CDL Hospitality Trusts - Sustainability Report 2022

Whistle Blowing Policy Our Approach The Managers have in place a whistle blowing policy setting out the procedure where staff and directors of the Managers as well as any other third parties can raise concerns in confidence as well as good faith on possible improprieties without fear of reprisals. The whistle blowing policy is made known to all new employees of the Managers as part of their orientation training and is publicly disclosed on CDLHT’s website. For concerns raised, it will be independently investigated and appropriate actions will be taken. There is also an open-door policy at the hotel level maintained by the respective human resource departments for staff to have an open channel to report any incidences of non-compliance or violations. The Managers’ ARCs maintain oversight and review of whistle blowing incidents at its scheduled meetings Our Performance There were no whistle blowing complaints received via CDLHT’s whistle blowing channels. Anti-bribery And Code of Conduct Our Approach CDLHT has zero tolerance for bribery, corruption or fraud. The Managers are committed to conducting business with integrity and in compliance with all applicable laws. Consistent with this commitment, various policies and guidelines are in place to guide all employees of the Managers to maintain the highest standards of integrity in their work and business dealings. There is an Internal Code of Business and Ethical Conduct and a Business Hospitality and Gifts Policy for all employees of the Managers which serve as frameworks for the handling of gifts (monetary or in kind), entertainment or concessionary offerings. All employees also undergo refresher training periodically to re-acquaint themselves with anti-corruption policies and procedures. Our Performance The Managers strive to maintain zero incidences of corruption, bribery and misconduct resulting in significant fines and sanctions. For FY 2022, there were no such incidences reported. We continuously conduct training on relevant policies as part of the orientation for new hires, and keep our employees informed of new related policies and regulations. Compliance With Social And Environmental Regulations As an organisation with a global portfolio, CDLHT is conscious of remaining compliant with all the social and environmental regulations applicable within the countries in which we operate. Our Approach We ensure compliance by continually monitoring changes to requirements through monthly interaction with our hotel operating partners in each country. This process allows each asset to adhere to local and national regulations. Our Performance In FY 2022, CDLHT had zero incidences of non-compliance with social and environmental laws, and no significant fines and sanctions. CDLHT aims to maintain zero incidences of non-compliance with social and environmental laws and regulations which could result in significant fines and sanctions. Data Privacy And Protection Our Approach The Managers have a Data Protection Handbook in place to ensure that personal data processed is subject to certain legal safeguards and restrictions, in line with the Personal Data Protection Act and the Securities and Futures Act in Singapore. At the portfolio level, relevant lessees/hotel managers will also comply with local data and privacy laws in the respective jurisdictions. Our Performance In FY 2022, there were no complaints received by the Data Protection Officer on data privacy breaches for H-REIT Manager and HBT-Trustee Manager. The portfolio properties will continue to ensure upkeep of best practice in data protection measures, both in our Singapore and overseas operations. 107 OVERVIEW AND FINANCIAL REVIEW MARKET REVIEW LEADERSHIP STRUCTURE PROPERTY PORTFOLIO SUSTAINABILITY & GOVERNANCE FINANCIAL STATEMENTS AND OTHER INFORMATION