Doing the right thing is essential to our brand promise. ENVIRONMENTAL, SOCIAL, AND GOVERNANCE 2019 ANNUAL REPORT Governance, Risk and Compliance G O V E R N A N C E R I S K & C O M P L I A N C E D I V E R S I T Y & I N C L U S I O N S O C I A L , E N V I R O N M E N T & S U S T A I N A B I L I T Y Our strong governance framework protects our reputation, employees, and clients. Compliance truly is our competitive advantage as we are the most highly regulated travel company in the world. Our risk mitigation strategies address privacy, cyber-security, business continuity, crisis management – and combat fraud, terrorist ﬁnancing, money laundering, bribery and corruption. OUR CODE OF CONDUCT It provides guiding principles to show our colleagues how to conduct business, examples to assist them in resolving potentially troublesome issues and contact information for seeking advice. Risk & Compliance Training Code of Conduct Sanctions and Anti-Money Laundering Anti-Bribery and Anti-Corruption Privacy Awareness Information Security Antitrust Unfair, Deceptive or Abusive Acts or Practices (UDAAP) Telephone Consumer Protection Act (TCPA) Click here to view the complete Environmental, Social, and Governance 2019 Report. American Express Global Business Travel (GBT) is a joint venture that is not wholly owned by American Express Company or any of its subsidiaries (American Express). “American Express Global Business Travel,” “American Express,” and the American Express logo are trademarks of American Express and are used under limited license. This document contains unpublished, conﬁdential, and proprietary information of American Express Global Business Travel (GBT). No disclosure or use of any portion of these materials may be made without the express written consent of GBT. © 2020 GBT Travel Services UK Limited. 3 6 0 ° C O M P L I A N C E RESPOND ■ Investigations ■ Disciplinary Actions ■ Remediation ■ Issue Management PREVENT ■ Policies ■ Procedures ■ Communication ■ Training DETECT ■ Risk Assessment ■ Testing ■ Monitoring ■ Reporting/ Whistleblower OUR RISK AND COMPLIANCE PROGRAM A true 360 o program How compliance and risk management is built into the DNA of GBT RESPONSIBLE PROCUREMENT Our Supplier Responsible Business Shared Values provide an overview of the ethical standards that are important to GBT. All our suppliers and their employees must abide by these Shared Values in all business dealings for and on behalf of our Company. Risk and Compliance Policies Sanctions and Anti-Money Laundering Anti-Bribery and Anti-Corruption Fraud Prevention Antitrust Incident Management and Business Continuity Third-Party Oversight Responsible Marketing Product Development Data Privacy and Information Security

Doing the right thing is essential to our brand promise. · Information Security Antitrust Unfair, Deceptive or Abusive Acts or Practices (UDAAP) Telephone Consumer Protection Act

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Doing the right thing is essential to our brand promise.

ENVIRONMENTAL, SOCIAL, AND GOVERNANCE 2019 ANNUAL REPORT

Governance, Risk and Compliance

VERN

ANCE

RIS

K &

MPL

NCE

DIVERSITY & INCLUSIONSOCIAL,

ENVIRONMEN

& SUSTAINABILITY

� Our strong governance framework protects our reputation, employees, and clients.

� Compliance truly is our competitive advantage as we are the most highly regulated travel company in the world.

� Our risk mitigation strategies address privacy, cyber-security, business continuity, crisis management – and combat fraud, terrorist financing, money laundering, bribery and corruption.

OUR CODE OF CONDUCTIt provides guiding principles to show our colleagues how to conduct business, examples to assist them in resolving potentially troublesome issues and contact information for seeking advice.

Risk & Compliance Training � Code of Conduct � Sanctions and Anti-Money Laundering

� Anti-Bribery and Anti-Corruption � Privacy Awareness � Information Security � Antitrust � Unfair, Deceptive or Abusive Acts or Practices (UDAAP)

� Telephone Consumer Protection Act (TCPA)

Click here to view the complete Environmental, Social, and Governance 2019 Report.

American Express Global Business Travel (GBT) is a joint venture that is not wholly owned by American ExpressCompany or any of its subsidiaries (American Express). “American Express Global Business Travel,” “AmericanExpress,” and the American Express logo are trademarks of American Express and are used under limited license.

This document contains unpublished, confidential, and proprietary information of American Express GlobalBusiness Travel (GBT). No disclosure or use of any portion of these materials may be made without the expresswritten consent of GBT. © 2020 GBT Travel Services UK Limited.

360°

COM

PLIANCE

RESPOND■ Investigations■ Disciplinary Actions■ Remediation■ Issue Management

PREVENT■ Policies■ Procedures■ Communication■ Training

DETECT■ Risk Assessment■ Testing■ Monitoring■ Reporting/

Whistleblower

OUR RISK AND COMPLIANCE PROGRAM

A true 360o programHow compliance and risk management is built into the DNA of GBT

RESPONSIBLE PROCUREMENTOur Supplier Responsible Business Shared Values provide an overview of the ethical standards that are important to GBT. All our suppliers and their employees must abide by these Shared Values in all business dealings for and on behalf of our Company.

Risk and Compliance Policies � Sanctions and Anti-Money Laundering � Anti-Bribery and Anti-Corruption � Fraud Prevention � Antitrust � Incident Management and Business Continuity � Third-Party Oversight � Responsible Marketing � Product Development � Data Privacy and Information Security

https://www.amexglobalbusinesstravel.com/corporate-social-responsibility/