What is the IHG Confidential Reporting Hotline and what concerns can I raise?

This is an independent, confidential channel via the telephone or internet which can be used by our colleagues, including those working in franchise hotels and any person with a relationship to IHG including our suppliers and workers in our supply chain to speak up and report concerns about breaches of our Code of Conduct such as:

1. human rights and modern slavery
2. human trafficking
3. discrimination or harassment
4. dangers to health & safety or the environment
5. accounting and auditing matters
6. bribery or conflict of interest
7. insider trading
8. competition or antitrust violations
9. falsifying records
10. fraud or theft
11. facilitation of tax evasion

IHG’s Code of Conduct sets out the principles we must all work by at IHG, wherever we are in the world. The principles, spirit and purpose of the Code are relevant to all of IHG.

For other matters outside the Code, there may be better ways to raise questions and concerns, for example:

• To provide feedback on hotel stay and reservation experiences; please contact IHG customer care.
• To provide feedback or for questions on human resources policies or procedures such as questions on pay, benefits, holiday entitlements etc; please raise these directly with your line manager, supervisor, your local Human Resources representatives or to appropriate local management.

How can I report my concerns? And what happens after I contact IHG’s Confidential Reporting Hotline?

We hope that you will feel able to report your concerns directly to your line manager, supervisor, your local Human Resources representatives or to appropriate local management in the first instance as this is often the most effective way of obtaining a response.

However, for certain matters, we recognise that it may not always be appropriate to do this. In these instances, a confidential report can be filed through the IHG Confidential Reporting Hotline.

1. You can submit your report via the telephone or internet form in your local language and translators will translate your report into English.
2. Please provide detailed information about your concern (who, when, how, what and why) and include supporting evidence where available.
3. Once you submit a concern, whether through the website or by phone, you will be given a personalized report key and password which will allow you to return to your report again at any time, either online or by telephone. It is important that you regularly return to your report to answer questions or add further information that will help resolve open issues or monitor the progress of your inquiries and ask questions if you wish.
4. IHG will acknowledge receipt of your report within 5 working days. If your initial report does not include sufficient information/evidence, you will be asked to provide more information via the portal.
5. IHG commits to undertaking enquiries for all reports received. You will be notified when the enquiries into your report have been completed. However, for legal reasons, it may not always be possible to inform you of the outcome of our enquiries.

We aim to investigate and resolve cases in a timely manner; however the duration of the investigation and resolution might vary based on the complexity of the case.

If these steps do not deliver a satisfactory outcome, contact the Head of Risk and Assurance.

Are reports to the IHG confidential Reporting Hotline secure and confidential?

Yes, any report you make will be kept confidential to the fullest extent possible consistent with law and good business practices. IHG uses NAVEX’s EthicsPoint case management application hosted on NAVEX’s secure server which is not part of IHG’s website or intranet. EthicsPoint does not capture the Internet Protocol (IP) address or the phone number of the reporter.

Can I file a report anonymously?

Yes. You can use the online or phone reporting processes to report anonymously if you wish (where allowed by law). To remain anonymous, please ensure not to include any information in your report that might identify yourself.

It may make it difficult to conduct enquiries if you do not provide enough details about the issues reported. That is why it is particularly important for anonymous reporters to regularly log in (using the unique report key and password provided after you have logged your concerns) and check your reports as this will be the only channel available for IHG to ask you for additional details.

If you feel comfortable sharing information about your identity when reporting your concern, we will take steps to keep this information confidential to the extent possible during the investigation. Please note the team involved in the investigation will see your details. Being able to identify the reporter can support the investigation and ensure the reporter’s concerns are addressed in an effective and efficient manner.

How does IHG manage my concerns?

IHG has a group of dedicated personnel within the IHG Internal Audit Team who are responsible for reviewing all reports filed. EthicsPoint informs these personnel every time a report is filed, they will review it and, when appropriate, will launch internal inquiries to understand the context of your concern. Should one of the dedicated personnel be mentioned in your report, EthicsPoint will ensure that this person cannot access the report.

Are translation services provided?

For online reports, you may file a report online using your local language and translators will translate your report into English.

Telephone reports can be made using the toll-free number of your country. This number can be found on the IHG ethical concerns poster displayed in your hotel or office or online at ihgethics.com.

For telephone reports, you must say the name of your preferred language in English when the operator answers the phone. You will then be passed to a translator who will speak to you in your preferred language.

What is IHG’s stance on retaliation?

IHG does not permit retaliation against employees making good faith reports of either suspected breaches of the Code of Conduct or suspected violations of the law even if it may result in a loss of business to IHG. If you believe you have faced retaliation of any kind, please report it through the Confidential Reporting Hotline so that IHG can undertake inquiries and take appropriate action.