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.