Commitment to an Ethical Culture

Four Seasons is committed to conducting business in a manner that complies with applicable laws and is consistent with the highest ethical standards, including standards intended to prevent bribery and corruption. Four Seasons is committed to understanding the risks that may compromise these standards and using all reasonable efforts to ensure that those who provide services to and for Four Seasons – including employees, contractors and agents – are aware of and share our commitment to an ethical and anti-bribery culture.

Four Seasons has earned an enviable reputation internationally that is built, in part, on our commitment to doing business in a manner that complies with applicable laws and is, and is perceived to be, consistent with the highest ethical standards. This means, among other things, avoiding bribery and corruption, and implementing appropriate policies and procedures throughout Four Seasons business operations that will guide those who provide services to and for Four Seasons – including employees, contractors and agents – consistent with the company’s ethical standards.

Four Seasons has adopted a Code of Business Conduct and Ethics, which has been endorsed by its Board of Directors and senior management. The Code reflects, among other things, the most current assessment by Four Seasons of external and internal risks of bribery and fundamental standards that Four Seasons expects those who provide services to and for it – including employees, contractors and agents – to abide by when acting on behalf of Four Seasons.

Four Seasons will not use third parties or intermediaries to engage on its behalf in unethical practices that would be prohibited under applicable law – including the Bribery Act – if undertaken by Four Seasons. Four Seasons expects that all parties and intermediaries that it engages will conduct themselves accordingly when acting on behalf or for the benefit of Four Seasons.

Four Seasons is committed to open communication concerning its ethical standards and anti-bribery initiatives and has established procedures that are described in the Code to permit the submission on a confidential and anonymous basis (to the fullest extent possible consistent with applicable law) of good faith complaints relating to violations of the Code using a third-party reporting service.