelines, principles and policies and/or of applicable laws.

A Supplier’s relationship with the LVMH Group will not be affected by a report of potential misconduct made in good faith.

The LVMH alert line, which is also open to LVMH Group’s employees and other external stakeholders, can be accessed through LVMH.com or directly.