Summary of Key Anti-Corruption Principles

Starwood Hotels & Resorts Worldwide, Inc. does not condone nor permit
bribery, solicitation of bribery or the payment of kickbacks, even if permitted by local
custom or practice. Starwood’s Code of Business Conduct and Ethics (“Code”) and
Anti-Corruption Policy mandate compliance with applicable law, rules or regulations.
The key principles set forth in these policies include the following:

Conduct Prohibited Under Starwood’s Code and Anti-Corruption Policy

It is impermissible to offer, promise, give or authorize the giving of anything of

value, directly or indirectly, to a government official or any other person to
influence official action, induce him/her to perform work duties improperly or
secure an improper advantage.

It is impermissible to make any “facilitation payments”— also known as

“expediting” payments or “grease,” “dash” or “speed” payments — to
accelerate routine business acts by government officials.

It is impermissible to enter into an agreement with an external party if there is

a material risk that such party will violate anti-corruption laws or the Anti-
Corruption Policy.

It is impermissible to maintain inaccurate books and records, hide or

misallocate funds, or disguise or attempt to disguise the source of funds or
the true nature of any payment.

Conduct Required Under Starwood’s Code and Anti-Corruption Policy

Approval is required for the hotel (or any of its associates) to offer or give
anything of value, even minimal value, to a government official or to someone
in a position to influence a government official, unless otherwise permitted
without such approval in the Anti-Corruption Policy.

Procedures are required under the Anti-Corruption Policy, including

conducting due diligence, assessing corruption risk and obtaining required
pre-approvals, prior to any hotel (or its associates) engaging in certain
business interactions — including involvement with external parties who
interact with government and government officials.

Certain behavior is mandated, including the implementation of accounting

practices, that help ensure the accuracy of books and records and adequate
internal controls and procedures to help prevent and detect illegal and/or
corrupt transactions.

Refer to Starwood’s Code, which is available publically on Starwood’s website

(http://www.starwoodhotels.com/corporate/about/investor/governance.html), and
Starwood’s Anti-Corruption Policy, a detailed summary of which can be found in the
Code and the full form of which is available upon request, for additional information.