MVW SUPPLIER CODE OF CONDUCT GUIDELINES
Marriott Vacations Worldwide (“MVW”, “Company”, “We”, “Us” or “Our”) is committed to responsible businesspractices and operations, including engaging with suppliers that are dedicated to similar principles and holding
their own suppliers and subcontractors to the same standards and practices. Our suppliers play a vital role inupholding MVW’s reputation for excellence with owners, members, guests, associates, business partners,investors, contractors, and other important stakeholders. We want to do business with companies that shareour values and identify and build relationships with suppliers that follow all applicable laws as well as the spirit
and intent of our principles.
MVW’s Supplier Code of Conduct Guidelines (“Supplier Guidelines”) set forth the principles, standards, andguidelines that we expect our suppliers to uphold and that are applicable to all MVW officers, managers andassociates in MVW’s global operations. As an MVW supplier it is expected that you and your employees will
strive to stay within comparable standards of conduct and will respect the obligations of MVW associates toadhere to MVW policies and applicable standards.
MVW may take steps to assess a supplier’s adherence to these principles, standards and guidelines. Failure touphold these guidelines could jeopardize the business relationship.

HUMAN RIGHTS
We expect our suppliers to acknowledge and respect the principles contained in the United Nations’ Universal
Declaration of Human Rights and related international covenants. We expect our suppliers to match ourcommitment to conduct business in all locations in a manner consistent with these principles and to protect
human rights within the conduct of their business.
We expect our suppliers to be engaged in responsible workplace practices and to conduct their business in amanner that is free from complicity in human rights abuses in all forms. We expect our suppliers to embody acommitment to ethical business practices and good corporate citizenship.

ENVIRONMENTAL IMPACT & SUSTAINABILITY
We expect our suppliers to take responsibility for the environmental impact of their business operations. We
expect our suppliers to support the United Nations’ Sustainable Development Goals (SDGs) throughenvironmental and social initiatives.

INCLUSION AND DIVERSITY
We expect our suppliers to promote and embrace diversity and seek to provide an inclusive environment in all
aspects of their business operations. We expect our suppliers to not tolerate discrimination in the workplace.
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PROTECTION OF THE RIGHTS OF CHILDREN
MVW condemns all forms of exploitation of children. We expect our suppliers to only recruit, employ and dobusiness with individuals who are of lawful age to work in the applicable geographical location. Our suppliers
should support laws enacted to prevent and punish the crime of exploitation of children.

FORCED LABOR & HUMAN TRAFFICKING
We expect our suppliers to prohibit the use of forced, bonded, or compulsory labor. We expect our suppliers tocommit to ensuring that forced labor in all its forms are prevented from occurring as a result of businessactivities. 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 expect our suppliers to fully support the following principles from the Sustainable Hospitality Alliance’s
Principles on Forced Labor:•••

Every worker should have freedom of movement;
No worker should pay for a job; andNo worker should be indebted or coerced to work.

We expect our suppliers to be committed to being vigilant in identifying, reporting, and assisting in preventing
human trafficking in all forms. We expect our suppliers to have a comprehensive human trafficking awarenessprogram, which includes mandatory company-wide associate training, in an effort to help employees identify
possible situations of human trafficking. The human trafficking awareness program should align with allapplicable jurisdictional requirements, as well as guidance and recommendations issued by local organizations
and law enforcement agencies.

FAIR TREATMENT
We expect our suppliers to not tolerate any form of disparate treatment in the workplace.
••Our suppliers should treat all of their employees with dignity and respect and should not subject themto any form of unethical treatment, threats of violence, or other forms of physical, mental, or sexual
harassment.
Our suppliers should clearly define disciplinary policies and procedures in support of these requirements
and communicate them to all of their employees.

HEALTH AND SAFETY
We expect our suppliers to provide their employees with a safe and healthy working environment.
©2022 MVW. All Rights Reserved. MVW CONFIDENTIAL AND PROPRIETARY INFORMATION. The contents of this material are confidential and proprietary to MVW and may not be reproduced, disclosed, distributed, or usedwithout the express permission of an authorized representative of MVW. Any other use is expressly prohibited.

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Suppliers should strive to ensure their business operations do not impact basic human needs, such asaccess to food, water, sanitation, or healthcare in local communities.
Suppliers’ employees should have the right to refuse and report unsafe or unhealthy working conditions
regardless of role, title or responsibility.
Suppliers’ employees should be trained on the appropriate occupational health and safety policies andprocedures, including emergency evacuation procedures, prior to employment and then on a regularbasis in the primary language(s) of their workers. Workers should be provided appropriate protective
equipment and instructed on appropriate use.

ETHICAL BUSINESS CONDUCT
We expect our suppliers to conduct business with honesty and integrity and in full compliance with applicablelaws. Our suppliers’ policies should establish clear ethical standards and guidelines for how they conductbusiness and establish accountability. All of our suppliers’ employees should be required to obey the law andcomply with specific standards relating to legal obligations, ethics, and business conduct. Our suppliers shouldhave clear accountability mechanisms in place to monitor and report on compliance with those directives.

GRIEVANCE MECHANISMS
To report questionable behavior or a possible violation of these Supplier Guidelines, suppliers are encouraged towork with their primary MVW business contact in resolving their concern. If that is not possible or appropriate,please contact MVW through any of the following methods:• Mail: Marriott Vacations Worldwide
Attention: Internal Audit7812 Palm Parkway
Orlando, FL 32836• Email: business.ethics@mvwc.com• Tel:+1 407-206-6375

AUDITING AND COMPLIANCE
Our suppliers should ensure that adequate and effective policies, procedures, audits, systems and training are inplace to ensure ongoing compliance with these Supplier Guidelines. We reserve the right to request from oursuppliers information about the management of relevant issues outlined in the Supplier Guidelines.
MVW may request to verify a supplier’s compliance with these Supplier Guidelines through internal and external
assessment mechanisms, including on-site independent third-party audits. A supplier’s non-compliance and/orfailure to take recommended corrective actions may negatively impact, or result in termination of, MVW’s
ongoing business relationship with the supplier.
©2022 MVW. All Rights Reserved. MVW CONFIDENTIAL AND PROPRIETARY INFORMATION. The contents of this material are confidential and proprietary to MVW and may not be reproduced, disclosed, distributed, or usedwithout the express permission of an authorized representative of MVW. Any other use is expressly prohibited.

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We may request that suppliers disclose information that may pertain to geographical location of facilities thatproduce any item supplied to MVW.
Management of these Supplier Guidelines is the responsibility of MVW’s Corporate Procurement Team, which isa participating member of the MVW Environmental, Social and Governance (ESG) Task Force that manages
MVW’s interaction with the environment, our impact on society, and how our company is governed. Ultimate
oversight for the ESG Task Force resides with our Board of Directors and our Executive Committee.

©2022 MVW. All Rights Reserved. MVW CONFIDENTIAL AND PROPRIETARY INFORMATION. The contents of this material are confidential and proprietary to MVW and may not be reproduced, disclosed, distributed, or usedwithout the express permission of an authorized representative of MVW. Any other use is expressly prohibited.

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