Code of Ethics

Contents

Open letter from H10 Hotels management

Scope

Understanding the code of conduct

Code of conduct

Complying with the code of conduct

Effective date

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Code of Ethics

OPEN LETTER FROM H10 HOTELS MANAGEMENT

Dear team members,

Since the beginning of H10 Hotels in the early 80's, our main focus has been on customer satisfaction. To achieve this, our hotels have privileged locations, both on the sea front and in the city centre, specialized services, carefully selected meals and facilities that are constantly updated to ensure the highest quality. To this end, we have developed the most demand-ing quality systems and have obtained multiple certificates and accreditations both nationally and internationally. All this is possible thanks to the constant work of each and every member of the H10 Hotels team who strives every day to make our mission possible: to amaze our customers so they enjoy their time in our hotels and dream of returning.

Our focus on continuous improvement and a firm commitment to our values (respect, en-thusiasm, responsibility, honesty and creativi-ty) also lead us to the need and the desire to promote and achieve the highest levels of busi-ness ethics, both in our internal relations (with our employees and collaborators) and our ex-ternal relations (with our customers and suppli-ers of goods and services).

With this in mind, in July 2017 we approved the H10 Hotels Code of Ethics to serve as a framework of conduct for all those who are part of the organisation and as a demonstra-tion of H10 Hotels corporate management's binding commitment with compliance. The approval of this Code of Ethics, which should govern the behaviour of all employees, man-agers, administrators and collaborators of H10 Hotels, as well as its customers, partners, sup-pliers and, in general, any natural or legal per-son that maintains relations with H10 Hotels in any capacity—working, professional, commer-cial, business, civil—, has gone ahead as part of an implementation framework for an ambi-tious programme of regulatory compliance and good governance that must support all our actions.

From now on, we want to be known not only for the excellence and quality of our services, but also for the commitment of all the people who are part of H10 Hotels to our ethical prin-ciples and to rigorous regulatory compliance in all areas.

BarcelonaH10 Casa Mimosa****s

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Code of Ethics

SCOPE

This Code is binding, mandatory and applica-ble to all employees, managers and collabo-rators that are part of H10 Hotels, including members of the governing bodies of the com-panies that comprise it, without any exception or distinction due to job position, responsibility, occupation or geographical location.

Awareness and compliance is also mandatory for customers, partners, suppliers and any nat-ural or legal persons, insofar as they maintain some type of connection or legal relationship with H10 Hotels.

Notwithstanding the powers of supervision and control that ultimately correspond to the Director of Regulatory Compliance, the re-sponsibility to comply with the code of con-duct that makes up this Code and to respect its principles and guiding values lies with each and every one of the people who com-prise H10 Hotels. For this reason, no one is

authorised to execute orders or instructions that contravene or violate the provisions of this Code and, in the event that this happens, the recipient of such orders or instructions should never abide by them and must make the inci-dent known to the group's management or the Director of Regulatory Compliance, through the whistleblower channel specially created for this purpose.

The application or enforcement of this Code may never protect the violation of applicable legal provisions nor excuse their non-compliance.

Any violation of the principles, values or code of conduct set forth in this Code may imply the imposition of appropriate disciplinary or con-tractual measures, depending on the serious-ness of the breach, and may lead to the ter-mination of the corresponding working, civil or business relationship.

UNDERSTANDING THE CODE OF CONDUCT

Notwithstanding the effectiveness of commu-nication actions and acceptance of this Code by H10 Hotels and its employees, managers, dependents, collaborators, customers, sup-pliers, partners or third parties, its publication and distribution through the corporate website (www.h10hotels.com) makes its knowledge and compliance mandatory for all people in-cluded in its scope.

Any doubts that may arise from the interpreta-tion or application of the code of conduct es-tablished in this Code shall be submitted to the responsible officer of the corresponding area of activity or, if necessary, to the Director of Regulatory Compliance, the Legal Department and/or to Human Resources.

TenerifeH10 Conquistador****

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Code of Ethics

CODE OF CONDUCT

Our valuesIn o rder to be consistent with ourselves and with all those who are part of H10 Hotels, it is necessary and essential that all of us who make up this organisation should be aware of and act on the values we have decided should govern our behaviour, in the way we proceed/act within H10 Hotels, in order to be able to ful-fill the mission and vision that we have estab-lished, adopting the following values:

• RESPECT: Treat the environment and oth-ers as I would like to be treated. Know how to listen, value and understand. Know how to ac-cept decisions made for the common good.

• ENTHUSIASM: Optimism, joy, living every day with enthusiasm. There is no need to be serious in order to work seriously. Desire and predisposition to get things done. Face chal-lenges with an eagerness to overcome—posi-tiv i sm. See changes as opportunities for improvement.

• RESPONSIBILITY: Ability to commit suc-cessfully to a role. Firmly meet accepted com-mitments and their consequences.

• HONESTY: Recognise our own mistakes, towards ourselves and towards others, acting without deceit and with transparency. Sincerity, honesty, integrity.

• CREATIVITY: Added value that sparks con-tinuous improvement, initiating changes in es-tablished processes, breaking the routine and creating new and surprising outcomes, not fall-ing away either in success or failure.

This commitment represents a change, if nec-essary, with ways of acting contrary to the val-ues set forth, for all of us who are currently part of the company and for those who will be in-tegrated in the future. We have the obligation

to comply with them, as well as to ensure that they are fulfilled, without ascribing to the theory of the "fake colleague" or misguided corporat-ism as an excuse not to do so, since if some-one does not comply with what the group has decided, by doing or tolerating it, they are ex-cluded from the group, as defined, in order of importance, in the WORKING PRINCIPLES OFTEAMMEMBERS (those of us who are a part of and who will be a part of H10 Hotels):

1.THEYSHAREANIMPORTANTCOMMON GOAL.

2.THEYHAVEPOWERFULVALUESANDCOMMONBELIEFS.

3.THEYRESPECTANDTRUSTEACHOTHER.

4.THEYSPEAKANDCOMMUNICATEWITHEACHOTHEROPENLY.

5.THEYPUTTHEOBJECTIVESOFTHE GROUP AHEAD OF THEIR OWN.

6.THEYMUTUALLYPROTECTANDSUPPORT EACH OTHER.

7.THEYPUTSHAREDLEADERSHIPINTO PRACTICE.

The indicated values are mandatory for all those who are part of H10 Hotels, so we must act according to them a nd the interpretation we have given them, not tolerating contrary at-titudes and actions.

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Code of Ethics

Our commitment to compliance with the lawAll persons who are part of H10 Hotels must be aware of the criminal law that governs the places where we provide our services, as well as comply with and observe the measures and procedures established by the company to prevent the commission of crimes.

Consequently, all persons who work for H10 Hotels or who are in any way linked to our ac-tivity must assume the obligatory commitment to avoid any conduct or behaviour that may be considered illegal, irregular or unethical during the carrying out of their working, professional, commercial, business or institutional functions or in representation of the company.

Our commitment to loyalty and good faithLoyalty and good faith are two essential values of our corporate culture.

All our employees, managers and collabora-tors must always adjust their actions to princi-ples of loyalty and good faith in their interper-sonal, working, commercial and professional relationships with the company, its customers and its suppliers.

In the event of a conflict, the general interests of the company and our customers will always be a priority over our personal or third-party interests.

Our commitment to human rights and the dignity of individualsRespect for human rights is an inalienable eth-ical pillar of any civilised society.

In our corporate sphere, relations between people who in one way or another are linked to H10 Hotels must be based on respect for the dignity of people and on non-discrimination:

We believe and promote real and effective equal opportunities for men and women.

We appreciate cultural diversity and opinions as a source of understanding and business development.

We strongly reject any type of discrimination, behaviour or expression that promotes ha-tred or hostility on the basis of race, physical or psychological disability, age, religion, sexu-al orientation, political ideology or social origin.

Any type of physical, psychological or sexual harassment or abuse in our work, commercial or social environment is unacceptable.

We do not tolerate any kind of activity related to pornography or prostitution in which minors or disabled persons may be involved.

All H10 Hotels employees, managers and col-laborators are responsible for respecting and promoting these principles during the provision of services.

For this reason, H10 Hotels calls on all its em-ployees and managers to take care of their manners and the language that they use in their relations, and, particularly, in the treatment that they give to our customers and suppliers, al-ways avoiding making disrespectful or defam-atory comments and, of course, refraining from any kind of act or expression that may entail humiliation, contempt, intimidation or discredit towards the person in question.

TenerifeH10 Costa Adeje Palace****

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Code of Ethics

Our commitment to safety at work and equal opportunitiesAt H10 Hotels we promote equality of treat-ment and opportunities for all our employ-ees, taking care to ensure that the processes of recruitment and professional promotion are transparent and governed by criteria of objec-tivity and responsibility.

We strive to base all our recruitment and pro-motion processes on the merits, capacity, competence and professional qualifications of the candidates, conferring special value to their ethical values and corporate culture.

Under no circumstances will our employees be subject to contractual conditions or obligations that harm, limit or eliminate their legitimate la-bour rights.

The safety and hygiene of our working environ-ment is an absolute priority at H10 Hotels.

H10 Hotels guarantees all its workers a safe and healthy work environment, and undertakes to adopt all measures that can reasonably be carried out to minimise occupational hazards, as well as to comply with and respect all pre-ventive legal regulations, and to facilitate train-ing and individual security measures necessary to provide the best possible protection for life, health and physical and psychological integrity.

During working hours, the consumption of al-cohol or banned substances is prohibited for all our employees.

Our commitment to trust and confidentialityAll the information that H10 Hotels collects from its employees, customers and suppliers is legitimately obtained and is only used in the exercise of our corporate activity. The person-al data of our employees, professionals, cus-tomers and third parties, will always be sub-ject to strict and careful custody, and its use and treatment will always conform to the most stringent standards of protection imposed by current legislation.

Any type of use, appropriation, transfer or dis-closure of personal or confidential data that the employee, collaborator or manager of H10 Hotels may have had access to in the course of their work or their functions is prohibited if it has not been expressly authorised.

All our employees will take the utmost care to maintain the confidentiality of all private infor-mation that has been provided to them about the corporation itself, its partners, companies, customers, suppliers and other employees.

Likewise, any business secrets that may have been accessed for business reasons, whether belonging to H10 Hotels or to another collabo-rating or competing company, must be stored with the utmost respect and confidentiality by all our employees and collaborators.

Private or personal data cannot be treated in any case for a purpose other than that which, legally and contractually, was planned at the time of receipt.

All our managers and employees are respon-sible for using the tools and IT resources that have been provided to them by H10 Hotels in a diligent manner and must scrupulously com-ply with all the instructions they have received through the Code of Use of IT Tools.

MallorcaH10 Punta Negra Boutique Hotel****

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Code of Ethics

Our commitment to the privacy of individualsAt H10 Hotels we deeply respect the image and communications of all our customers, em-ployees and suppliers.

No person may access, without being ex-pressly authorised to do so, any type of data, personal or private, that is stored or filed in the company's IT systems.

The private communications, documents, files and personal belongings of our customers are untouchable and we will never tolerate in our premises the non-consensual use of instru-ments or devices to listen, record or intercept images or conversations of others.

Photographs or audio-visual recordings of customers or other employees that have been taken in the private or public areas of our es-tablishments may not be subject to any type of disclosure or transfer to third parties without the previous and express authorisation of the persons in question.

Our commitment to respect for industrial and intellectual property rightsPart of our business philosophy rests on the scrupulous respect for the protection of intel-lectual and industrial property rights, our own and others.

In our hotels no public performance or artistic interpretation is allowed that damages the in-tellectual property rights of others; nor the sale of products that infringe the industrial or intel-lectual property rights of third parties.

Nor is the use of any type of program or com-puter application permitted that was not creat-ed or developed by H10 Hotels unless it comes with the corresponding licenses of use.

All our services should always be advertised under our own trademarks, avoiding any kind of plagiarism or undue confusion with other distinctive brands of external services, as well as the non-consensual use of registered pho-tographic or audiovisual materials, without the required authorisation of the right holders.

FuerteventuraH10 Sentido Playa Esmeralda****

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Code of Ethics

Our commitment to the market and consumersH10 Hotels will always provide truthful and complete information in the advertising of our services as well as in relations with custom-ers and suppliers, to prevent them from taking wrong or harmful decisions due to our fault.

We believe in free competition. However, at H10 Hotels we are committed to competing in the market with professionalism and loyalty, re-fraining from carrying out any kind of denigrat-ing practice or misleading advertising against our competitors and customers.

We guarantee our customers a scrupulous re-spect for the law, both national and region-al legislation, regulating consumer and user rights and their protection.

Customers’ and suppliers’ credit cards and payment instruments will always be used in the way they have been designed, always ensuring their interests and avoiding any type of use that may be harmful to them. Likewise, the integrity of systems of measurement of the consump-tion of vending machines and supplies will be monitored.

Our commitment to honesty in business and public serviceH10 Hotels strongly rejects any form of corrup-tion in private business and in our relations with public administration.

All our employees, managers and collabora-tors are prohibited from soliciting, accepting or receiving gifts, commissions or any kind of economic advantage or benefit to influence or favour a customer or supplier in a particu-lar business, in the procurement of supplies of goods or services or in maintaining pre-exist-ing business relationships.

We do not need incentives to do our work with professional care, as expected of us by all our customers and suppliers.

Anyone who represents H10 Hotels in its re-lations with public administration will conduct themselves with the utmost courtesy and re-spect toward public officials and the interven-ing authorities and will refrain from offering or giving them any type of gift, commission, ad-vantage or economic benefit aimed at influenc-ing their behaviour or to obtain or retain a pub-lic contract or a particular deal.

H10 Hotels strongly rejects corruption in all its forms and compels all its employees, manag-ers and collaborators to report to the compe-tent authorities any kind of bribery or conduct intended to influence a public official or authori-ty to carry out, not carry out or delay a decision within the scope of its functions or to dictate some kind of resolution capable of generating economic benefits regarding which it may have information during the provision of its business services or the carrying out of its professional or commercial activities.

LanzaroteH10 Suites Lanzarote Gardens****

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Code of Ethics

Our commitment to the fulfillment of our legal, fiscal and social security obligationsH10 Hotels formally undertakes to publish all corporate, accounting and financial informa-tion required by the applicable commercial law, with full transparency, in a way that faithfully re-flects its assets, economic and financial situa-tion in accordance with legally enforceable and generally accepted accounting practices.

All companies that make up H10 Hotels and all its employees, professionals, managers and collaborators, will refrain from providing inac-curate or incorrect information to the compa-ny's creditors or from performing any act of disposition that may cause them unfair preju-dice or impede the effective exercise of their legal actions, avoiding, hindering or preventing the fulfillment of our payment obligations or the fulfillment of our social responsibilities.

The upholding of public expenses and social security payments is the responsibility of every-one and at H10 Hotels we want to make public our commitment, accepting our obligation to contribute to it through our conscientious tax and social practices.

Bookkeeping and presenting annual accounts for all companies will always be carried out through scrupulous compliance with the pro-visions of applicable commercial law, avoiding any kind of falsehood, omission, simulation or irregularity.

Likewise, all legal obligations related to the preservation of business, commercial and ac-counting documentation of the companies shall be meticulously observed.

Employees, managers and professionals in-volved in the preparation, processing and management of the tax returns of the compa-nies that make up H10 Hotels, will avoid the commission of any omission, falsification or ir-regularity that could lead to fraud towards the

Treasury of the Spanish government or that of the European Union.

Likewise, all employees, managers and profes-sionals involved in the management of payroll and social security of the companies that make up H10 Hotels, must prevent any type of irreg-ularity that could lead to fraud toward Social Security.

At H10 Hotels we make the most firm commit-ment to collaborate with all the agencies and authorities responsible for the administrative supervision and tax, labour and social security inspection of our companies.

Our commitment to fighting money laundering and terrorist financingAt H10 Hotels we are fully committed to fight-ing money laundering and terrorist financing.

All managers and employees who are author-ised by the company to make and receive pay-ments or bank transfers in the normal exercise of their duties are obliged to strictly comply with the instructions received in order to avoid any negligence in the strict compliance with legal regulations against money laundering and the prevention of terrorist financing.

BarcelonaH10 Urquinaona Plaza****

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Code of Ethics

Our commitment to preserve natural resources and the environmentAt H10 Hotels we are moving towards the sus-tainable management of our business activity, applying a policy of conservation and improve-ment of the cultural heritage and economic and social development of the destination via the effective management of all our resources.

The implementation of our Responsible Tourism System provide us with, among other things, a Best Environmental Practices programme that guarantees the conservation of the area and fosters awareness among collaborators, sup-pliers and customers.

We regard the following commitments as essentialforthispurpose:

• Implement programmes that reduce solid and hazardous waste creation.

• Implement training programmes aimed at environmental education.

• Engage the active participation of our cus-tomers and suppliers.

• Ensure compliance with current environmen-tal, national, regional and local legislation.

• Encourage local employment.• Within purchasing processes, prioritise the

acquisition of locally sourced products and services.

• Participate with local institutions in environ-ment-related activities.

• Continuously improve all our processes, es-pecially those of a socio-cultural, economic and environmental nature.

As a result, we have been nationally and in-ternationally accredited for our contribution to ecosystem protection and sustainabili-ty (Biosphere Responsible Tourism, Travelife, Mesoamerican Reef Tourism Initiative, Commitment to Tourism Quality) and we must continue to work on maintaining and improving our results in this area.

All employees, managers and professionals involved in the management of our hotels are responsible for the reasonable use of energy, limited consumption of supplies, reduction of waste creation and the need to promote recy-cling and maximise energy efficiency.

When remodelling or refurbishing our hotels, we are committed to maximum compliance with urban planning regulations and the secu-rity and monitoring measures required for the use and storage of any type of potentially haz-ardous substance or products.

All employees and managers of H10 Hotels must comply strictly with the environmental legislation applicable to our activity and re-frain from performing or authorising any type of dumping or depositing of waste in the soil, subsoil, sea or inland waters.

Riviera Maya (Mexico)Ocean Riviera Paradise*****

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Code of Ethics

Our commitment to the health of our customersAt H10 Hotels we are committed to complying with legal requirements and the most demand-ing quality systems, always focusing on the continuous improvement of all our processes and the satisfaction of our customers.

We have developed our own quality and envi-ronmental system, the H10 Quality Excellence Management System, which pursues the sat-isfaction and safety of our customers and is committed to sustainable development. We have been accredited nationally and inter-nationally for the quality of our services (ISO 9001: 2008, K Quality Tourism) and we must continue to work on maintaining and improving our results in this area.

All food and drinks served in our premises are subjected to the most stringent quality controls and our employees are expressly obliged to ensure strict compliance with all legal and reg-ulatory requirements governing composition, quality and expiration conditions which must be met by products to ensure their suitability for consumption.

H10 Hotels prohibits any type of food adulter-ation with additives, preservatives or unauthor-ised agents.

The handling of food destined for the con-sumption of our customers is carried out fol-lowing the strictest compliance with applicable hygiene standards, in order to avoid any risk of contamination by infectious agents.

Our group guarantees to all our customers the strictest compliance with legislation regulat-ing measures against tobacco and smoking in public spaces. Smoking is prohibited in our ho-tels, except in specifically designated areas.

The trafficking or illegal consumption of toxic drugs, narcotics or psychotropic substances will not be tolerated on our premises.

BarcelonaThe One Barcelona*****GL

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Code of Ethics

COMPLYINGWITHTHECODEOFCONDUCT

all persons who are members of H10 Hotels or who maintain any type of connection or rela-tionship with our business group are responsi-ble for complying with this Code. That is why it is necessary for all our employees, managers and collaborators to be aware, understand and comply with it accordingly.

If any person included in its scope of cover-age has any doubts as to whether a particu-lar conduct is prohibited by this Code, they should consult the person responsible for the respective area of activity, his/her superior or the Director of Regulatory Compliance before proceeding.

Likewise, all employees and managers of H10 Hotels undertake to communicate to the Director of Regulatory Compliance any viola-tion of the Code of Ethics regarding which they have full knowledge, through the Whistleblower Channel specially created for this purpose.

Customers, suppliers and external collabora-tors can do so through hotel management, cus-tomer service or the department responsible.

H10 Hotels ensures the utmost rigour and complete confidentiality in the treatment of complaints received and guarantees that in no case will any personal or corporate retaliation against the whistleblowers be tolerated.

EFFECTIVEDATE

This Code of Ethics has been approved by the governing bodies of all companies that make up H10 Hotels and has entered into force on July 20, 2017.

Failure to comply with its rules, principles and values will result in disciplinary sanctions and, where appropriate, dismissal or termination of contract, or appropriate civil or criminal legal actions for any liabilities the offender may have

incurred in light of the seriousness of their breach.

Notwithstanding this, compliance with this Code does not exclude the application of other measures, codes of conduct and prevention protocols implemented by H10 Hotels to pre-vent or avoid the risk of crimes being commit-ted within our corporation.

LisbonH10 Duque de Loulé Boutique Hotel****s

Tenerife

Lanzarote

Fuerteventura

La Palma

Gran Canaria

Mallorca

Costa del Sol

Costa Daurada

Riviera Maya

Punta Cana

Cuba

Barcelona

Madrid

Seville

Rome

London

Berlin

Lisbon

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