1 HILTON OCCUPATIONAL HEALTH AND SAFETY POLICY 2024

HILTON OCCUPATIONAL HEALTH AND SAFETY POLICY 2024

OUR VISION

At Hilton, we are a business of people serving people, and because people are at the

heart of what we do, so is safety. We recognize the importance of creating a safe

environment for our Team Members, guests, contractors, and other visitors. Safety

requires a commitment from everyone. Each Team Member is responsible for

understanding and complying with all applicable safety and health laws and guidelines.

We support a proactive culture of risk management to ensure accidents or incidences

of ill health remain as low as is reasonably practicable.

OUR RESPONSIBILITIES

As a global company, Hilton’s legal responsibilities for the safety of Team Members,

guests and others varies depending on local regulations and ownership/management

structures. Hilton as a management company retains responsibility for implementing

occupational health and safety programs in leased and managed hotels and corporate

offices, while these responsibilities sit with franchisees (separate legal entities) for

franchised hotels. The management of occupational health and safety in our leased,

and managed hotels and corporate offices is incorporated into everyday business

practices, and we regularly measure and review performance, focusing on the

development of a proactive safety culture. Hotels operate occupational health and

safety (“OHS”) programs relevant to their regions and local legislative requirements. We

are committed to continually improving the performance of our OHS program, and

corporate Safety and Security leaders meet regularly alongside hotel-based leaders to

update and refine guidance, training, and procedures.

OUR LEADERSHIP

General Managers are ultimately responsible for driving a positive safety culture in our

leased and managed hotels, and some larger hotels also have dedicated safety and

security teams on property to assist. Above property level, a dedicated team of regional

corporate safety and security directors provides expert guidance, assistance, and

auditing to help deliver on our vision. Regional Safety and Security Directors are

overseen by Regional Senior Directors/Vice Presidents who in turn report into the

Global Vice President of Safety and Security. At a global level, a Director of Global

Safety and Compliance ensures that regional teams have the necessary guidance and

training resources to deliver in their regions, and monitors accident, incident, and audit

data to gauge compliance. The Safety and Security function reports into a Senior Vice

President - Hilton’s Chief Risk and Accounting Officer.

OUR 2024 PRIORITIES

Each year the Corporate Safety and Security team prioritizes initiatives to drive

occupational safety forward across the estate. Below are examples of initiatives that

each region is advancing this year:

 The Americas region is relaunching a simplified and upgraded safe hands

initiative aimed at reducing work related accidents through raising awareness of

safe working practices.

 The EMEA region is implementing monthly educational webinars with hotels to

raise awareness of safety and security resources and initiatives.

 The APAC region is implementing a serious accidents mitigation strategy.

CONSULTING WITH OUR EMPLOYEES

Managed hotels and corporate offices consult with Team Members at all levels to

identify safety concerns and opportunities for improvement by hosting regular Health

and Safety Committee meetings. Hotel management are encouraged to take an active

role in overseeing these meetings to increase engagement and help foster a strong

safety culture.

INVESTIGATION OF WORK-RELATED INJURIES, ILL HEALTH, DISEASES AND

INCIDENTS

Work related injuries, ill health, diseases and incidents are investigated on property by

the relevant management. Managed hotels follow internal investigation reporting

requirements, which is evidenced on an incident management platform. Brand

Standards require all hotels to train Team Members in safety, which assists in the

prevention of work-related injuries.

OCCUPATIONAL HEALTH AND SAFETY PROGRAMS

Hilton’s Managed hotels operate health and safety programs tailored by region.

Regional examples of components of the OHS programs are outlined below but are not

exhaustive. While Hilton’s Occupational Health and Safety programs are not

independently certified against international standards such as ISO 45001, our

programs reflect similar levels of comprehensiveness on issues such as risk

management, employee consultation and legal and regulatory compliance.

Americas

Hotels in the United States are required to operate health and safety programs

that align with the requirements of OSHA. Each hotel is provided with a

template safety program and is required to customize the program to address

the specific safety needs of the hotel. Examples of safety programs operated by

hotels include blood borne pathogens, electrical safety, hazard communication,

injury prevention, machine guarding and PPE. In addition to the safety programs,

hotels can access monthly safety refresher training resources to help drive

home the importance of these programs. While OSHA applies only in the US,

resources are also made available to hotels in the Caribbean and Latin America

regions.

Separately, a ‘Safe Hands’ initiative is in place to help guide hotels in reducing

accidents. The Safe Hands initiative includes scorecards for evaluating the safe

performance of hazardous tasks such as moving a housekeeping cart, alongside

additional training resources.

Job safety analysis sheets are provided for hazardous activities such as lifting

heavy objects, welding, and window cleaning. These sheets contain detailed

step-by-step guidance on how to perform a hazardous task safely, thereby

reducing risk to the Team Member and others in the vicinity.

Departmental job safety training packs have been produced to guide hotels

through the process of inducting and training Team Members. These packs

(examples include Culinary, Engineering, Laundry, etc.) are developed with the

Team Member’s safety in mind and ensure proper training and instruction has

been provided for regular tasks.

Hotels are provided with checklists to self-assess their compliance with various

safety requirements. Checklists include ladder inspections and pool water

quality checks, among other tasks. Checklists help hotels identify potential

hazards and reduce risk.

Europe, Middle East & Africa, and Asia Pacific

With more than 100 countries represented outside the Americas, exact

occupational health and safety programs are influenced by local regulations, but

an overarching ‘Health and Safety Manual’ is in place to guide managed and

leased hotels through the requirements for keeping Team Members and Guests

safe. The Safety Manual -- available in multiple languages -- is extensive, but

examples of content include working at height, manual handling, chemical safety,

electrical safety, and slips, trips and falls. The manual contains a variety of

guidance, checklists and appendices that enable hotels to apply the content

directly to their properties.

In addition to the safety manual, hotels are provided with a suite of Safe Systems

of Work. Safe Systems of Work are provided for hazardous activities such as

chemical dosing, cleaning bodily fluid spills, and using ladders. They contain

detailed step by step guidance on how to perform a hazardous task safely,

thereby reducing risk to the Team Member and others in the vicinity.

Where required by local law (such as in the UK), hotels conduct workplace safety

risk assessments. These assess the likelihood and severity of injury occurring

due to the tasks typically conducted across the operation. Hotels then

implement corrective control measures where required, to ensure a satisfactory

level of residual risk. Risk assessments also help to monitor the effectiveness of

control measures.

Department specific eLearning courses are available in multiple languages.

These bespoke Hilton courses educate Team Members on the common hazards

associated with their departments and give comprehensive safety advice on

how to stay safe and avoid injury to themselves and others. Examples of these

eLearning courses include Kitchens Safety, Food and Beverage Safety, and

Housekeeping Safety.

Quarterly audits are provided for hotels to self-assess their compliance with the

contents of the safety manual. These audit requirements align with the control

measures identified in risk assessments. 21 separate audits are provided to cover

all aspects of hotel operations, and include examples such as fitness center,

kitchen, car park and conference and events.

Team Members in all regions have access to the School of Safety and Security – our

one-stop location for all safety training, available in multiple languages, and containing 11

hours of safety and security related content.

GOVERNANCE

At a corporate level, managed and leased hotels receive periodic safety and security

reviews (audits) by their Regional Safety and Security Director. These reviews provide

an opportunity for the regional director to identify areas for improvement and to assess

compliance with the occupational safety programs. Hotels are selected for audit by

taking a risk-based approach. Audits facilitate the prioritization of remedial actions and

result in action plans which hotels are required to complete. An escalation process

enables auditors to raise any major concerns with senior regional leadership (Area

Operations Vice President) and Corporate Safety and Security leadership (Regional

Safety & Security Senior Director/Vice President). A customized audit platform is used

to capture audit actions and ensure completion. Audits are a key tool for evaluating

progress in reducing/preventing health issues/risks against quantified pass

marks/targets at audit.

Managed and Leased hotels report accidents into corporately managed reporting

systems, from which trend analysis is performed to identify areas of focus and further

mitigation.

An independently operated hotline is available for Team Members at Corporate,

Managed and Leased locations to report any code of conduct concerns, which may

include unsafe practices.

Further to safety and security audits, hotels are inspected by Quality Assurance

auditors who verify the completion of mandated safety training requirements such as

health and safety, CPR, emergency procedures and fire safety, food safety and

sanitation, and preventing human trafficking. These mandated requirements apply to

franchised hotels in addition to managed and leased hotels globally.

All corporate members of the Hilton Safety & Security Team (in addition to certain hotel

Safety & Security Directors, dependent on hotel location and size) are certified or

qualified in appropriate safety standards applicable to their regions. Examples include:

 Americas - OSHA 501: Trainer Course in Occupational Safety and Health

Standards for General Industry, the highest certification individuals can receive

for private sector OSHA training.

 EMEA – NEBOSH Diploma in Occupational Health and Safety Management, BSc

or MSc in Environmental Health.

 APAC - Singapore National Occupational Safety and Health and Business

Continuity (BCLE2000).

Safety and Security processes and programs are periodically verified where necessary,

by third parties. Examples include:

 United Kingdom – A primary authority arrangement with a local government

body ensures safety guidance produced by the UK corporate safety team is in

line with local legislative requirements.

 USA – A legal firm - Jackson Lewis - periodically assesses the Americas OHS

programs to ensure they are compliant with OSHA requirements.

 Globally – Third party food hygiene inspections conducted by Ecosure and

Diversey help verify food hygiene standards in kitchens.

The refinement and verification of our occupational health and safety procedures is

further aided by the connections our global and regional Safety and Security corporate

leaders have with peers across the industry. Such connections enable the sharing of

best practice and often involve feedback directly to lawmakers. One such example is

the involvement of the UK Regional Safety & Security Director on the UK Health and

Safety Executive Hospitality Liaison Forum.

TRAVEL SAFETY

As a major global company, many corporate Team Members and hotel managers are

required to travel internationally as part of their roles. Hilton operates a comprehensive

duty of care program with its partner Global Guardian. This program ensures all

international travellers have access to pre travel advisories, country risk ratings, and

expert travel safety advice. All international travellers are required to complete

bespoke Hilton international travel safety eLearning, which addresses a wide range of

safety, security, medical and emergency procedures. Team Members have access to a

Global Guardian mobile app which geolocates them during their travels and contains

important safety features such as a panic button. Hilton also works closely with travel

booking platforms to verify safe airlines and routes.