CEO message
http://www.ihgplc.com/index.asp?pageid=812

Policies
http://www.ihgplc.com/index.asp?pageid=733

Commitment to UNGC
http://www.ihgplc.com/index.asp?pageid=763

CEO message
What is the role of hotels in 21st century society?

As the world's largest hotel group1 we understand that the role of hotels in society goes beyond selling hotel rooms. We must act responsibly and build trust in our brands.

Building trust and being a responsible business are fundamental. Our size and scale give us a big responsibility. The great news is that doing the right thing strengthens our reputation and reinforces trust in our brands. It shows, for instance, that we're listening to our stakeholders. A growing number of our guests want to make sustainable choices and lots of our corporate clients want proof of our green credentials.

We treat CR as a strategic business issue, and an integral part of our vision to become one of the world's great companies by creating Great Hotels Guests Love. At the same time, we're working to make our brands even stronger by becoming BrandHearted, putting our brands at the heart of everything we do in order to offer a more consistent experience for our guests and owners.

Our approach to CR is based on innovation and collaboration. We develop groundbreaking technologies and concepts, like our online sustainability tool, Green Engage and our online Innovation Hotel. And we partner with some of the best organisations around in order to find new ways to tackle the challenges we all face. These include Oxford and Harvard Universities, LEED (Leadership in Energy and Environmental Design), the World Travel and Tourism Council and, most recently, CARE International, who are helping us deliver our disaster relief programme.

IHG has strong foundations in place and is forging a reputation for taking an industry lead in CR. This year we became the first hotel company to be endorsed by LEED for an existing hotel programme when we received a coveted LEED endorsement for Green Engage. Green Engage is central to the environmental element of our strategy and we continue to invest in it, having recently launched version 2.0 of the system that helps our hotels manage energy costs.

We recently refreshed our Community Strategy to concentrate our efforts on the areas where IHG, as a hotel company, can have the most positive impact in our local communities. Our community involvement means a lot to me. I'm particularly keen to give more people better access to career opportunities in hospitality, so I am very excited about the IHG Academy. The IHG Academy is a public/private partnership that helps us create local economic opportunity in the communities around our hotel and corporate offices. This year, the IHG Academy will be developing in Greater China, the UK, USA and Australia, and in other countries in the very near future.

The nature of our business also allows us to make a real difference in local communities when disaster strikes. We have a long history of pulling together to provide shelter in a storm in our hotels and recognise that we have a real opportunity to use our size and scale for even more positive good. Under the IHG Shelter in a Storm Programme, we are reinforcing the great work we already do by developing standard operating procedures that will help us respond more effectively when natural and manmade disasters occur. We are working with our new global charity partner CARE International on this important disaster relief programme.

This report shows how we put our CR thinking into practice, providing a clear and transparent record of what we've achieved and what we need to do better. We don't pretend to have all the answers and we acknowledge there are areas we can improve. But we believe that striving to take an industry lead and making CR a genuine part of our overall strategy to create brands and hotels that our guests and owners trust and always prefer will enable us to play a leading role in 21st century society.

Richard Solomons

Chief Executive Officer

1 By number of rooms

Key achievements
- Developed a unique Human Rights policy
- We endorse the United Nations Global Compact as a reflection of our policy.

http://www.ihgplc.com/index.asp?pageid=763

At IHG we believe that strong ethics and good business are natural partners. We are committed to operating our company with integrity, working to the highest ethical standards. Our reputation is built on the trust and confidence of all our stakeholders, and is fundamental to our vision to make IHG one of the world's great companies.

View our Code of ethics and business conduct - http://www.ihgplc.com/index.asp?pageid=244

More and more of our stakeholders want reassurance that we provide decent working conditions for all of our employees, manage our risks with all our business partners and make sure the rights of the local people where we operate are protected. While we work towards covering these areas in our contract terms and conditions we accept we have much more to do.

In 2010 we signed up to the Global Compact, aligning our operations and strategies with the ten universal principles that include commitments to human rights and labour standards.

Since 2008 we have been developing comprehensive methods to help us assess and respond to human rights issues. All members of the Executive Committee take responsibility for human rights on behalf of the Board.

http://www.ihgplc.com/index.asp?pageid=763

Human Rights Policy
http://www.ihgplc.com/index.asp?pageid=733#humanrights

How our employees can raise a grievance
We have a whistleblower line and let employees know about it through internal communications and a dedicated website

www.ihgethics.com

At IHG we believe that strong ethics and good business are natural partners. We are committed to operating our company with integrity, working to the highest ethical standards. Our reputation is built on the trust and confidence of all our stakeholders, and is fundamental to our vision to make IHG one of the world's great companies.

View our Code of ethics and business conduct - http://www.ihgplc.com/index.asp?pageid=244

More and more of our stakeholders want reassurance that we provide decent working conditions for all of our employees, manage our risks with all our business partners and make sure the rights of the local people where we operate are protected. While we work towards covering these areas in our contract terms and conditions we accept we have much more to do.

In 2010 we signed up to the Global Compact, aligning our operations and strategies with the ten universal principles that include commitments to human rights and labour standards.

Since 2008 we have been developing comprehensive methods to help us assess and respond to human rights issues. All members of the Executive Committee take responsibility for human rights on behalf of the Board.

www.ihgethics.com

https://secure.ethicspoint.com/lrn/media/en/gui/20831/faq.html

At IHG we believe that strong ethics and good business are natural partners. We are committed to operating our company with integrity, working to the highest ethical standards. Our reputation is built on the trust and confidence of all our stakeholders, and is fundamental to our vision to make IHG one of the world's great companies.

View our Code of ethics and business conduct - http://www.ihgplc.com/index.asp?pageid=244

More and more of our stakeholders want reassurance that we provide decent working conditions for all of our employees, manage our risks with all our business partners and make sure the rights of the local people where we operate are protected. While we work towards covering these areas in our contract terms and conditions we accept we have much more to do.

In 2010 we signed up to the Global Compact, aligning our operations and strategies with the ten universal principles that include commitments to human rights and labour standards.

Since 2008 we have been developing comprehensive methods to help us assess and respond to human rights issues. All members of the Executive Committee take responsibility for human rights on behalf of the Board.

Working conditions
We respect and support our employees' rights to decent working conditions. Our employment policies are designed to comply with all local labour laws and also to create safe, healthy and fair conditions throughout the whole of IHG. We know that wages, working hours and job security can be challenges within our industry. To begin to mitigate these risks we put in place a Human Rights policy for IHG-owned and -operated properties and will expand this to include business partners in contract terms and conditions.

IHG's Anti-Bribery Commitment
IHG is committed to carrying out business with integrity and in accordance with the highest ethical standards. IHG does not support or condone bribery or corruption.

We have in place a Bribery and Anti-Corruption Policy and a Gifts and Entertainment Policy which apply to all IHG employees and in all our owned and managed hotels. We include appropriate language in relevant agreements (including Hotel Management Agreements and Franchise Agreements) and we have launched a bribery training programme for our employees. Our financial control, risk management and internal audit processes also take into account bribery legislation to raise awareness of regulations and compliance with our policies.

How our employees can raise a grievance
We have a whistleblower line and let employees know about it through internal communications and a dedicated website www.ihgethics.com

Labour unions
We recognise the importance of partnerships with labour unions that represent our employees. 'Room to be Yourself' is the employer side of our deal with our employees. Through it, we support our employees' right to decide if they want to be part of a union or not, free from any outside pressure or intimidation. In order to make the process fair, personal and democratic we support our employees' right to a private, secret ballot election.

Approximately 20% of hotel-based employees in the United States and Canada are members of an organised labour union. There are no collective bargaining agreements in other regions. In the Europe, Middle East and Africa region, we set up a Works Council for employee representation.

We give employees and union representatives advance notice of material operational changes. Minimum notice periods may vary by location and we always seek to comply with local laws.

http://www.ihgplc.com/index.asp?pageid=763

Human Rights Policy
http://www.ihgplc.com/index.asp?pageid=733#humanrights

Our people
http://www.ihgplc.com/index.asp?pageid=758

Diversity and Ethnicity
http://www.ihgplc.com/index.asp?pageid=762

How our employees can raise a grievance
We have a whistleblower line and let employees know about it through internal communications and a dedicated website

www.ihgethics.com

At IHG we believe that strong ethics and good business are natural partners. We are committed to operating our company with integrity, working to the highest ethical standards. Our reputation is built on the trust and confidence of all our stakeholders, and is fundamental to our vision to make IHG one of the world's great companies.

View our Code of ethics and business conduct - http://www.ihgplc.com/index.asp?pageid=244

More and more of our stakeholders want reassurance that we provide decent working conditions for all of our employees, manage our risks with all our business partners and make sure the rights of the local people where we operate are protected. While we work towards covering these areas in our contract terms and conditions we accept we have much more to do.

In 2010 we signed up to the Global Compact, aligning our operations and strategies with the ten universal principles that include commitments to human rights and labour standards.

Since 2008 we have been developing comprehensive methods to help us assess and respond to human rights issues. All members of the Executive Committee take responsibility for human rights on behalf of the Board.

www.ihgethics.com

https://secure.ethicspoint.com/lrn/media/en/gui/20831/faq.html

Diversity and Ethnicity
http://www.ihgplc.com/index.asp?pageid=762

Examples of Diversity and Ethnicity
Since 2007, the Americas region has engaged in more effective recruitment through targeted recruitment aimed at both minority and underrepresented groups in an effort to ensure a diverse mix of candidates. For example, all of IHG’s job postings are fed to various third party alliance and partner websites, which in turn has increased numbers. Job postings are also advertised on numerous diversity sites and Military networks. Similarly, our Americas requisitions in Taleo get pushed out to a College Alumni Network. This network includes 531colleges and universities in the U.S.

Our corporate office in the Americas region is committed to diversity and inclusion. Here are some examples which serve as evidence of positive diversity behaviors and what the region is doing to increase the level of engagement among certain diverse groups or diversity strands:
o IHG sponsors the eWIT (Engaging Women In Technology) group - this is an organisation that IHG's Chief Information Officer, Tom Conophy, sponsors. It is designed to attract, retain and advance women in the field of technology. The number of women at IHG involved with eWIT is approximately 8-10.
o IHG encourages its female employees to join the Georgia Women in Lodging (GWIL) organisation and to attend their events.
o IHG, in conjunction with the Georgia Employer Support of the Guard and Reserves, signed a Statement of Support of the National Guard and Reserve in 2011 that demonstrates IHG's commitment to colleagues who are service members, giving them peace of mind that their jobs will be waiting for them when they come back home.
o The corporate office hosts a variety of diversity-related events:
 In April 2011, IHG hosted a ‘Women in Leadership Tea’ for corporate women leaders and aspiring leaders.
 Senior members of IHG, plus representatives from Pink, an online magazine for woman, shared tips on how to make one's life and career more beautiful.
o IHG’s Americas region has a corporate Affirmative Action programme in place. The Affirmative Action Plan (AAP) for Minorities and Females is a results-oriented programme designed to ensure employment opportunities for minority and female employees based on good faith efforts.

In the Americas region, IHG has also increased its efforts to decrease the incidence of bullying and harassment. Examples include:
o The creation of an Americas corporate Bullying Policy in 2011.
o Bolstering of the existing corporate Harassment Policy to include genetic information and sexual orientation as protected diversity strands listed therein.

Our people
http://www.ihgplc.com/index.asp?pageid=758

Employee profile
http://www.ihgplc.com/index.asp?pageid=760

Our approach to Corporate Responsibility
http://www.ihgplc.com/index.asp?pageid=727

Environment policy
http://www.ihgplc.com/index.asp?pageid=733

Our approach to the Environment
http://www.ihgplc.com/index.asp?pageid=740

Environmental legislation
http://www.ihgplc.com/index.asp?pageid=741

Climate and Carbon
http://www.ihgplc.com/index.asp?pageid=745

Energy
http://www.ihgplc.com/index.asp?pageid=749

Water
http://www.ihgplc.com/index.asp?pageid=750

Waste
http://www.ihgplc.com/index.asp?pageid=751

Our approach to the environment through:
Innovation - http://www.ihgplc.com/index.asp?pageid=719
Collaboration - http://www.ihgplc.com/index.asp?pageid=720

Environment approach
http://www.ihgplc.com/index.asp?pageid=740

Green Engage
http://www.ihgplc.com/index.asp?pageid=742

Governance
http://www.ihgplc.com/index.asp?pageid=728

Green Engage - LEED
http://www.ihgplc.com/index.asp?PageID=116&NewsID=2568

Innovation Hotel Launch
http://www.ihgplc.com/index.asp?PageID=116&NewsID=2676

Green Engage
http://www.ihgplc.com/index.asp?pageid=742

Energy
http://www.ihgplc.com/index.asp?pageid=749

Water
http://www.ihgplc.com/index.asp?pageid=750

Waste
http://www.ihgplc.com/index.asp?pageid=751

IHG PART OF INDUSTRY CARBON MEASUREMENT INITIATIVE
http://www.ihgplc.com/index.asp?PageID=116&NewsID=2680

CR Index Results
http://www.ihgplc.com/index.asp?PageID=116&NewsID=2635

Green Engage and CDP Score
http://www.ihgplc.com/index.asp?PageID=116&NewsID=2701

Carbon Measurement Initiative
http://www.ihgplc.com/index.asp?pageid=745

In IHG, we believe that strong ethics and good business should go together naturally. We are committed to operating our company with integrity and in accordance with the highest ethical standards.

Our reputation is built upon the trust and confidence of all our stakeholders, and is an integral part of our vision to make IHG one of the very best companies in the world.

This code of ethics and business conduct (‘The Code’) sets out the principles and standards describing how we should work and behave, wherever we are in the world. It applies to all directors, officers and employees of IHG, and should be read together with the company’s core values (our ‘Winning Ways’).

We must all uphold our responsibility to behave ethically and protect the reputation of our company. These principles lie at the heart of who we are, and nothing should ever compromise our commitment to honesty and integrity.

Policies
http://www.ihgplc.com/index.asp?pageid=733

Bribery and Anti-Corruption Policy
1. PRINCIPLE
IHG is committed to operating with honesty and integrity and in compliance with the laws of
the countries in which we do business. IHG does not support or condone corruption.

These guidelines set out IHG’s policy on bribery and corruption and are intended to raise awareness
of relevant international laws. Breach of the policy may lead to disciplinary procedures.

2. THE LEGAL BASIS

While most countries have local laws which will apply in the local territory, UK and US
regulations, in particular, apply internationally, making it an offence to bribe foreign officials
and to give or receive any bribes to obtain or retain any business advantage.

The UK Bribery Act and the US Foreign Corrupt Practices Act prohibit bribery of foreign public
officials. Making any payment or giving anything of value or any advantage to a public official,
with the intention of obtaining or retaining business or an advantage in business, is likely to be
a criminal offence.

The UK Bribery Act also makes it an offence to pay, or offer, or give anything of value, to private
individuals, with the intention that they act improperly in carrying out their office, business or
employment.

Further information on the legal basis is set out in the Legal Questions and Answers available on
Merlin.

A breach of anti-corruption laws is a serious offence and, apart from the reputational damage to
IHG and its brands, can lead to fines and/or imprisonment for individuals and fines for companies.

3. POLICY
IHG does not support or condone corruption. Accordingly all IHG employees and all managed
hotels are required to comply with this policy which sets out IHG’s “minimum standard”. Local
laws may however require a higher standard which must also be complied with.

Bribery and Anti-Corruption Policy

3.1 You Must Not

You must not:
 make any improper cash payment to any public official or any private individual in connection
with any IHG or hotel business. Any cash payment must be properly recorded and accounted for.
 offer, promise or give anything of value, or authorise an improper payment or the giving of
anything of value to any public official or any private individual, to gain improperly a business
advantage or attempt to induce a public official to act
improperly in carrying out their function.
 give any gifts, complimentary arrangements, hospitality, favours or entertainment to public
officials or any private individuals, if it could reasonably be viewed as improperly influencing
business transactions.
It is still likely to be an offence if:
 the official suggested the payment be made;
 payments are not made to the official, but to a related company or party (e.g. his family
member);
 entertainment, gifts, commissions, kickbacks, services or complimentary room nights etc
are given instead of a cash payment;
 nothing is actually handed over, but a payment or other advantage is offered or promised to
the official or private individual; or
 a third party is encouraged or facilitated to make an improper payment.

 pay or give any benefit to a third party if you know (or have reason to believe) that all or
part of the payment or benefit will be passed on to a public official or private individual, to
help obtain or retain business improperly, or to obtain any other improper benefit.
It is still likely to be an offence if inadequate due diligence is done and you choose to ignore
the payments.
 request, agree to, or accept, any financial or other advantage offered to you personally in
connection with any IHG or managed hotel business, unless you have complied with IHG's Gifts and
Entertainment Policy.
 establish any unrecorded “funds” or “budgets” for any purpose.

3.2 You Must

You must:
 conduct appropriate due diligence before entering a business relationship with agents,
intermediaries, consultants and business partners to check they are reputable and qualified.
Further information is set out in the Third Party Due Diligence Guidelines available on Merlin.
 ensure that appropriate records and approvals are kept for all payments, in particular
payments to public officials including:
 accurately recording any payments, gifts, complimentary arrangements, hospitality and
entertainment given to, or received from, public officials, private individuals, or in connection
with corporate hospitality;
 reporting to your local VP Finance any gifts, complimentary arrangements, hospitality
or entertainment given to public officials which
exceed US$500 or local currency equivalent; and
 reporting to your Executive Committee Member any gifts, complimentary arrangements,
hospitality or entertainment given to public officials which exceed US$2000.
 ensure that any gifts to public officials are permitted under local written law.
 challenge any payments which are not supported by the underlying documentation or
transaction.
 keep all other records (including e-mail correspondence) relating to any such payments.

3.3 Facilitation Payments

“Facilitation payments” (also known as “grease payments”) are generally defined as small payments
made to secure or expedite the performance by a low level official of a routine or necessary
action. Such payments may be permissible in extremely limited circumstances under the laws of a few
countries, but it is often very difficult to distinguish between a “facilitation payment” and an
illegal bribe and such payments will be illegal in most countries.

Facilitation payments should not be made. You must consult your regional Head of Legal if you have
any doubts about any payments, before they are made. Further information is set out in the
Facilitation Payment Guidelines available on Merlin.

3.4 Gifts, Favours and Corporate Hospitality

It is in IHG’s best interests to establish mutually beneficial commercial relationships with our
guests, suppliers and business partners. Offering or accepting gifts, entertainment or
personal favours is only acceptable if their value is modest and the practice is consistent with
local business culture.

You Must Not

You must not:
 accept gifts, entertainment or favours which might place you under any obligation or which
would reasonably be viewed as improperly influencing IHG or managed hotel business transactions.
 offer or give any gifts, entertainment or favours to third parties (including public
officials) if they could reasonably be viewed as improperly influencing business
transactions.

You Must

You must:
 comply with the Gifts and Entertainments Policy available on Merlin.
 obtain all appropriate line management approvals for, and keep accurate records of, all
gifts, entertainment and favours given to third parties.
 report any gifts, entertainment and favours given to public officials in accordance with this
policy.

Further information is set out in the Gifts, Entertainment and Corporate Hospitality Guidelines
available on Merlin. If you have any queries or uncertainties about any transactions you must
contact your regional Head of Legal.

3.5 Charitable and Political Donations

IHG supports a variety of activities in the communities where we do business, but we do not make
party political donations. You are free to take part personally in political activities in your own
time but political donations should not be made by IHG or any managed hotel.

Charitable giving should only be done in accordance with IHG’s Corporate Responsibility guidelines
and charitable donations should never be made where it could be viewed as improperly influencing
IHG or managed hotel business.

3.6 Confidential Disclosure Hotline

If you have any concerns over violation of IHG’s Bribery and Anti-Corruption Policy or you suspect
that improper payments have been made or facilitated by IHG employees you should contact the
confidential disclosure channel available on Merlin.

At IHG, we believe that we should always “Do the right thing” and abiding by our Code of Ethics and Business Conduct is a core part of this commitment. Whilst we must all uphold our responsibility to behave ethically and protect the reputation of our company, it is possible that a small minority of our staff may act in a way which conflicts with these standards. We hope that staff will feel able to report any ethical concerns directly to their line managers, HR, or to another member of management at their hotel or office if appropriate. However, IHG also offers a confidential reporting channel to report such incidents, should employees prefer.

The IHG “Confidential Disclosure Channel” provides employees with the mechanism to confidentially report ethical concerns by telephone or online via www.ihgethics.com or by clicking on the Contact the Ethics Line box to the right. Additional information on the confidential reporting channel can be found by clicking the Frequently Asked Questions box to the right.

www.ihgethics.com

Anti-Bribery and Corruption training
IHG's eLearning section contains all of the eLearning course offerings. The listing includes courses developed by IHG and courses offered by our third-party partners which are endorsed by IHG. Bribery and Anti-Corruption training is offered as a course through the eLearning intranet portal.

At IHG we believe that strong ethics and good business are natural partners. We are committed to operating our company with integrity, working to the highest ethical standards. Our reputation is built on the trust and confidence of all our stakeholders, and is fundamental to our vision to make IHG one of the world's great companies.

View our Code of ethics and business conduct - http://www.ihgplc.com/index.asp?pageid=244

More and more of our stakeholders want reassurance that we provide decent working conditions for all of our employees, manage our risks with all our business partners and make sure the rights of the local people where we operate are protected. While we work towards covering these areas in our contract terms and conditions we accept we have much more to do.

In 2010 we signed up to the Global Compact, aligning our operations and strategies with the ten universal principles that include commitments to human rights and labour standards.

Since 2008 we have been developing comprehensive methods to help us assess and respond to human rights issues. All members of the Executive Committee take responsibility for human rights on behalf of the Board.

www.ihgethics.com

https://secure.ethicspoint.com/lrn/media/en/gui/20831/faq.html