SLLN Employee Handbook

ELIGIBILITY FOR BIRTH PARENTS

To be eligible for Shared Parental Leave (SPL) and Statutory Shared Parental Pay (ShPP),
both parents must:

• share responsibility for the child at birth

• meet work and pay criteria - these are different depending on which parent wants
to use the shared parental leave and pay

You’re not eligible if you started sharing responsibility for the child after it was born.

You can check if you can get leave and pay, including SPL and ShPP.
The eligibility criteria are different if you’re adoptive parents.

IF BOTH PARENTS WANT TO SHARE THE SPL AND ShPP

You and your partner must:

• have been employed continuously by the your employer for at least 26 weeks
by the end of the 15th week before the due date

• stay with the same employer while you take SPL
• be ‘employees’ (not ‘workers’)
• each earn on average at least £118 a week
If either of you is a ‘worker’, you can share ShPP but not SPL. If either of you earns
less than £118 a week, you can share SPL but not ShPP.

IF THE MOTHER’S PARTNER WANTS TO TAKE SPL AND ShPP

The mother must:

• have been working for at least 26 weeks (they do not need to be in a row)
during the 66 weeks before the week the baby’s due

• have earned at least £390 in total across any 13 of the 66 weeks

The mother’s partner must:

• have been employed continuously by the same employer for at least
26 weeks by the end of the 15th week before the due date

• stay with the same employer while they take SPL
• be an ‘employee’ (not a ‘worker’)
• earn on average at least £118 a week
If the mother’s partner is a ‘worker’, they can get ShPP but not SPL.

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If the mother’s partner earns less than £118 a week, they can get SPL but not ShPP.

IF THE MOTHER WANTS TO TAKE SPL AND ShPP

The mother’s partner must:

• have been working for at least 26 weeks (they do not need to be in a row)
during the 66 weeks before the week the baby’s due

• have earned at least £390 in total in 13 of the 66 weeks (add up the highest
paying weeks, they do not need to be in a row)

The mother must:

• have been employed continuously by the same employer for at least 26 weeks
by the end of the 15th week before the due date

• stay with the same employer while they take SPL
• be an ‘employee’ (not a ‘worker’)
• earn on average at least £118 a week
If the mother is a ‘worker’, she can get ShPP but not SPL.
If the mother earns less than £118 a week, she can get SPL but not ShPP.

ELIGIBILITY FOR ADOPTERS

To be eligible for Shared Parental Leave (SPL) and Statutory
Shared Parental Pay (ShPP), both adoptive parents must:

• share responsibility for the child
• meet the work and earnings criteria - these are different depending on

which one of you wants to use the shared parental leave and pay
The eligibility criteria are different if you’re birth parents.

IF BOTH PARENTS WANT TO SHARE THE SPL and ShPP

You and your partner must:

• have been employed continuously by the same employer for at least
26 weeks by the end of the week you were matched with the child

• stay with the same employer while you take SPL
• be ‘employees’ (not ‘workers’)

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• each earn on average at least £118 a week
If either of you is a ‘worker’, you can share ShPP but not SPL.
If either of you earns less than £118 a week, you can share SPL but not ShPP.

IF ONLY ONE OF THE PARENTS WANTS TO TAKE THE SPL AND ShPP

The parent who wants to take the leave and pay must:

• have been employed continuously by the same employer for at least
26 weeks by the end of the week you were matched with the child

• have stayed with the same employer while they take SPL
• be an ‘employee’ (not a ‘worker’)
• earn on average at least £118 each a week

The other parent must:

• have been working for at least 26 weeks (they do not need to be in a row)
during the 66 weeks before the week the child was placed with you

• have earned at least £390 in total in 13 of the 66 weeks (add up the highest
paying weeks, they do not need to be in a row)

If the parent who wants to take the leave and pay is a ‘worker’, they can get ShPP
but not SPL. If they earn less than £118 a week, they can get SPL but not ShPP.

WHEN YOU CAN START

You can only start Shared Parental Leave (SPL) or Shared Parental Pay (ShPP) once
the child has been born or placed for adoption.

FOR SPL TO START

The mother (or the person getting adoption leave) must either:

• return to work, which ends any maternity or adoption leave
• give their employer ‘binding notice’ of the date when they plan to end

their leave (you cannot normally change the date you give in binding notice)

You can start SPL while your partner is still on maternity or adoption leave
as long as they’ve given binding notice to end it.
You can give binding notice and say when you plan to take your SPL at
the same time.

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If the mother or adopter does not get maternity or adoption leave
The mother or adopter must end any maternity pay, adoption pay or Maternity
Allowance so that they or their partner can get SPL.

FOR ShPP TO START

The mother (or the person getting adoption pay) must give their employer
binding notice of the date when they plan to end any maternity or adoption pay.
If they get Maternity Allowance, they must give notice to Jobcentre Plus instead.
They cannot restart maternity pay, Maternity Allowance or adoption pay
once it’s ended.

You can start ShPP while your partner is still on maternity pay, adoption pay
or Maternity Allowance as long as they’ve given binding notice to end it.
You can give binding notice and say when you plan to take your ShPP at
the same time.

COMPULSORY LEAVE

A mother cannot return to work before the end of the compulsory 2 weeks of
maternity leave following the birth (4 weeks if she works in a factory).
If you’re adopting, the person claiming adoption pay must take at least 2 weeks of
adoption leave.

CANCELLING THE DECISION TO END MATERNITY OR ADOPTION LEAVE

The mother or adopter may be able to change their decision to end maternity
or adoption leave early if both:

• the planned end date has not passed
• they have not already returned to work

One of the following must also apply:

• you find out during the 8-week notice period that neither of you is eligible for SPL
or ShPP

• the mother or adopter’s partner has died
• the mother tells her employer less than 6 weeks after the birth (and she gave notice

before the birth)

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WHAT YOU’LL GET

ShPP is paid at the rate of £148.68 a week or 90% of your average weekly earnings,
whichever is lower.

This is the same as Statutory Maternity Pay (SMP) except that during the first 6 weeks
SMP is paid at 90% of whatever you earn (with no maximum).
Example: A woman decides to start her maternity leave 4 weeks before the due
date and gives notice that she’ll start SPL from 10 weeks after the birth (taking a total
of 14 weeks maternity leave). She normally earns £200 a week.

HOW MUCH PAY YOU’LL GET

ShPP is paid at the rate of £148.68 a week or 90% of your average weekly earnings,
whichever is lower.

This is the same as Statutory Maternity Pay (SMP) except that during the first 6 weeks
SMP is paid at 90% of whatever you earn (with no maximum).
Example: A woman decides to start her maternity leave 4 weeks before the due date
and gives notice that she’ll start SPL from 10 weeks after the birth (taking a total of
14 weeks maternity leave). She normally earns £200 a week.

She’s paid £180 (90% of her average weekly earnings) as SMP for the first 6 weeks of
maternity leave, then £148.68 a week for the next 8 weeks. Once she goes onto SPL,
she’s still paid £148.68 a week.

APPLYING FOR LEAVE AND PAY

To get Shared Parental Leave (SPL) or Shared Parental Pay (ShPP) you must:

• follow the rules for starting SPL and ShPP
• give your employer at least 8 weeks’ written notice of your leave dates

You can do both at the same time using forms created by Acas.

Please request the forms from HR.

You can change your mind later about how much SPL or ShPP you plan to
take and when you want to take it. You must give notice of any changes at
least 8 weeks before the start of any leave.

You might not get SPL or ShPP if you do not include all the required information.

Your partner must apply to their own employer if they also want SPL or ShPP.

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GIVING MORE INFORMATION

Your employer can ask you for more information within 14 days of you
applying for SPL or ShPP. They can ask for:

• a copy of the birth certificate
• a declaration of the place and date of birth (if the birth has not been

registered yet)
• the name and address of your partner’s employer or a declaration that

your partner has no employer

If you’re adopting, your employer can ask for the:

• name and address of the adoption agency
• date you were matched with the child
• date the child will be start to live with you
• name and address of your partner’s employer or a declaration that your

partner has no employer

You must give this information within 14 days of being asked for it.

BOOKING BLOCKS OF LEAVE

You can book up to 3 separate blocks of Shared Parental Leave (SPL)
instead of taking it all in one go, even if you are not sharing the leave with
your partner.

If your partner is also eligible for SPL, you can take up to 3 blocks of leave each.

You can take leave at different times or both at the same time.

You must tell your employer about your plans for leave when you apply for SPL.
You can change these plans later but you must give your employer at least 8
weeks’ notice before you want to begin a block of leave.

SPLITTING BLOCKS OF LEAVE

If your employer agrees, you can split blocks into shorter periods of at
least a week.

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Example

A mother finishes her maternity leave at the end of October and takes the
rest of her leave as SPL. She shares it with her partner, who’s also eligible.
They each take the whole of November as their first blocks of SPL. The
partner then returns to work.

The mother also returns to work in December. She gives her employer
notice that she’ll go on leave again in February - this is her second block of SPL.
Her employer agrees to a work pattern of 2 weeks on, 2 weeks off during the block.

SHARED PARENTAL LEAVE IN TOUCH (SPLIT) DAYS

You and your partner can each work up to 20 days while you’re taking SPL. These
are called ‘Shared Parental Leave in touch’ (or SPLIT) days.

These days are in addition to the 10 ‘keeping in touch’ (or KIT) days available
to those on maternity or adoption leave.

KIT and SPLIT days are optional - both you and your employer must agree to them.

FLEXIBLE WORKING POLICY

The policy only applies to Shangri-La Hotel at the Shard employees on UK
terms and conditions and does not apply to agency workers or the self-
employed. No-one will be discriminated against or subjected to detriment for
taking leave in accordance with this policy.

We are committed to providing equality of opportunity in employment and
to developing work practices and policies that support work-life balance. We
recognise that, in addition to helping balance work and personal lives,
flexible working can raise staff morale, reduce absenteeism and improve our
use and retention of staff.

This Flexible Working Policy gives eligible employees an opportunity to
formally request a change to their working pattern in accordance with the
statutory procedure for such requests. It also allows any employee to make
such a request informally without following the statutory procedure.

Managers are encouraged to facilitate requests unless they cannot be
accommodated for business or operational reasons.

No-one who makes a request for flexible working will be subjected to any
detriment or lose any career development opportunities as a result.

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Any questions about this policy or related topics should be directed to your
HR Department

ELIGIBILITY

The Company is only required to consider, under the statutory entitlement,
one application to work flexibly, whether to care for a child or an adult, from
each employee in any 12 month period. Additional requests within a 12
month period may be considered at the discretion of the HR Director.

To be eligible to apply the employee must:

(a) be an employee;

(b) have worked for us continuously for 26 weeks at the date your request is
made;

(c) be making the request because of your caring responsibilities; and

(d) not have made a formal request to work flexibly during the last 12 months.

CARING RESPONSIBILITIES

You can make a flexible working request to care for a child if:

(a) the child is under 17 or is under 18 and in receipt of disability living
allowance;
(b) you are responsible for bringing up the child; and
(c) either:

(i) you are the mother, father, adopter, guardian, special guardian,
foster parent or private foster carer of the child; or
(ii) you are married to, or the civil partner or partner of, the child's
mother, father, adopter, guardian or foster parent. ; or
(iii) you or your spouse, partner or civil partner have a residence order
in force in your favour in respect of the child.

The right to request flexible working to care for a child does not extend to
grandparents, aunts, uncles, brothers or sisters or other relatives of children
unless they also fall into one of the other categories, for example where
relatives take over responsibility for a child’s upbringing from the natural
parents.

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You can make a flexible working request to care for an adult who is in need
of care if you are (or expect to be) the person who cares for that adult, and
they are either:

(a) your spouse, partner or civil partner; or

(b) your relative; or

(c) neither of the above, but living at the same address.

The right to request flexible working to care for an adult does not apply where
the adult is a distant relative who is not living with you, or a neighbour. An
application under this policy can only be made in order for an employee to
care for either a child or an adult who requires it and not for any other
purpose.

"Partner" means someone you live with as if you were married or in a civil
partnership.

"Relative" means your mother, father, adopter, guardian, special guardian,
parent-in-law, step-parent, son, step-son, son-in-law, daughter, step-
daughter, daughter-in-law, brother, step-brother, brother-in-law, sister, step-
sister, sister-in-law, uncle, aunt or grandparent, and includes adoptive
relationships and relationships of half blood.

Employees who do not meet the eligibility criteria for the formal procedure,
but who want to make changes to their working arrangements, may make
an informal request to the Director of Human Resources, who will consider the
request according to our business and operational requirements.

Any employee interested in flexible working is advised to request an informal
meeting with the Director of Human Resources to discuss their eligibility, the
different options and the effect of their proposed work pattern on colleagues
and service delivery before submitting a formal or informal request.

SCOPE OF FLEXIBILITY

An eligible employee may request:

(e) a change to the hours he/she works

(f) a change to the times when he/she is required to work

(g) to work from home (for all or part of the week)

Applications for a change in working pattern will not always require a

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significant alteration. For example, a parent may simply wish to start work half
an hour later to take his/her child to school and make up the time later in the
day.

Unless specifically agreed otherwise any change to the employee’s contract
will be on a permanent basis and the employee will have no automatic right
to return to his/her former working arrangements at a later date. It is therefore
very important that the employee considers very carefully what the effect of
a change in their current contractual terms will mean to them. Any reduction
in hours worked will result in a pro-rata reduction to salary.

THE PROCEDURE

Step 1

An eligible employee who wishes to apply for flexible working should submit a
written application to his/her Manager indicating the request is made under
the statutory right to request a flexible working pattern and also indicating if a
previous application has been made and if so to who and when;

This application should include:

(h) the reason for the request

(i) the relationship of the employee to the child or adult

(j) the proposed start date

(k) the changes requested

(l) the effect these changes may have on the business and how these
effects could be dealt with

Applications should be submitted well in advance of when the change is to
take effect wherever reasonably possible and ideally at least two months
before you wish the changes you are requesting to take effect.

We might be able to agree your proposal without the need for a meeting
(which is the next stage of the formal procedure). If that is the case, the
Director of Human Resources will write to you, confirming the decision and
explaining the changes that will be made to your contract of employment. If
your proposal cannot be accommodated, discussion between you and your
manager may result in an alternative working pattern that can assist you

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Step 2

Within 28 days of receiving the written application the Manager will arrange
to meet with the employee and a senior member of the HR department to
discuss the desired work pattern and how best it might be accommodated.
The meeting will also provide an opportunity to consider other alternative
working patterns should there be problems in accommodating the desired
work pattern outlined in the employee’s application.
Your Manager or HR may suggest starting new working arrangements under
an initial trial period to ensure that they meet your needs and those of the
Company.
The employee has the right to be accompanied to this meeting by a current
Company colleague or a qualified union representative. Your companion will
be entitled to speak during the meeting and confer privately with you, but
may not answer questions on your behalf.

Step 3

Following the meeting, your Manager will notify you of the decision in writing
within 14 days. If your request is accepted, or where we propose an
alternative to the arrangements you requested, your Manager will write to
you with details of the new working arrangements, details of any trial period,
an explanation of changes to your contract of employment and the date on
which they will commence. You will be asked to sign and return a copy of the
letter. This will be placed on your personnel file to confirm the variation to
your terms of employment or the Company may generate a new contract of
employment. There may also be some additional practical matters, such as
arrangements for handing over work, that your Manager will discuss with you.
Unless otherwise agreed (and subject to any agreed trial period) changes to
your terms of employment will be permanent. You will not be able to make
another formal request until 12 months after the date of your most recent
request.

If your Manager needs more time to make a decision, they will ask for your
agreement to delay the decision for up to a further 14 days. A request for an
extension is likely to benefit you. For example, your Manager may need more
time to investigate how your request can be accommodated or to consult
several members of staff.

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There will be circumstances where, due to business and operational
requirements, we are unable to agree to a request. In these circumstances,
your Manager will write to you:

(a) giving the business reason(s) for turning down your application;
(b) explaining why the business reasons apply in your case; and
(c) setting out the appeal procedure.

The eight business reasons for which we may reject your request are:
(a) the burden of additional costs;
(b) detrimental effect on ability to meet customer demand;
(c) inability to reorganise work among existing staff;
(d) inability to recruit additional staff;
(e) detrimental impact on quality;
(f) detrimental impact on performance;
(g) insufficiency of work during the periods that you propose to work;
and
(h) planned changes.

THE RIGHT OF APPEAL

If the employee is not satisfied with the outcome of the application he/she
has the right to appeal. An employee who wishes to appeal against a
decision must do so to the HR Director within 14 working days in writing and
dated, setting out the grounds of appeal.

The HR Director will arrange a meeting with the employee (at which the
employee may be accompanied by a current colleague or qualified union
representative) to hear the appeal without unreasonable delay, usually
within 14 days of receipt of the appeal. A Director or manager who is senior
to the employee who made the original decision will hear all appeals and will
notify the employee of their decision without reasonable delay, usually within
14 days of the appeal meeting. His/her decision is final.

FURTHER APPLICATIONS FOR FLEXIBLE WORKING

Once the employee has exhausted the procedure set out in this policy
he/she may not make any further application for flexible working for 12
months from the date of the previous application.

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INFORMAL APPLICATIONS

Employees who wish to make an informal request for flexible working may
make a request to their senior service manager, who will consider it
according to our business and operational requirements. It will help your
manager to consider your request if you:

(a) make your request in writing and confirm whether you wish any
change to your current working pattern to be temporary or
permanent;

(b) provide as much information as you can about your current and
desired working pattern, including working days, hours and start and
finish times, and give the date from which you want your desired
working pattern to start;
(c) think about what effect the changes to your working pattern will
have on the work that you do and on your colleagues, as well as on
our service delivery. If you have any suggestions about dealing with
any potentially negative effects, please include these in your written
application. Your manager can consider whether they are workable;
and give details of the demands of your caring responsibilities, if you
have any.

Your manager will advise you what steps will be taken to consider your
request, which may include inviting you to attend a meeting, before advising
you of the outcome of your request.

PARENTAL LEAVE POLICY

The law recognises and we respect that there will be occasions when
working parents wish to take time off work to care for or spend time with their
child or children.

This policy reflects the statutory right of employees with at least one year's
continuous service to take up to 18 weeks' unpaid parental leave in respect
of each child.

No-one will be subjected to a detriment for taking or seeking to take parental
leave in accordance with this policy.

The policy only applies to Shangri-La Hotel at the Shard employees on UK
terms and conditions and does not apply to agency workers or the self-

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employed. No-one will be discriminated against or subjected to detriment for
taking leave in accordance with this policy.

ENTITLEMENT TO PARENTAL LEAVE

Employees who fulfil the criteria set out below are entitled to take up to 18
weeks' parental leave in relation to each child for whom they are responsible.
The rules on how and when parental leave can be taken are set out in further
detail below.

Any parental leave that employees take in relation to a child while working
for another employer counts towards their 18-week entitlement. If you have
taken parental leave in relation to a child during previous or concurrent
employment, you should provide details to the Human Resources
Department.

To take a period of parental leave in relation to a child, you must:

a) have at least one year's continuous employment;
b) have or expect to have responsibility for the child; and
c) be taking the leave to spend time with or otherwise care for the child.

In relation to the above, you have responsibility for a child if you:

a) are the child's biological mother or father (whether or not you are living
with the child);

b) are the child's adoptive parent; or
c) otherwise have legal parental responsibility for the child. For example, if

you are the child's guardian.

TIMING OF PARENTAL LEAVE

You can only take parental leave:

a) before the child's fifth birthday; or
b) in the case of a child entitled to a disability living allowance, before the

child's 18th birthday; or
c) in the case of an adopted child, before the fifth anniversary of the

date of placement or, if sooner, the child's 18th birthday.

Unless the leave is to be taken in respect of a child entitled to a disability
living allowance, you:

a) can only take parental leave in blocks of a week's leave or a multiple
of a week's leave; and
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b) are only entitled to take four weeks' parental leave each year in
relation to each child. A year for this purpose begins on the date when
you became entitled to take parental leave in relation to the child in
question.

NOTIFICATION REQUIREMENTS

You must give the Human Resources Department notice of your intention to
take parental leave. It would be helpful if you can give this notice in writing.
The notice requirements are as follows:

• If you wish to take parental leave commencing immediately on the
birth of a child, you must give notice of this intention at least 21 days
before the start of the expected week of childbirth (EWC). The notice
must specify the EWC and the duration of the period of leave required.

• If you wish to take parental leave commencing immediately on the
adoption of a child, you should give notice of this intention at least 21
days before the start of the expected week of placement (EWP). If this
is not possible, you must give as much notice as you can. The notice
must specify the EWP and the duration of the period of leave required.

• In all other circumstances, you must give notice of your intention to
take parental leave at least 21 days before you intend the leave to
start. The notice must specify the dates on which the period of leave is
to begin and end.

If you wish to take a period of parental leave immediately after a period of
ordinary paternity leave, it would be helpful if you could give the Human
Resources Department notice of that intention at least 21 days before the
start of the EWC (or EWP, if applicable). If this is not possible, you should give
as much notice as you can. If you do not give notice at least seven days
before your period of ordinary paternity leave starts, we might not allow you
to take the period of parental leave requested. However, we shall consider
each case on its merits.

EVIDENTIAL REQUIREMENTS

Before you take a period of parental leave under this policy, you must
provide us with evidence of:

a) your responsibility or expected responsibility for the child;
b) the child's date of birth or date of adoption placement; and
c) if applicable, the child's entitlement to a disability living allowance.

For details of what evidence is required in your particular circumstances, or if
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you have difficulties obtaining the evidence, please contact the Human
Resources Department.

OUR RIGHT TO POSTPONE PARENTAL LEAVE

Where you give notice in the form set out above of your intention to take
parental leave on the birth or adoption of a child, we shall not postpone that
leave. We shall not postpone parental leave if, in the case of an adopted or
disabled child, the postponement would result in the leave being taken after
the child's 18th birthday.

However, in any other circumstances we might postpone a proposed period
of parental leave for up to six months where the leave as planned would
unduly disrupt our business. We might do so, for example, where:

a) you wish to take parental leave during a peak period;
b) a number of employees wish to take parental leave at the same time;
c) your work is of importance to a time-critical project; or
d) cover for your work cannot be found before the date on which your

parental leave is due to start.

If we decide to postpone your parental leave, we shall:

a) consult with you about the date to which the leave might be
postponed; and

b) no more than seven days after you gave notice of your intention to
take the leave, give you written notice stating the reason for the
postponement and the new beginning and end dates of the leave
which we will allow you to take.

You will not lose your parental leave entitlement if, because of our
postponement of such leave, the leave remains untaken on your child's fifth
birthday (or on the fifth anniversary of the child's adoption placement, if
applicable).

TERMS AND CONDITIONS DURING PARENTAL LEAVE

Parental leave under this policy is unpaid. Your contractual provisions relating
to pay and benefits are suspended during parental leave.

However, during parental leave you are entitled to benefit from any
contractual terms you have in relation to being given notice, redundancy
compensation and disciplinary and grievance procedures.

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During parental leave you will remain bound by your obligation of good faith
towards us, as well as any contractual terms relating to the giving of notice,
the disclosure of confidential information, the acceptance of gifts and
benefits, and your freedom to participate in another business (for example,
by working for a third party).

PENSIONS

If you are a member of the pension scheme, we shall not make contributions
during a period of unpaid parental leave.

RETURNING TO WORK

You are normally entitled to return to work following parental leave to the
same position you held before commencing leave. Your terms of
employment will be the same as they would have been had you not been
absent.

However, it might not be possible for us to allow you to return to the same job
where your period of parental leave has been longer than four weeks, or has
been combined with a period of additional maternity, paternity or adoption
leave. In such circumstances, we will offer you a suitable and appropriate
alternative position.

We will deal with any requests by employees to change their working
patterns (such as working part-time) after parental leave on a case-by-case
basis, in accordance with our Flexible Working Policy. We will try to
accommodate your wishes unless there is a justifiable reason for refusal,
bearing in mind the needs of our business. It is helpful if flexible working
requests are made as early as possible.

ABUSE OF THIS POLICY

Where an employee takes a period of parental leave under this policy for
purposes other than spending time with or otherwise caring for their child, this
will be dealt with as a disciplinary issue under our Disciplinary Procedure.

TIME OFF TO CARE FOR DEPENDANTS

The policy only applies to Shangri-La Hotel at the Shard employees on UK

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terms and conditions and does not apply to agency workers or the self-
employed. No-one will be discriminated against or subjected to detriment for
taking leave in accordance with this policy.

We recognise and respect that there will be occasions when you will need to
take time off work to deal with unexpected events involving one of your
dependents. This time off for dependants policy gives all employees the right
to take a reasonable amount of unpaid time off work to deal with certain
situations affecting their dependants.

Typical examples of unexpected events might include assisting a dependant
who has given birth, making arrangements for the care of a dependant who
is ill or injured, taking action required in consequence of the death of a
dependent, dealing with an unexpected incident involving your child during
school hours or dealing with disrupted child care arrangements. A
‘dependant’ is defined as a spouse, partner, child, parent or someone who
lives with you apart from a tenant, boarder or a live-in employee.

The amount of time off you can take is not defined by law; however, in most
circumstances it is expected that 1 or 2 days at any one time will be sufficient
to deal with most family emergencies and we will always consider each set
of circumstances on their facts. In the event that you need to take time off
for dependants, you must provide as much notice as possible to your
Manager. If you cannot give advance notice, you are expected to contact
your Manager at least 3 hours in advance of the start of your absence to
explain the reasons for it, and you must maintain telephone contact with your
Manager throughout the period you are off. For any period of time off for
dependants, you must complete the appropriate form available from your
Human Resources department.

The right to time off is intended to cover unforeseen matters only - if you know
in advance that you will need time off this must be taken as annual leave in
the usual way. Action is likely to be considered necessary if you knew in
advance that a problem might arise but didn't make alternative
arrangements for a dependant's care.

If you fail to notify us as is required under this policy, you may be subject to
disciplinary proceedings under our Disciplinary Procedure for taking
unauthorised time off.

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Where it is possible to do so in advance or when you return to work after
taking time off under this policy, we might ask you to provide evidence for
your reasons for taking the time off. Suspected abuse of this policy will be
dealt with as a disciplinary issue under our Disciplinary Procedure.

COMPASSIONATE LEAVE POLICY

The policy only applies to Shangri-La Hotel at the Shard employees on UK
terms and conditions and does not apply to agency workers or the self-
employed. No-one will be discriminated against or subjected to detriment for
taking leave in accordance with this policy.

The Company recognises that you may require time away from work in times
of bereavement. Compassionate leave is designed to help an employee
where they need to deal with necessary arrangements for or assist a close
relative who is seriously or critically ill.

The granting of compassionate leave upon the death of a close relative is at
the sole discretion of the Company and there is no automatic right to
payment in such circumstances. Any request for compassionate leave should
be made to the Human Resources department and the decision to grant
compassionate leave will be at the discretion of the Human Resources
Director.

As a guideline only, the Company may grant up to 5 days’ paid leave upon
the death of a spouse, civil or long term partner, parent, brother or sister, or
child. For more distant relationships e.g. grandparent or relations-by-marriage
(in-laws), the Company may grant 1 day’s paid leave for attendance at a
funeral. If a bereaved employee wishes to take additional time off, the
Company will give favourable consideration to any holiday request. In
certain circumstances we may ask you for evidence of bereavement before
granting compassionate leave.

Additionally, we will make every effort where possible to provide you with
additional unpaid leave where necessary, whether for family or non-family
members.

JURY SERVICE

This policy does not form part of any employee's contract of employment
and it may be amended at any time.

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We wish to enable employees to perform any public duties that they may be
committed to undertake and so will give them time off to do so where it does
not conflict with the operational needs of our business. We are not obliged to
grant employees paid leave for these purposes. The circumstances in which
we are prepared to do so are set out below.

In the event that you are summoned for jury service which requires you to be
absent from work, you must notify your Manager of your summons and
provide a copy of your summons if requested prior to taking jury service
leave. You must then give the Human Resources department a statement of
the service allowance paid and the days on which jury duty was performed
from the court. The Company will then pay the difference between the
money you receive from the court for your service allowance and your
regular pay. The number of working days for which jury service shall be paid is
limited to a maximum of 2 weeks in any calendar year.

Depending on the demands of our business we may request that you apply
to be excused from or defer your jury service.

DATA PROTECTION POLICY

Everyone has rights with regard to how their personal information is handled.
During the course of our activities we will collect, store and process personal
information about our staff, and we recognise the need to treat it in an
appropriate and lawful manner.

The types of information that we may be required to handle include details of
current, past and prospective employees, suppliers, customers, and others
that we communicate with. The information, which may be held on paper or
on a computer or other media, is subject to certain legal safeguards
specified in the General Data Protection Regulation, May 2018 (GDPR) and
other regulations. The Regulation imposes restrictions on how we may use
that information.

This policy does not form part of any employee's contract of employment
and it may be amended at any time. Any breach of this policy will be taken
seriously and may result in disciplinary action.

This policy has been approved by the management. It sets out our rules on
data protection and the legal conditions that must be satisfied in relation to
the obtaining, handling, processing, storage, transportation and destruction
of personal information.

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If you consider that the policy has not been followed in respect of personal
data about yourself or others you should raise the matter with your Manager
or the Data Protection Compliance Manager.

DEFINITION OF DATA PROTECTION TERMS

Data is information which is stored electronically, on a computer, or in certain
paper-based filing systems.

Data subjects for the purpose of this policy include all living individuals about
whom we hold personal data. A data subject need not be a UK national or
resident. All data subjects have legal rights in relation to their personal data.

Personal data means data relating to a living individual who can be
identified from that data (or from that data and other information in our
possession). Personal data can be factual (such as a name, address or date
of birth) or it can be an opinion (such as a performance appraisal).

Data controllers are the people who or organisations which determine the
purposes for which, and the manner in which, any personal data is
processed. They have a responsibility to establish practices and policies in line

with the Regulation. We are the data controller of all personal data used in
our business.

Data users include employees whose work involves using personal data. Data
users have a duty to protect the information they handle by following our
data protection and security policies at all times.

Data processors include any person who processes personal data on behalf
of a data controller. Employees of data controllers are excluded from this
definition but it could include suppliers which handle personal data on our
behalf.

Processing is any activity that involves use of the data. It includes obtaining,
recording or holding the data, or carrying out any operation or set of
operations on the data including organising, amending, retrieving, using,
disclosing, erasing or destroying it. Processing also includes transferring
personal data to third parties.

Sensitive personal data includes information about a person's racial or ethnic
origin, political opinions, religious or similar beliefs, trade union membership,
physical or mental health or condition or sexual life, or about the commission
of, or proceedings for, any offence committed or alleged to have been

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committed by that person, the disposal of such proceedings or the sentence
of any court in such proceedings. Sensitive personal data can only be
processed under strict conditions, and will usually require the express consent
of the person concerned.

DATA PROTECTION PRINCIPLES

Anyone processing personal data must comply with the eight enforceable
principles of good practice. These provide that personal data must be:

a) Processed fairly and lawfully.
b) Processed for limited purposes and in an appropriate way.
c) Adequate, relevant and not excessive for the purpose.
d) Accurate.
e) Not kept longer than necessary for the purpose.
f) Processed in line with data subjects' rights.
g) Secure.
h) Not transferred to people or organisations situated in countries without

adequate protection.
i) Fair and lawful processing.

The Regulation is intended not to prevent the processing of personal data,
but to ensure that it is done fairly and without adversely affecting the rights of
the data subject. The data subject must be told who the data controller is (in
this case Shangria-La Hotels PTE Limited), who the data controller's
representative is (in this case the Data Protection Compliance Manager), the
purpose for which the data is to be processed by us, and the identities of
anyone to whom the data may be disclosed or transferred.

For personal data to be processed lawfully, certain conditions have to be
met. These may include, among other things, requirements that the data
subject has consented to the processing, or that the processing is necessary
for the legitimate interest of the data controller or the party to whom the
data is disclosed. When sensitive personal data is being processed, more
than one condition must be met. In most cases the data subject's explicit
consent to the processing of such data will be required.

PROCESSING FOR LIMITED PURPOSES

Personal data may only be processed for the specific purposes notified to the
data subject when the data was first collected or for any other purposes
specifically permitted by the Regulation. This means that personal data must

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not be collected for one purpose and then used for another. If it becomes
necessary to change the purpose for which the data is processed, the data
subject must be informed of the new purpose before any processing occurs.

ADEQUATE, RELEVANT AND NON-EXCESSIVE PROCESSING
Personal data should only be collected to the extent that it is required for the
specific purpose notified to the data subject. Any data which is not
necessary for that purpose should not be collected in the first place.

ACCURATE DATA
Personal data must be accurate and kept up to date. Information which is
incorrect or misleading is not accurate and steps should therefore be taken
to check the accuracy of any personal data at the point of collection and at
regular intervals afterwards. Inaccurate or out-of-date data should be
destroyed.
TIMELY PROCESSING
Personal data should not be kept longer than is necessary for the purpose.
This means that data should be destroyed or erased from our systems when it
is no longer required. For guidance on how long certain data is likely to be
kept before being destroyed, contact the Data Protection Compliance
Manager.

PROCESSING IN LINE WITH DATA SUBJECT'S RIGHTS
Data must be processed in line with data subjects' rights. Data subjects have
a right to:
a) Request access to any data held about them by a data controller.
b) Prevent the processing of their data for direct-marketing purposes.
c) Ask to have inaccurate data amended.
d) Prevent processing that is likely to cause damage or distress to
themselves or anyone else.

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DATA SECURITY

We must ensure that appropriate security measures are taken against
unlawful or unauthorised processing of personal data, and against the
accidental loss of, or damage to, personal data. Data subjects may apply to
the courts for compensation if they have suffered damage from such a loss.

The Regulation requires us to put in place procedures and technologies to
maintain the security of all personal data from the point of collection to the
point of destruction. Personal data may only be transferred to a third-party
data processor if he agrees to comply with those procedures and policies, or
if he puts in place adequate measures himself.

Maintaining data security means guaranteeing the confidentiality, integrity
and availability of the personal data, defined as follows:

a) Confidentiality means that only people who are authorised to use the
data can access it.

b) Integrity means that personal data should be accurate and suitable for
the purpose for which it is processed.

c) Availability means that authorised users should be able to access the
data if they need it for authorised purposes. Personal data should
therefore be stored on our central computer system instead of
individual PCs.

Security procedures include:

a) Entry controls. Any stranger seen in entry-controlled areas should be
reported.

b) Secure lockable desks and cupboards. Desks and cupboards should
be kept locked if they hold confidential information of any kind.
(Personal information is always considered confidential.)

c) Methods of disposal. Paper documents should be shredded. Floppy
disks and CD-ROMs should be physically destroyed when they are no
longer required.

d) Equipment. Data users should ensure that individual monitors do not
show confidential information to passers-by and that they log off from
their PC when it is left unattended.

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DEALING WITH SUBJECT ACCESS REQUESTS
A formal request from a data subject for information that we hold about
them must be made in writing. A fee is payable by the data subject for
provision of this information. Any member of staff who receives a written
request should forward it to their service executive immediately.

PROVIDING INFORMATION OVER THE TELEPHONE
Any member of staff dealing with telephone enquiries should be careful
about disclosing any personal information held by us. In particular they
should:

a) Check the caller's identity to make sure that information is only given to
a person who is entitled to it.

b) Suggest that the caller put their request in writing if they are not sure
about the caller's identity and where their identity cannot be checked.

c) Refer to their service executive for assistance in difficult situations. No-
one should be bullied into disclosing personal information.

MONITORING AND REVIEW OF THE POLICY
This policy is reviewed every two years by our management board in
consultation with its advisors. Recommendations for any amendments are
reported to the Human Resources department and the management board.
We will continue to review the effectiveness of this policy to ensure it is
achieving its stated objectives.

ANTI-CORRUPTION AND BRIBERY POLICY

It is our policy to conduct all of our business in an honest and ethical manner.
We take a zero-tolerance approach to bribery and corruption and are
committed to acting professionally, fairly and with integrity in all our business
dealings and relationships wherever we operate and implementing and
enforcing effective systems to counter bribery.
We will uphold all laws relevant to countering bribery and corruption in all the

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jurisdictions in which we operate. However, we remain bound by the laws of
the UK, including the Bribery Act 2010, in respect of our conduct both at
home and abroad.

This policy forms part of your Contract of Employment. However, in
accordance with the Contract of Employment, the Company reserves the
right to amend this policy from time to time under its ongoing legal
obligations to do so. You will be notified of any amendments should they be
made.

The purpose of this policy is to:

• set out our responsibilities, and of those working for us, in
observing and upholding our position on bribery and corruption;
and

• provide information and guidance to those working for us on
how to recognise and deal with bribery and corruption issues.

Bribery and corruption are punishable for individuals by up to ten years'
imprisonment and if we are found to have taken part in corruption we could
face an unlimited fine, be excluded from tendering for public contracts and
face damage to our reputation. We therefore take our legal responsibilities
very seriously.

We have identified that the following are particular risks for our business and
ask that if in doubt, you report the matter immediately to the Company.

a. you become aware that a third party engages in, or has been
accused of engaging in, improper business practices in order to
secure you making a decision to use certain facilities or function
centres;

b. you learn that a third party has a reputation for paying bribes, or
requiring that bribes are paid to them, or has a reputation for
having a "special relationship" with foreign government officials in
order to secure business from you;

c. a third party insists on receiving a commission or fee payment
before committing to sign up to a contract with us, or, providing
preferred rates in order to pay you, or receive from you,
commission;

d. a third party requests payment in cash and/or refuses to sign a
formal commission or fee agreement for their services, or to
provide an invoice or receipt for a payment made by you;

e. a third party requests that you provide employment or some

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other advantage to a friend or relative;

f. you notice that we have been invoiced for a commission or fee
payment that appears large given the service stated to have
been provided;

g. a third party requests or requires the use of an agent,
intermediary, consultant, distributor or supplier that is not typically
used by or known to us;

h. you are offered an unusually generous gift or offered lavish
hospitality by a third party;

This list is no way exhaustive and is simply an illustration of the potential risks
that the General Manager has identified. If you are in doubt you should use
caution and notify the General Manager or the Group Company who will
advise you further.

In this policy, third party means any individual or organisation you come into
contact with during the course of your work for us, and includes actual and
potential General Managers, customers, suppliers, distributors, business
contacts, agents, advisers, and government and public bodies, including
their advisors, representatives and officials, politicians and political parties.

WHO IS COVERED BY THE POLICY?

This policy applies to all individuals working at all levels and grades, including
senior managers, officers, directors, employees (whether permanent, fixed-
term or temporary), consultants, contractors, trainees, seconded staff,
homeworkers, casual workers and agency staff, volunteers, interns, agents,
sponsors, or any other person associated with us, or any of our subsidiaries or
their employees, wherever located (collectively referred to as workers in this
policy).

WHAT IS BRIBERY?

A bribe is an inducement or reward offered, promised or provided in order to
gain any commercial, contractual, regulatory or personal advantage.

Examples;

Offering a bribe
You offer a potential General Manager tickets to a major sporting
event, but only if they agree to do business with us.

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This would be an offence as you are making the offer to gain a
commercial and contractual advantage. We may also be found to
have committed an offence because the offer has been made to
obtain business for us. It may also be an offence for the potential
General Manager to accept your offer.
Receiving a bribe
A supplier gives your nephew a job, but makes it clear that in return
they expect you to use your influence in our organisation to ensure
we continue to do business with them.
It is an offence for a supplier to make such an offer. It would be an
offence for you to accept the offer as you would be doing so to gain
a personal advantage.
Bribing a foreign official
You arrange for the business to pay an additional payment to a
foreign official to speed up an administrative process[, such as
clearing our goods through customs].
The offence of bribing a foreign public official has been committed
as soon as the offer is made. This is because it is made to gain a
business advantage for us. We may also be found to have
committed an offence.

GIFTS AND HOSPITALITY

This policy does not prohibit normal and appropriate hospitality (given and
received) to or from third parties.

The giving or receipt of gifts is not prohibited, if the following requirements are
met:

• it is not made with the intention of influencing a third party to
obtain or retain business or a business advantage, or to reward
the provision or retention of business or a business advantage,
or in explicit or implicit exchange for favours or benefits;

• it complies with local law;
• it is given in our name, not in your name;
• it does not include cash or a cash equivalent (such as gift

certificates or vouchers);

• it is appropriate in the circumstances. For example, in the UK it is
customary for small gifts to be given at Christmas time;

• taking into account the reason for the gift, it is of an
appropriate type and value and given at an appropriate time;

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• it is given openly, not secretly; and
• gifts should not be offered to, or accepted from, government

officials or representatives, or politicians or political parties,
without the prior approval of the General Manager set out more
fully in the terms of the Consultancy Agreement to which this
Bribery Policy is attached.
We appreciate that the practice of giving business gifts varies between
countries and regions and what may be normal and acceptable in one
region may not be in another. The test to be applied is whether in all the
circumstances the gift or hospitality is reasonable and justifiable. The intention
behind the gift should always be considered.

WHAT IS NOT ACCEPTABLE?

It is not acceptable for you (or someone on your behalf) to:

• give, promise to give, or offer, a payment, gift or hospitality with
the expectation or hope that a business advantage will be
received, or to reward a business advantage already given;

• give, promise to give, or offer, a payment, gift or hospitality to a
government official, agent or representative to "facilitate" or
expedite a routine procedure;

• accept payment from a third party that you know or suspect is
offered with the expectation that it will obtain a business
advantage for them;

• accept a gift or hospitality from a third party if you know or
suspect that it is offered or provided with an expectation that a
business advantage will be provided by us in return;

• threaten or retaliate against another worker who has refused to
commit a bribery offence or who has raised concerns under this
policy; or

• engage in any activity that might lead to a breach of this
policy.

•

FACILITATION PAYMENTS AND KICKBACKS

We do not make, and will not accept, facilitation payments or "kickbacks" of
any kind. Facilitation payments are typically small, unofficial payments made
to secure or expedite a routine government action by a government official.

They are not commonly paid in the UK, but are common in some other
jurisdictions in which we operate.

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If you are asked to make a payment on our behalf, you should always be
mindful of what the payment is for and whether the amount requested is
proportionate to the goods or services provided. You should always ask for a
receipt which details the reason for the payment. If you have any suspicions,
concerns or queries regarding a payment, you should raise these with the
General Manager.

Kickbacks are typically payments made in return for a business favour or
advantage. All workers must avoid any activity that might lead to, or suggest,
that a facilitation payment or kickback will be made or accepted by us.

DONATIONS

We do not make contributions to political parties. We only make charitable
donations that are legal and ethical under local laws and practices. No
donation must be offered or made without the prior approval of the General
Manager.

YOUR RESPONSIBILITIES

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of bribery and other forms of
corruption are the responsibility of all those working for us or under our
control. All workers are required to avoid any activity that might lead to, or
suggest, a breach of this policy.

You must notify the General Manager as soon as possible if you believe or
suspect that a conflict with this policy has occurred, or may occur in the
future. For example, if a client or potential client offers you something to gain
a business advantage with us, or indicates to you that a gift or payment is
required to secure their business. Further "red flags" that may indicate bribery
or corruption are set out in the below.

Any worker who breaches this policy will face action, which could result in
the termination for gross misconduct. We reserve our right to terminate our
contractual relationship with other workers if they breach this policy.

RECORD-KEEPING

We must keep financial records and have appropriate internal controls in

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place which will evidence the business reason for making payments to third
parties.

You must declare and keep a written record of all hospitality or gifts
accepted or offered, which may be payable by the Company and therefore
subject to the Company’s review.

You must ensure all expenses claims relating to hospitality, gifts or expenses
incurred to third parties are submitted in accordance with our expenses
policy and specifically record the reason for the expenditure.

All accounts, invoices, memoranda and other documents and records
relating to dealings with third parties, such as clients, suppliers and business
contacts, should be prepared and maintained with strict accuracy and
completeness. No accounts must be kept "off-book" to facilitate or conceal
improper payments.

HOW TO RAISE A CONCERN

You are encouraged to raise concerns about any issue or suspicion of
malpractice at the earliest possible stage. If you are unsure whether a
particular act constitutes bribery or corruption, or if you have any other
queries, these should be raised directly with the Company.

WHAT TO DO IF YOU ARE A VICTIM OF BRIBERY OR CORRUPTION

It is important that you tell the Company as soon as possible if you are offered
a bribe by a third party, are asked to make one, suspect that this may
happen in the future, or believe that you are a victim of another form of
unlawful activity.

PROTECTION

Workers who refuse to accept or offer a bribe, or those who raise concerns or
report another's wrongdoing, are sometimes worried about possible
repercussions. We aim to encourage openness and will support anyone who
raises genuine concerns in good faith under this policy, even if they turn out
to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment as a
result of refusing to take part in bribery or corruption, or because of reporting
in good faith their suspicion that an actual or potential bribery or other
corruption offence has taken place, or may take place in the future.

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Detrimental treatment includes dismissal, disciplinary action, threats or other
unfavourable treatment connected with raising a concern. If you believe
that you have suffered any such treatment, you should inform the
compliance manager immediately. If the matter is not remedied, and you
are an employee, you should raise it formally with the Company in writing.

TRAINING AND COMMUNICATION

You are required to familiarise yourself with the terms and affects of this Policy
and take all reasonable steps to ensure that you understand its contents and
effect on your ability to carry out your Contract of Employment to which this
Policy forms part of.

Our zero-tolerance approach to bribery and corruption must be
communicated to all suppliers, contractors and business partners at the
outset of any business relationship with them and as appropriate thereafter.

WHO IS RESPONSIBLE FOR THE POLICY?

The Company has overall responsibility for ensuring this policy complies with
its legal and ethical obligations, and that all those under our control comply
with it.

The General Manager has primary and day-to-day responsibility for
implementing this policy, and for monitoring its use and effectiveness and
dealing with any queries on its interpretation.

MONITORING AND REVIEW

The Company will monitor the effectiveness and review the implementation
of this policy, regularly considering its suitability, adequacy and effectiveness.
Any improvements identified will be made as soon as possible. Internal
control systems and procedures will be subject to regular audits to provide
assurance that they are effective in countering bribery and corruption.

All consultants are responsible for the success of this policy and should ensure
they use it to disclose any suspected danger or wrongdoing.

Employees are invited to comment on this policy and suggest ways in which it
might be improved. Comments, suggestions and queries should be
addressed to the General Manager.

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SCHEDULE - POTENTIAL RISK SCENARIOS: "RED FLAGS"

The following is a list of possible red flags that may arise during the course of
you working for us and which may raise concerns under various anti-bribery
and anti-corruption laws. The list is not intended to be exhaustive and is for
illustrative purposes only.

If you encounter any of these red flags while working for us, you must report
them promptly to the General Manager:

(a) you become aware that a third party engages in, or has been
accused of engaging in, improper business practices;

(b) you learn that a third party has a reputation for paying bribes, or
requiring that bribes are paid to them, or has a reputation for having a
"special relationship" with foreign government officials;

(c) a third party insists on receiving a commission or fee payment before
committing to sign up to a contract with us, or carrying out a
government function or process for us;

(d) a third party requests payment in cash and/or refuses to sign a formal
commission or fee agreement, or to provide an invoice or receipt for
a payment made;

(e) a third party requests that payment is made to a country or
geographic location different from where the third party resides or
conducts business;

(f) a third party requests an unexpected additional fee or commission to
"facilitate" a service;

(g) a third party demands lavish entertainment or gifts before
commencing or continuing contractual negotiations or provision of
services;

(h) a third party requests that a payment is made to "overlook" potential
legal violations;

(i) a third party requests that you provide employment or some other
advantage to a friend or relative;

(j) you receive an invoice from a third party that appears to be non-
standard or customised;

(k) a third party insists on the use of side letters or refuses to put terms
agreed in writing;

(l) you notice that we have been invoiced for a commission or fee
payment that appears large given the service stated to have been
provided;

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(m) a third party requests or requires the use of an agent, intermediary,
consultant, distributor or supplier that is not typically used by or known
to us;

(n) you are offered an unusually generous gift or offered lavish hospitality
by a third party;

CODE OF ETHICS

There is nothing of more value to Shangri-La than our reputation: with our
customers; with our employees; with our suppliers; with our owners (employer)
and with our communities.

As our company grows, our associates grow in their careers, and of necessity
new people join us from outside the company, it is imperative that we have a
common understanding of our expectations of behaviour, not just policies
and manuals.

The following stated elements of expected conduct and ethics cannot be all
encompassing. However, we expect our leadership to conduct themselves in
the spirit as well as the letter of these codes.

Failure to comply with the Shangri-La's Code of Conduct and Ethics may
result in disciplinary action which could include termination.

Underlying our expectations is the principle of integrity, in all of our behaviours
and in all of our relationships. We must personally and professionally always
be seen to be of high integrity.

WITH RESPECT TO OUR CUSTOMERS:

- We will give them fair value in the markets in which we serve.

- If we do not deliver what we had promised, we will not expect them to
pay for the services rendered, rather we will endeavor to motivate
them to give us the opportunity to redeem their confidence in Shangri-
La.

- We will not falsify records such that individuals may make
misrepresentation to their employers.

- We will look at each customer as a potential long term relationship for
our group and endeavor to earn their loyalty through quality service
and experiences.

WITH RESPECT TO OUR EMPLOYEES; OUR INTERNAL CUSTOMERS:

- We will respect them as individuals in the belief that all employees

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want to do a good job, and it is our responsibility as leaders to provide
the environment, processes and motivation to enable them to fulfil their
potential.

- We will provide staff facilities that are pleasing and of high quality, and
we should have "heart of the house" facilities/services for our
employees that are the envy of our industry.

- To the degree practical we will sincerely care for the total well being of
our employees and their families in our health and welfare programs.

- Honesty and candor will be practiced as we counsel our employees in
their performance and job/career expectations.

- We will offer career opportunities to qualified internal candidates and
employees of other Shangri-La hotels in preference to external
candidates.

- We will conduct ourselves as an equal opportunity employer and will
not discriminate on the basis of race, religion, sex, age, family status or
disability.

WITH RESPECT TO OUR SUPPLIERS:

- We will treat them with respect as business partners who play a vital
role in our mission of serving our internal and external customers.

- We will award business based upon quality and price without personal
favouritism.

- We will not solicit gifts under any circumstances nor personally accept
them of a value exceeding £50.00. Any gift that cannot be refused or
returned must be donated to a charitable cause and the transaction
documented to the Group Director of HR.

- We will endeavor to create long-term "win-win" relationships with
quality suppliers that allow us to enjoy excellent quality, price, and
supplier involvement in continuously improving our product, services
and profitability.

- We or our immediate family will not own, or have a vested interest in, or
be a Director of, any supplier of goods or services to Shangri-La, except
by way of shares in a public company. Any such relationship that exists
or may exist must have the express written approval of Shangri-La's
President & CEO.

WITH RESPECT TO OUR OWNERS (EMPLOYERS):

- All decisions must be made in their best long-term interest as investors
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and providers of employment.
- We will at all times be fair and honest, never taking unwarranted

personal advantage of our authority and privileges.
- We will recognize that as long as we accept our income from Shangri-

La we owe our employer our best effort and a fair commitment of time.
- We will respect the confidentiality and proprietorship of all information

learned as a result of our employment, and undertake not to share this
information outside our company during, or after employment with
Shangri-La.
- We will manage our hotels and our offices in accordance with the
policies and procedures as established by Shangri-La, and seek
approval for any deviation from them.

WITH RESPECT TO OUR COMMUNITIES:
- We will be good "corporate citizens" through leadership and our

involvement in civic and charitable organizations.
- We will take a leadership role in every community with respect to

environmental issues and programs.
- We will respect the cultural and religious traditions of the country in

which we operate and make every effort to educate ourselves in the
ways of its people.

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Part Two

Employee Relations

GUEST RELATIONS

We have a mission to delight our guests every time by creating engaging
experiences straight from our hearts. Whether you meet guests regularly, or
only occasionally, you are expected to project a genuine, professional and
respectful welcome. Smiling, making eye contact and offering a brief
greeting whenever you encounter a guest will help create an impression of
warmth and hospitality.
If a guest asks you to do something, you must act upon their request. Deal
with the request yourself if you can.
If you can’t help the guest personally, you must refer the request to someone
who can help; tell the guest who you will be referring the matter to and
explain that a colleague will be contacting them shortly.
If a guest asks you a question that you can’t answer, explain that you will find
out the answer and let them know - and do it!
Whilst we want you to be friendly towards our guests, you should always
remember that your relationship with our guests is a professional one. Whilst
you may get to know some of our regular guests well, you must not allow the
boundaries between professional respect and personal friendship to become
blurred. In particular, you are not allowed to accept any guest hospitality in
hotel bedrooms, bars and restaurants (on or off the property and regardless
of whether or not you are on duty). Any breach of this provision may be dealt
with by disciplinary action.
If a guest does offer you hospitality of any kind, you should politely explain
that our rules prevent you from accepting.

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COMMUNICATION

Clear communication is essential to the smooth running of any business.
Shangri-La uses a number of different means to share information with you.

NOTICE BOARDS

Please monitor the staff notice boards in back of house areas and in your
department on a regular basis. These notice boards will be used to
communicate information that may affect you at work. You must make
yourself aware of any notices or rules and regulations that may appear on
them from time to time.

COMMUNICATION MEETINGS

Please make every effort to attend your Department’s Communication
Meetings or Shift Briefings.

Your Manager will use these meetings to pass on information to you that will
enable you to do your job more effectively.

DIALOGUE MEETINGS

Dialogue meetings are chaired by the General Manager (or their designated
representative) and are attended by representatives selected by the
workforce to represent their views to management on a range of issues.

The Executive Committee uses these meetings to respond to matters raised
by staff representatives, to share information about the business, how it is
performing and matters that may affect it in the future. These meetings take
place at regular intervals and further information about the meeting can be
obtained from your Manager or Human Resources department. Your
Manager will be able to tell you the name of your department’s
representative and if you wish to table an issue at the Dialogue meeting, you
should ask your representative to raise it on your behalf.

GENERAL STAFF MEETINGS

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From time to time general staff meetings are held which we encourage you
to attend. You will find out about these meetings by notices and posters
displayed on staff notice boards or from your Manager. Again, you should
make every effort to attend these meetings so that you are kept fully
informed of what is happening in your place of work.

PERSONAL TELEPHONE CALLS AND
COMMUNICATION

COMPANY TELEPHONE SYSTEMS

Incoming personal telephone calls take us away from providing a service to
our guests. You are not allowed to use the Company’s telephone systems for
personal incoming or outgoing telephone calls or messages, other than in an
emergency. These calls should be made in your breaks, and you should not
leave your workplace to make calls without the permission of your Manager.
You must not use the guest telephones at any time. Failure to follow this
policy may lead to disciplinary proceedings.

MOBILE TELEPHONES
You are not allowed to use personal mobile telephones during working hours
or in guest areas. Please switch off your phone when going on duty. Use of
your mobile is only allowed in the Staff Concierge, Colleague Restaurant and
changing rooms during breaks. Please be considerate of our guest and
colleagues and refrain from using your mobile phone for calls in unauthorised
areas.

PERSONAL CORRESPONDENCE
Please do not have personal correspondence addressed to you at the
Company’s address or have correspondence relating to work addressed to
you at your home address.

The Company’s stationery must not be used for personal correspondence.
Failure to follow this policy may lead to disciplinary proceedings. The
Company is not liable if it opens any correspondence (personal or otherwise)

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that is directed to you at work.

FREQUENCY AND METHOD OF PAYMENT

PAYMENT METHOD
Wages and salaries are paid directly to your bank or building society account
on or around the last working day of each month. It is essential that you make
every effort to arrange a bank account into which your salary can be paid as
the Company cannot make such payments in cash. We may be able to help
you open a bank account if you do not already have one.

PAY QUERIES
If you have any questions concerning your wages, overtime or deductions,
please refer them to your Manager in the first instance.

INCOME TAX AND NATIONAL INSURANCE PAYMENTS
The Company is obliged by law to deduct Income Tax and National
Insurance contributions from your pay. You will receive a written pay advice
from us each month detailing the gross amount you have been paid, the
deductions we are obliged to make and the net amount being paid into
your account. Your Manager will give you your pay slip.

TAX OFFICE
If you need to correspond with HM Inspector of Taxes, the Human Resources
department can provide you with the address. You will need to tell them
where you work, giving your full name and National Insurance number, and
quote the Company’s tax reference number.
The Human Resources department can tell you the Company’s tax reference
number.

NATIONAL INSURANCE NUMBER
So that we can deduct National Insurance correctly, you will need to give us
your National Insurance number. If you do not have one, you will need to

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apply for one at the local Department of Social Security office.
The Human Resources department can give you the address and assist in
applying for a National Insurance number. When you have applied, you will
receive an acknowledgement form called a CF197. Please let the Human
Resources department have a copy of this document.

PAY DOCUMENTATION
Please keep all pay documents, especially any certificates of pay and
Income Tax deducted (form P60 which you receive annually at the end of
the tax year and form P45 which you receive when you leave us), carefully at
home as we cannot provide you with duplicates. It is also a good idea to
keep your monthly pay advices for at least the last two tax years.

SERVICE CHARGE (TRONC)
Your department may participate in a non-contractual Service Charge
scheme. Participation in a scheme depends on your position and contract
and is at the discretion of the Company and subject always to any scheme
rules. If you are entitled to a share of a Service Charge Scheme, your
Manager will supply details.

SECURITY

GENERAL
In the interests of safety and security for our guests and colleagues, you are
required to comply with any reasonable requests by the Hotel’s Security
department. Failure to do so may result in disciplinary action.

LOST PROPERTY PROCEDURE
Any item found or recovered by any member of staff or handed to a
member of staff by any guest or visitor to the hotel, will be deemed to be Lost
Property.
You must report any found items to your Manager immediately. Do not leave
any items unattended. Your manager will either accept and secure the item

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or direct you to report the find to the Security department who will advise you
further.
Please do not hold on to any lost property for even short periods of time.
Remember that the owner of the item may ask for it at any time so it is
important that the item has been recorded as “found” as soon as possible.

Failure to follow this procedure may be regarded as theft and may lead to
disciplinary proceedings.

PASS-OUT PROCEDURE

Unauthorised removal of property / assets belonging to the Hotel is a serious

breach of the Hotel rules and may lead to termination of employment.

Any hotel items received as a gift or obtained by purchase through the
Company must be accompanied by a proper receipt and/or authorised
pass-out. The pass-out must be signed by both the member of staff and the
authorising manager. The Duty Manager may, in the absence of your
manager, authorise the pass-out informing the Security department by e-
mail.

Any items given as a gift from a guest must, wherever possible, have a note
from the guest attached to the pass-out. Pass-out forms must be presented to
security personnel before exiting the building.
A ‘pass-out’ is valid for the date and in respect of the item indicated on the
‘pass-out’ itself only. Please be aware that you must obtain a ‘pass-out’ if you
wish to remove any item from the premises, even if the item is considered as
waste or marked for disposal.

Failure to follow the pass out procedure may lead to disciplinary proceedings
which can may result in dismissal for gross misconduct.

ENTERING AND LEAVING THE BUILDING

You must enter and exit your place of work using the staff entrance. Other
exits should only be used in an emergency situation. If you do not use the
staff entrance you may be subject to disciplinary action.

USE OF HOTEL FACILITIES/AUTHORISED AREAS

The Company’s public facilities are provided solely for the use of our guests
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and visitors and must not be used by any member of staff unless you have
the express authorisation of the General Manager or a member of the
executive committee. This includes all public toilets, lifts, health club, all food
and beverage outlets and public entrances.

For safety and security reasons you should confine yourself to permitted
employee areas within the building only. If you do need to go into a non-
employee area, you must get the permission of your Manager/Supervisor.

You are not permitted to be in the hotel when you are off duty; unless
permission has been granted to attend an employee event or invited to
attend a meeting regarding employment matters.

If you are found on the premises in your off duty time without good reason
you could be subject to disciplinary action.

Should you leave the employment of the Company, you are not permitted
onto Company or any other Shangri-La London premises for six months unless
you have express permission by the General Manager or the Director of
Human Resources.

COMPANY IDENTITY CARD
The Security or Human Resources department will issue you with an identity
card which you should carry with you at all times. This card proves that you
are employed by Shangri-La and you may be asked to produce it at any
time by a member of the Security team or Management team. The ID card
remains the property of the Company and must be surrendered when you
leave the Company before you receive your final payment. If you lose your
ID card, you should tell the Security department or the Human Resources
department who will issue a replacement for which there may be a small
charge.

LOCKERS

You may be allocated a locker for your personal use which must be
surrendered when you leave the Company, before you receive your final
payment and P45. Lockers are provided for you to keep your personal
belongings in at your own risk. Lockers are issued to you personally and you
should not transfer use of your locker to anyone else under any
circumstances.

Please do not use your locker to store items of Company equipment or
property, other than your uniform. On no account must you store food stuffs,

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alcohol or illegal drugs in your locker. If you do so you may be subject to
disciplinary action. Please note that we reserve the right to carry out spot
checks on lockers with you present or in your absence.

INSURANCE OF PERSONAL POSSESSIONS

The Company accepts no liability for items left in your locker and does not
insure your personal possessions at work. You use the Company lockers at
your own risk, so please do not leave money or valuable items in your locker
at any time. We also recommend that you obtain personal insurance for your
own possessions at work.

RIGHT OF SEARCH

The Company reserves the right to open and inspect a locker at any time.
This right of search is a necessary protection for both you and the Company
and is intended to safeguard the property of both yourself and the
Company.

Staff lockers are essentially to be used only for the storage of work uniforms
when off duty and the storage of personal clothing and immediate personal
belongings whilst on duty.

We reserve the right to remove from your locker any item that we reasonably
believe to be Company property.

STAFF SECURITY CHECKS
The Company’s right of search extends to any personal bags, packages or
other containers that you bring into, or remove from the premises. You will
routinely be asked by the Security department to submit any such belongings
for search as you leave or enter the building.

The Security Officer may also, on occasion, request an examination of
clothing pockets during the routine search in response to any reported losses.

These searches are intended to support the Company’ Loss prevention
strategy and are not indicative of any suspicion towards members of staff.
We ask that you co-operate with the Security Officer concerned who is simply
carrying out their duties.

The Company also reserves the right to ask you for proof of ownership of any

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articles of uncertain origin discovered during any search.

ISSUING OF KEYS AND SECURITY

To enable you to carry out your duties properly, you may be issued with a key
or key set (which may include master keys) for use throughout the hotel and
other company premises. Keys will be assigned through a unique code
allowing you to access the Traka Key cabinet.

You are responsible for the security of any keys drawn or placed in your
possession and must follow any security procedures or directives issued by
your Manager or the Security department.

You are not permitted to take keys outside hotel premises and MUST be
returned to their place of origin at the end of each shift.

Any member of staff who loses a key or key set must immediately report the
loss to their respective Department Head and immediately inform Security
Control of the date, time and place the keys were last seen.

You must not give your cabinet access code or keys on to any unauthorised
person; all keys remain the property of the Company and must be returned
when you leave our employment.

Any breach of key security is a serious issue and will be dealt with as a
disciplinary matter. Security of master keys is particularly important and any
loss or misuse of a master key may result in disciplinary action up to and
including summary dismissal.

CASH HANDLING PROCEDURES

If you are required to handle cash in the course of your duties, you must do so
strictly in accordance with procedures laid down by your Manager. All cash
handling employees are responsible for the security of the cash in their

control during their shift of operation. It is strictly forbidden for employees to
use, or borrow, cash from the Company’s floats or takings. If you are ever in
any doubt about the correct cash handling procedures to follow, you must
ask your Manager for clarification. Any contravention of cash handling
procedures is treated very seriously and may result in your dismissal.

MONITORING

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Please note that the Company may (at any time and without notice) monitor
or keep a record of communications sent and/or received over the
Company’s IT resources (including: computer hardware, software,
telephones, fax machines, voicemail, e-mail, building and facility access and
CCTV systems) and/or record employees use of the Company’s IT resources
in order to:-

– Detect and/or prevent crime.

– Establish the existence of business related facts.

– Ascertain whether employees and/or the Company are complying
with Company rules and policies (including, but not limited to, this
Policy) and also with legal and/or regulatory obligations to which
employees and/or the Company are subject.

– Ascertain whether communications are relevant to the Company’s
activities.

– Carry out maintenance of IT resources and to monitor for viruses
and/or any other programme which has contaminating and/or
destructive properties.

– Investigate or detect unauthorised use of the IT resources.

– Protect the vital interests of our employees as individuals, including
without limitation, concerns regarding our employees’ whereabouts
and/or safety.

The Company will, in conducting such monitoring activities, use all
reasonable endeavours to comply with the UK Information Commissioner’s
best practice guidelines and to respect our employees’ privacy and that of
third parties using the IT Resources.
Please note that where the Company identifies to the Commission a specific
criminal activity and determines that there is a need to obtain evidence of
this activity by monitoring, which would be prejudiced by informing our
employees about any such monitoring, the Company will conduct covert
monitoring, by means and for a period of time, which the Company
considers necessary to obtain evidence of the criminal activity. Any such
activity may be conducted with the knowledge of and/or in conjunction with
law enforcement authorities.

CCTV

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Please note the Company uses covert and overt CCTV monitoring on its
premises to:-

– Protect our employees’ personal safety and the safety of guests and
the public when they are on Company premises.

– Investigate, detect and/or prevent crime and to
apprehend/prosecute offenders.

– Ascertain whether staff members are complying with behavioural
requirements and standards specified in their employment contracts,
Company rules and policies and statutory or regulatory obligations to
which employees and/or the Company are subject.

Any such CCTV monitoring will be carried out in accordance with the Data
Protection Act. To do this, the Company will rely on the CCTV Code of
Practice issued by the Information Commissioner.

The Company may sometimes disclose CCTV footage to third parties such as
law enforcement authorities, solicitors and the Courts for the purposes listed
above. The Company may also disclose CCTV footage to the media if it
believes that this will assist in the apprehension of criminals. Other parties who
may come into contact with the CCTV footage which the Company records,
include individuals or organisations operating the CCTV system on the
Company’s behalf and organisations providing the Company with footage
editing services.

VIOLENCE & AGGRESSION GUIDELINES
Acts of aggression and violence towards staff or guests are not acceptable
and will not be tolerated by the Company. In the event of any potentially
violent or aggressive situation it is important not to place yourself or others
under any undue risk. Any action taken to manage an incident should always
be non- confrontational with the aim of defusing and calming down the
situation, ensuring that you remove yourself and others from potential
danger.

If a member of staff, guest or client becomes aggressive or violent for any
reason, inform your Manager, immediately and request the attendance of a
Security Officer and or a Human Resources manager. The Police may be
called if for any reason a member of staff feels under threat.

Physical restraint, holding or tackling an aggressor should be avoided unless
absolutely necessary in the cause of self-defence. Never try to confront or
apprehend anyone acting suspiciously or who may have been identified as a

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potential intruder.

Security or the Police must be called immediately. It is your responsibility to do
so if your Manager is not present. All aggressive situations whether verbal or
physical, and irrespective of who is involved, must be reported to a Senior
Service Manager, Service Executive, or Human Resources at once in order
that:-

– Appropriate support is provided.

– Problem areas can be identified.

– Appropriate corrective action is taken.

– Senior Management is immediately made aware of the situation.

– The Company Incident Report Form is completed with available
witness reports.

– The incident is recorded in the Accident Book.

– A full investigation is undertaken and substantiating evidence
collected.

THREATENING SITUATIONS

Any employee who may be involved in an attempted robbery or similar
violent situation must never resist and place themselves or others in further
danger.

In the event of this situation arising you should try to:-

– Stay calm and adopt a non-hostile manner
– Always obey instructions given – such as handing over the money or
article requested or filling bags etc.

– Never attempt to foil the robbery or situation and never refuse to
hand over what is demanded – money and articles can always be
replaced.

Robbers and others will generally be very nervous and agitated and may
overreact aggressively if challenged. This may result in you or others
becoming hurt unnecessarily.

– Avoid sudden or suspicious movements, such as putting a hand in a
pocket.

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– Make a mental note of the person’s appearance but eye contact
should be avoided.

– Only activate an alarm if it is safe to do so.

– Never try to apprehend anyone as this may result in you and others
being hurt.

After a threatening situation has occurred always make sure Security or the
Police have been contacted. Try to preserve the condition of the scene. Do
not touch anything.

Request any member of staff or clients who have witnessed the event to
remain until Security or the Police arrive. If they do insist upon leaving the
scene, obtain names and addresses before they do so.

As soon as possible, take time to write down the description of the people
involved and anything else that may be relevant, (clothing, language
accent etc.) In the first instance rely on your own memory and try not to
confer with others.

Make sure your Manager has been contacted and that you follow any
instructions that they specifically give to you. If you are in the state of shock
and unable to make a report or continue with your duties, ensure that you
are seen by a First Aider or another member of staff.

An Incident Report Form must be completed, as well as any Security reports.

EQUAL OPPORTUNITIES

Shangri-La Hotel is an equal opportunity employer. This means that we do not
permit discrimination of any kind against any person on the grounds of
colour, creed or religion, belief, race, nationality or ethnic or national origins,
sex, age, transsexualism, sexual orientation, marital status, disability, part-time
workers, fixed term employees or any other grounds that could be termed
discriminatory under equal opportunities legislation. We will ensure that equal
opportunity principles are applied to the recruitment, training, development
and promotion of staff. Such decisions will be made on the basis of merit and
ability only.

As an employee, you have a personal responsibility for helping us to ensure
that equal opportunity principles are applied at work. You must not
discriminate, directly or indirectly, against another person on any of the
grounds outlined above.

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Direct discrimination occurs if you treat a person less favourably than
someone else in similar circumstances on the basis of one of the grounds
outlined above. Indirect discrimination occurs when a provision, criterion or
practice (whether intentional or not) adversely affects a larger proportion of
individuals who have one of the grounds outlined above or any other
grounds that could be termed discriminatory under equal opportunities
legislation.

We regard any form of discrimination as gross misconduct. Any employee
who victimises, bullies, harasses or discriminates against another person
(whether this is another employee, worker, guest, supplier, or other third party
or member of the public) will be subject to disciplinary action, potentially
leading to summary dismissal for gross misconduct.

Any employee who feels that they have been subject to discrimination
should raise the matter through the Company’s grievance procedure. The
Company will also consider informal approaches to the situation and will
endeavour to resolve the matter informally if possible.

DISCIPLINARY PROCEDURES

RULES AND PROCEDURES

The rules set out below are designed to clarify the rights and responsibilities of
management and staff in matters relating to discipline. These procedures will
be followed if you fail to act in accordance with the Company’s policies,
standards of performance and/or rules of conduct.

The purpose of the procedure is to be corrective rather than punitive where
possible, and it should be recognised that the existence of procedures such
as these are to help and encourage employees to achieve and maintain
standards of conduct, attendance and job performance and to ensure
consistent and fair treatment for all employees.

If you are called to a disciplinary meeting interview/hearing, or request an
appeal hearing, you are entitled to be accompanied by a current
workplace colleague, or a qualified official of a Trade Union. Employees are
expected to cooperate under this procedure and attend all meetings where
possible and not unreasonably delay the process.

A record of any disciplinary action taken against you under this procedure
will be kept in your employee file, for the appropriate length of time, in the
Company’s records and you will be issued with a copy.

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