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GLOBAL CITIZENSHIP AT STARWOOD2015 UPDATE AND GLOBAL REPORTING INITIATIVE (GRI) INDEX

2GLOBAL CITIZENSHIP AT STARWOOD // 2015 GLOBAL REPORTING INITIATIVE INDEX 2

“Doing the right thing” is at the core of who we are, and Global Citizenship remained a priority for Starwood in 2015. It was business as usual for our properties, associates and leaders as we focused on Starwood’s environmental and social responsibility strategy and goals, even during a “business unusual” year for our company.

We made significant progress across many areas of our business as we worked to protect the environment, promote community vitality and mitigate our business risk. We are proud of our 2015 accomplishments and would like to share a few key highlights:

• Starwood continues to drive toward our industry-leading 30/20 by 20 goals to reduce energy consumption by 30%, greenhouse gas emissions by 30% and water usage by 20% by 2020. At the end of 2015, we were more than 50% of the way to our energy goal, almost 75% of the way to our emissions goal and nearly 90% of the way to our water goal, and we’ve saved our owners millions of dollars in utility costs in the process. Additionally, we went the extra step to create a water risk framework that gives us a comprehensive strategy for development and operating in locations with significant water risk issues.

• As part of Starwood’s commitment to Sustainable Food & Beverage, we introduced a comprehensive on-property Sustainable Seafood toolkit, including back-of-house collateral, a resource library and a procurement pocket guide. We also outlined our long-term strategy and goals in a public-facing Seafood Position Statement.

• Starwood’s commitment to Workplace Readiness – both through philanthropic support and our recruitment practices – earned us recognition by the National Fund for Workforce Solutions as a 2015 “Young Adult Employer Champion” for the student internship program we created at our Stamford, CT, headquarters office.

• Starwood celebrated our 20-year partnership with UNICEF, a now-global relationship that began in our European division in 1995 with the launch of Check Out For Children™. Over the past two decades, Starwood hotels, associates and guests have raised more than $30M to improve the lives of vulnerable children around the world.

• We launched an industry-leading Children’s Rights Assessment in Mexico, led by the Starwood Foundation and UNICEF, to fulfill our promise of support for communities where we operate.

At Starwood, we realize the importance of reducing our environmental footprint, supporting the communities in which we operate and bringing financial value to our owners and shareholders, and we are therefore committed to being an exemplary corporate citizen. We are confident that the efforts of our hotels and associates will continue to make a difference in the communities where we work and live.

Andrea Pinabell Vice President, Sustainability

Michelle Naggar Vice President, Social Responsibility

Michelle Naggar

Andrea Pinabell

GENERAL STANDARD DISCLOSURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4

GOVERNANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

ETHICS AND INTEGRITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

SPECIFIC STANDARD DISCLOSURES

ECONOMIC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

ENVIRONMENTAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

SPECIFIC STANDARD DISCLOSURES: SOCIAL

LABOR PRACTICES AND DECENT WORK . . . . . . . . . . . . . . . . . . . . . . . . . 34

HUMAN RIGHTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

SOCIETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

PRODUCT RESPONSIBILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

This report covers Starwood’s Global Citizenship metrics, data and Global Reporting Initiative (GRI) content as of December 31, 2015, unless otherwise noted. This report was compiled using the GRI G4 framework as a guide and contains Standard Disclosures from the GRI Sustainability Reporting Guidelines. We welcome your feedback. Please send any comments or questions to [email protected]

GLOBAL CITIZENSHIP AT STARWOOD // 2015 UPDATE

TABLE OF CONTENTS

mailto:[email protected]

GENERAL STANDARD DISCLOSURES

Indicator Description Response Reported

GLOBAL CITIZENSHIP AT STARWOOD // 2015 GLOBAL REPORTING INITIATIVE INDEX 5


Strategy and Analysis

G4-1 Statement from most senior decision maker. Please refer to page 2 of this document for statement from Starwood’s Vice President, Social Responsibility, and Vice President, Sustainability.

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G4-2 Key impacts, risks and opportunities. Identifying and mitigating risks is essential to safeguarding our license to operate in communities that include some of the world’s most beautiful, remote and ecologically sensitive destinations. At properties in approximately 100 countries, we are developing and promoting resources, programs and opportunities to empower our associates to make choices that promote sustainability, support communities and protect potentially vulnerable populations.

We continue to promote our 30/20 by 20 environmental goals, launched in 2009, which aim to reduce our energy consumption by 30% and water consumption by 20% by 2020, using a 2008 baseline year. In 2013, we added a carbon emissions reduction goal of 30% for the same timeframe. Our critical areas of focus include energy efficiency and diversification, water efficiency and risk, waste reduction and diversion, indoor environmental quality, climate change and GHG emissions, biodiversity and ecosystem health, sustainable food & beverage, sustainable community development, responsible supply chain operations, human rights and human trafficking, disaster response and relief, culture and community preservation, workforce development and employee engagement.

Please visit our Global Citizenship web page for additional information.

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Organizational Profile

G4-3 Name of the organization. Starwood Hotels & Resorts Worldwide, Inc. Fully

G4-4 Primary brands, products and services. Starwood Hotels and Resorts’ brands are some of the most recognized in the world, and as of December 31, 2015, included St. Regis®, The Luxury Collection®, Tribute Portfolio™, W®, Westin®, Sheraton®, Le Méridien®, Four Points® by Sheraton, Aloft® and Element®, along with an expanded partnership with Design Hotels.

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G4-5 Location of the organization’s headquarters. One StarPoint, Stamford, CT 06902 Fully

G4-6 Number of countries where the organization operates and names of countries where either the organization has significant operations or that are specifically relevant to the sustainability topics covered in the report.

As of December 31, 2015, our hotel portfolio included 1,297 properties, providing approximately 369,967 rooms in around 100 countries. There were 704 properties in the Americas, including the Caribbean, 261 properties in Europe, Africa and the Middle East, 317 in Asia Pacific, and 15 Starwood Vacation Ownership resorts.

Starwood applies the same sustainability and social responsibility standards across all market operations. For an up-to-date, detailed list of our properties by country, please visit the Starwood Hotel Directory.

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G4-7 Nature of ownership and legal form. Publicly traded on the New York Stock Exchange under the stock symbol HOT. Fully

G4-8 Markets served (including geographic breakdown, sectors served, and types of customers and beneficiaries).

Starwood serves the travel and tourism markets with a global footprint. Beneficiaries include travel and tourism customers, and hotel owners, as well as the communities and economies in which Starwood operates.

The number of properties by division as of December 31, 2015, was 608 in North America, 96 in Latin America, 261 in Europe, Africa and the Middle East, 317 in Asia Pacific, and 15 Starwood Vacation Ownership resorts.

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G4-9 Scale of organization. 2015 10-K, pp 1–2 Fully

http://www.starwoodhotels.com/corporate/about/citizenship/index.html

http://www.starwoodhotels.com/corporate/directory/hotels/all/list.html

https://starwood.q4web.com/investor-relations/financial-reporting/sec-filings/secC-filings-details/default.aspx?FilingId=11210732




G4-10 Total workforce by employment contract and gender. Starwood employs 188,000 associates at our owned and managed properties, vacation ownership resorts and corporate offices.

Given the global scale of our operations, information on the number of employees by employment type, region of operations and/or gender is not currently available outside of owned and managed operations in North America.

Partially

G4-11 Percentage of total employees covered by collective bargaining agreements. Starwood supports the collective bargaining rights of all of our associates and acts in accordance with local requirements governing collective bargaining. In North America, including Hawaii and Canada, 36% of our workforce is unionized. Starwood supports employees’ rights to join a U.S. union through the secret ballot election process of the National Labor Relations Board (NLRB).

Across our Owned and Managed properties in the European Union (within the Europe, Africa and Middle East division), 30% of our associates are unionized. In Latin America, 57% of our associates at Owned and Managed properties are unionized. In Asia Pacific, 10% of associates at Owned and Managed properties are unionized. Globally, approximately 24% of associates at Owned and Managed properties are unionized.

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G4-12 Describe the organization’s supply chain. Our hotels and resorts use goods and services from more than 100,000 vendors. There are four major categories: Operating Supplies and Equipment, Food & Beverage, Information Technology, and Furniture, Fixtures and Equipment.

The Supply Chain Group manages procurement and is led by our Chief Supply Chain Officer. Starwood outlines supplier performance expectations and uses a variety of policies and procedures to verify that our suppliers uphold our company’s ethical, human rights and environmental standards. Starwood does not have standard global procurement practices; however, the Company published a Supplier Code of Conduct in December 2014. In 2015, 11.2% of our spend in the United States went to diverse vendors.

Please refer to our Supplier Code of Conduct for the minimum standards we expect suppliers to meet and exceed wherever practical and our CDP Supply Chain response for additional information.

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G4-13 Significant changes during the reporting period regarding the organization’s size, structure and ownership, or its supply chain.

During 2015, we added one additional brand, Tribute Portfolio, to our global portfolio, and expanded our partnership with Design Hotels.

On October 27, 2015, Starwood entered into definitive agreements with Interval Leisure Group, Inc. (ILG), pursuant to which our vacation ownership business, to be held by Vistana Signature Experiences, Inc., our wholly owned subsidiary (Vistana), would be spun off to our stockholders, and immediately thereafter Vistana would merge with a wholly owned subsidiary of ILG.

On November 15, 2015, Starwood entered into a definitive agreement to combine with Marriott International, Inc.

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http://www.starwoodhotels.com/Media/PDF/Corporate/SC_Supplier_Letter_-_Code_of_Conduct_Jan15_Final.pdf

https://www.cdp.net/en-US/Results/Pages/Company-Responses.aspx?company=17657




G4-14 Whether and how the precautionary approach or principle is addressed by the organization.

While Starwood does not formally follow the precautionary principle, we have robust risk assessment and management processes intended to ensure that we take a long-term view of Global Citizenship.

To assess risks in future franchise, management and development projects, Starwood applies several different internally developed checklists to each project. During the development process, a checklist is utilized to assess a project’s potential for violation of Starwood’s policies and codes, and business risk due to terrorism and corruption. The results of the checklist inform decisions on moving forward with development projects and mitigating associates’ risks. In addition, the Global Citizenship team has developed two checklists; the first aims to minimize the environmental impact of new construction development projects, and the second aims to minimize the environmental and social risk of the furniture and fixtures specified by our Global Brand Design team.

We also rely on employee grievance mechanisms, our Code of Business Conduct and Ethics and our Supplier Code of Conduct to help assess and manage risk. These codes and additional policies cover corruption and bribery, discrimination, money laundering, insider trading or dealing, health and safety, and whistle blowing. We carefully evaluate and take seriously instances of possible harm to our guests, associates, business partners and the communities where we operate.

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G4-15 Externally developed economic, environmental and social charters, principles or other initiatives to which the organization subscribes or which it endorses.

Our unwavering commitment to provide a respectful and safe work environment for all our associates is evidenced through our Human Rights Policy, issued in 2007 and updated in 2015. Our policy follows the principles of the United Nations (UN) Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human Rights, and applies to all of our owned, managed and franchised hotels. In 2012, in line with the UN doctrine, we began adding a clause into our suppliers’ contracts and conducting targeted audits to ensure that the contracts also comply with our Human Rights Policy. Please refer to our Human Rights Policy and Human Trafficking Position Statement for additional information.

Since 2007, Starwood has reported its GHG emissions to CDP Investor (formerly the Carbon Disclosure Project). We also use the Integrated Hotel Carbon Measurement Initiative (HCMI) as the standard for measuring guestroom night and meeting emissions, and voluntarily report to CDP’s water disclosure questionnaire. Please review our full CDP responses.

In 2009, Starwood published its Environmental Sustainability Policy, most recently updated in 2014 to reflect additional critical areas of focus. In 2012, Starwood published a Sustainable Food & Beverage Policy, also updated in 2014, that includes a global ban on all sales of whale and sea turtle, and an elimination of shark fin consumption throughout Starwood’s food & beverage operations. Starwood’s further commitment to sustainable seafood and ocean health is detailed in its Sustainable Seafood Position Statement, published in 2015. Finally, Starwood’s Supplier Code of Conduct, also released in 2015, outlines certain standards of conduct expected of all Starwood suppliers.

Starwood is often approached to verify ESG data for inclusion on sustainability indexes such as MSCI Global Sustainability Indexes and Newsweek Green Rankings.

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https://s1.q4cdn.com/483583335/files/HOT%20Code%20of%20Business%20Conduct%20and%20Ethics%20(as%20of%20June%202013)_v001_n6vsjt.pdf


https://www.starwoodhotels.com/Media/PDF/Corporate/SC_Supplier_Letter_-_Code_of_Conduct_Jan15_Final.pdf

http://www.starwoodhotels.com/Media/PDF/Corporate/Starwood_Human_Rights_Policy_Statement_Final_12.15.pdf



http://www.starwoodhotels.com/corporate/about/citizenship/reports.html

https://www.starwoodhotels.com/corporate/about/citizenship/esp.html

https://www.starwoodhotels.com/Media/PDF/Corporate/Sustainable.pdf

https://www.starwoodhotels.com/Media/PDF/Corporate/Sustainable.pdf

https://www.starwoodhotels.com/Media/PDF/Corporate/SUSTAINABLE_SEAFOOD_POSITION_STATEMENT_exvf.pdf





G4-16 Memberships in associations (such as industry associations) and/or national/international advocacy organizations in which the organization: * Has positions in governance bodies; * Participates in projects or committees; * Provides substantive funding beyond routine membership dues; or * Views membership as strategic.

The vitality of our business is directly linked to the vitality of our communities. Our commitment to Global Citizenship is aimed at making a lasting difference in the places and destinations where we live and work. Starwood is a member of these associations that help achieve our Global Citizenship goals:

• American Hotel & Lodging Association• Clinton Global Initiative• Conservation International• Human Rights Campaign• International Tourism Partnership• National Oceanic and Atmospheric Administration (NOAA) Sanctuary System• U.S. Green Building Council• Urban Land Institute• Stamford 2030

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Identified Material Aspects and Boundaries

G4-17 All entities included in the organization’s consolidated financial statements or equivalent documents and whether any of these entities is not covered by the report.

Starwood Hotels & Resorts Worldwide, Inc.Starwood Vacation Ownership, Inc.

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G4-18 Explain the process for defining the report content and the Aspect Boundaries and how the organization has implemented the Reporting Principles for Defining Report Content.

Over the past several years, Starwood has made steady progress on developing our Global Citizenship approach. In 2013, we launched a comprehensive stakeholder engagement process and conducted a materiality assessment. We considered Aspect Boundaries within and outside of the organization.

Our stakeholder engagement process focuses on understanding how external stakeholders view our Global Citizenship performance. The results are informative, revealing stakeholders’ priorities, need for additional metrics, and communications about our Global Citizenship efforts.

Please refer to our 2012 Global Citizenship at Starwood Report, pp. 8–13, for additional information.

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http://www.starwoodhotels.com/Media/PDF/Corporate/GC_Report_2014.pdf




G4-19 All the material Aspects identified in the process for defining report content. Based on our internal materiality assessment conducted in 2013, our participation in a stakeholder dialogue with International Tourism Partnership in 2014, and our targeted associate and customer engagement activities in 2015, we continue to focus on the following material Aspects:

• Adaptation• Climate change• Data privacy• Emissions• Energy• Food waste• Human rights overall• Labor standards• Preservation of local heritage• Renewable energy and materials• Resiliency• Security• Social responsibility aspects of goods and services• Solid waste• Sourcing of local products and services• Supply chain• Sustainable construction• Water

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G4-20 The Aspect Boundary within the organization for each material Aspect. The following table summarizes the Aspect Boundary within Starwood for each material Aspect.

Issue GRI G4 (Aspects) Aspect Boundary

Carbon and Emissions Energy Hotel OperationsClimate Change Emissions Hotel OperationsDisaster Preparedness No GRI-Specific Aspects Business Operations, Hotel

Operations and AssociatesEnergy Efficiency and Energy Hotel OperationsDiversificationIndoor Environmental No GRI-Specific Aspects Hotel OperationsQualityResiliency No GRI-Specific Aspects Business OperationsSupply Chain Supplier Environmental Business Operations

AssessmentSustainable Development Governance, Environmental Business Operations

ManagementSustainable Food & Supplier Environmental Hotel OperationsBeverage AssessmentWaste Reduction and Materials Hotel OperationsDiversionWater Efficiency and Risk Water Hotel OperationsWorkforce Development Indirect Economic Impacts, Associates

Labor Practices and Decent Work

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G4-21 The Aspect Boundary outside the organization for each material Aspect. The following table summarizes the Aspect boundary outside Starwood for each material Aspect.

Issue GRI G4 (Aspects) Aspect Boundary

Biodiversity and Biodiversity Local CommunitiesEcosystem HealthCommunity Development Indirect Economic Impacts Local CommunitiesCulture and Community Local Communities Local CommunitiesPreservationDisaster Preparedness No GRI-Specific Aspects Local Communities,

Supply ChainHuman Rights Nondiscrimination, Freedom Local Communities,

of Association and Collective Supply ChainBargaining, Child Labor, Forced or Compulsory Labor

Strategic Philanthropy Indirect Economic Impacts Local CommunitiesSupply Chain Supplier Environmental Supply Chain

Assessment, Supplier Assessment for Labor Practices, Supplier Human Rights, Supplier Assessment for Impact on Society

Sustainable Development Indirect Economic Impacts Local CommunitiesWorkforce Development Indirect Economic Impacts, Local Communities

Labor Practices and Decent Work

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G4-22 The effect of any restatements of information provided in previous reports, andthe reasons for such restatements.

There are no restatements of information from previous reports. Please refer to previous reports for more information.

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G4-23 Significant changes from previous reporting periods in the Scope and Aspect Boundaries.

There are no significant changes in Scope and Aspect Boundaries from previous reports. Fully

Stakeholder Engagement

G4-24 A list of stakeholder groups engaged by the organization. The stakeholder groups we engaged with include investors, governments, guests and customers, nongovernmental organizations (NGOs) and advocacy groups, owners, associates, industry associations, and corporate and nonprofit partners. Some illustrative examples of specific stakeholders we engage with include:

• Investors/Owners: Christian Brothers Investment Services (CBIS), Interfaith Center on Corporate Responsibility (ICCR), Trillium Asset Management, Association of Starwood Franchisees & Owners – North America (ASFONA)

• NGOs: Conservation International (CI), Sustainable Fisheries Partnership, World Resources Institute, UNICEF, Humane Society

• Industry Associations: American Hotel & Lobby Association (AHLA), International Tourism Partnership (ITP), World Travel and Tourism Council (WTTC), Urban Land Institute (ULI), U.S. Green Building Council

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G4-25 The basis for identification and selection of stakeholders with whom to engage.

Engaging stakeholder groups (including investors, governments, guests and customers, nongovernmental organizations (NGOs) and advocacy groups, owners, associates, industry associations and corporate partners) is key to understanding our current impact and planning for the future. Surveys, interviews and questionnaires are used to gather insight from stakeholders and to provide feedback on our operations. Based on the feedback received and our material issues, we select stakeholders with whom to engage through internal discussions. We aim to involve stakeholders with different perspectives that will improve our Global Citizenship program.

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G4-26 The organization’s approach to stakeholder engagement, including frequency of engagement by type and by stakeholder group, and an indication of whether any of the engagement was undertaken specifically as part of the report preparation process.

Engagement with different stakeholder groups varies depending on multiple factors. In some cases, we respond to incoming requests; in others, there are regularly occurring scheduled engagements with specific groups. We conduct targeted engagements with groups like our hotel owners as well as execute one-off types of engagements on an as-needed basis.

We engage with our external stakeholders through various events like meetings, hotel and facility tours, newsletters, conferences, press releases, investor and board meetings, industry associations, surveys and via social media. Internally, we conduct interactive interviews with employees regarding topics such as employee volunteerism and environmental reduction goals.

At the company level, outreach and collaboration with business partners, advocacy groups and nonprofits happen on an ongoing basis. Our engagement with guests and associates happens continually throughout the year. For example:

• We engage investors through calls, meetings and presentations. There have been specific questions around Global Citizenship, though it is a small portion of investor relations’ overall discussions.

• In 2014, guests received a survey post-stay where we inquired about their experience, as well as about their commitment to how they utilized their purchasing power around Corporate Social Responsibility. That survey included information about sustainability.

• To bring Starwood Preferred Guest (SPG®) and associates’ voices into the development of new programs and services, Starwood partnered with C Space (formerly Communispace) to build and operate private online communities. C Space helps brands build direct connections to their customers to improve performance and drive growth. Our goal is to build a better guest experience through this program. In 2015, we conducted a survey (Global Citizenship Perception of Sustainability and Corporate Sustainability at Starwood) of select globally diverse SPG members to gauge customer preference and level of interest in Global Citizenship awareness and perceptions in addition to general awareness, perception, priorities and consumer spending trends with regards to Sustainability and Social Responsibility topics.

• In 2014, Starwood participated in the inaugural International Tourism Partnership (ITP) Stakeholder Dialogue, and we will continue to be involved in this biannual process, the next Stakeholder Dialogue being held in Hong Kong later in 2016.

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G4-27 Key topics and concerns that have been raised through stakeholder engagement and how the organization has responded to those key topics and concerns, including through its reporting. The stakeholder groups that raised each of the key topics and concerns.

Starwood and Global Citizenship have conducted stakeholder assessments, forums and various different forms of engagement based on the stakeholder, topics and other factors. The topics around which stakeholders raised issues in 2015 included diverse aspects such as cage-free eggs, human trafficking and our supplier code of conduct. Due to the wide range of questions and stakeholders, Starwood has actively responded to concerns as they have been raised, in manners best suited to each situation. As an example, multiple stakeholders, including industry groups and NGOs, reached out to us on how our sustainability practices aligned with our supplier practices. As a response, we considered their question(s), and developed and issued a corporate Supplier Code of Conduct.

Key topics and concerns that have been raised include:• Carbon footprint• Energy, water and waste management• Human trafficking• Labor rights• Management of marine and coastal environments• Sustainable food & beverage• Water risk and scarcity

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Report Profile

G4-28 Reporting period for information provided. January 1, 2015–December 31, 2015 Fully

G4-29 Date of most recent previous report (if any). In October 2015, we published a GRI Index G4 covering the 2014 calendar year. Fully

G4-30 Reporting cycle. Annual. Fully

G4-31 The contact point for questions regarding the report or its contents. [email protected] Fully

G4-32 Report the “in accordance” option the organization has chosen; the GRI Content Index for the chosen option and the reference to the External Assurance Report, if the report has been externally assured.

This index contains standard disclosures from the GRI Index G4 Sustainability Reporting Guidelines.

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G4-33 The organization’s policy and current practice with regard to seeking external assurance for the report.

Annually, Starwood obtains independent third-party verification of our 30/20 by 20 data from YR&G Consulting. Lloyd’s Register Quality Assurance provides assurance and verification of our processes for obtaining GHG emissions and water data each year through an audit and site visit approach. The Disclosure Committee of Starwood’s Board of Directors provides final approval of this GRI report.

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mailto:?subject=

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GENERAL STANDARD DISCLOSURES: GOVERNANCE



G4-34 The governance structure of the organization, including committees of the highest governance body. Identify any committees responsible for decision making on economic, environmental and social impacts.

Strong disclosure and checks and balances across our organization are integral to how we do business. Starwood’s Board of Directors is responsible for the global conduct of the company and sets the tone and standards for our properties and associates. Key committees include the Audit Committee, Compensation and Option Committee, Corporate Governance and Nominating Committee (which also has sustainability oversight responsibility) and Capital Committee. A high-level Global Citizenship Steering Committee represents our geographic operating divisions (The Americas – North America and Latin America; Europe, Middle East and Africa; and Asia Pacific), as well as functional departments centralized at our corporate headquarters.

For detailed information on our governance structure and committees, please refer to our 2015 Amended Annual Report (10-K/A), pp. 1–5, 49–50.

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G4-35 The process for delegating authority for economic, environmental and social topics from the highest governance body to senior executives and other employees.

The Global Citizenship team is led by Chief Administrative Officer and General Counsel Ken Siegel. The team regularly monitors and reports on progress to executive leadership, the Starwood Board of Directors, and internal and external stakeholders.

The Vice Presidents of Global Citizenship include Michelle Naggar, VP of Social Responsibility, and Andrea Pinabell, VP of Sustainability. They directly report to Ken Siegel, and in 2015 he reported to CEO Adam Aron, who reported to the Board of Directors.

The Global Citizenship Steering Committee (“Committee”) members consist of divisional and global sustainability and social responsibility champions. These champions have hotel operations, human resources and engineering backgrounds. The Committee convenes monthly with the Global Citizenship team to discuss ongoing programs, efforts, goals, challenges and best practices. The Committee ensures the regional relevance and feasibility of all Global Citizenship initiatives and facilitates the development, execution and communication of these programs. The Global Citizenship team also works with our global Sales, Operations, Development and Brand teams to create effective processes that enable implementation of global projects across the entire hotel portfolio.

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G4-36 Whether the organization has appointed an executive-level position or positions with responsibility for economic, environmental and social topics, and whether post holders report directly to the highest governance body.

Starwood’s Global Citizenship team is responsible for establishing and implementing Starwood’s sustainability and social responsibility strategies worldwide and is led by Chief Administrative Officer and General Counsel Ken Siegel. Mr. Siegel reports to the CEO. Charlene Barshefsky, who chairs the Corporate Governance and Nominating Committee, serves as the point person on the Board of Directors for Global Citizenship issues.

The Global Citizenship team regularly monitors and reports on progress to the Board of Directors and Senior/Executive Leadership Team.

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G4-37 Processes for consultation between stakeholders and the highest governance body on economic, environmental and social topics. If consultation is delegated, describe to whom and any feedback processes to the highest governance body.

Starwood’s Board of Directors is responsible for the global conduct of the company and sets the tone and standard for our properties and associates. One of the key committees of the Board is the Corporate Governance and Nominating Committee, which also has oversight responsibility for Starwood’s Global Citizenship efforts. Stakeholder consultation is delegated by the Governance and Nominating Committee to Chief Administrative Officer and General Counsel Ken Siegel, who leads the Global Citizenship team. Stakeholder engagement occurs through our Global Citizenship Steering Committee and various advisory groups, including the Owner Advisory Board, General Manager Advisory Board, Brand Leaders, Starwood’s Franchise Owners group, NGO partners, etc. The Vice President of Sustainability and the Vice President of Social Responsibility report to the Board of Directors and the Governance and Nominating Committee at least twice a year.

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G4-38 Report the composition of the highest governance body and its committees by:

• Executive or nonexecutive • Independence • Tenure on the governance body • Number of each individual’s other significant positions and

commitments, and the nature of the commitments • Gender • Membership of underrepresented social groups • Competences relating to economic, environmental

and social impacts • Stakeholder representation

Please refer to our 2015 10-K, Part III, for information. Fully

G4-39 Whether the Chair of the highest governance body is also an executive officer (and, if so, his or her function within the organization’s management and the reasons for this arrangement).

Please refer to our 2015 Amended Annual Report (10-K/A), pp. 1–5, 49–50, for information. Fully

G4-40 The nomination and selection processes for the highest governance body and its committees, and the criteria used for nominating and selecting highest governance body members.

Please refer to our 2015 Amended Annual Report (10-K/A), pp. 1–5, 49–50, for information. Fully

G4-41 The nomination and selection processes for the highest governance body and its committees, and the criteria used for nominating and selecting highest governance body members.

Starwood’s Code of Business Conduct and Ethics, which is applicable to all associates, including our Board of Directors, and is signed annually, contains restrictions on conflicts of interest. In addition, Starwood’s Board of Directors must adhere to our Conflict of Interest Policy and Corporate Opportunity & Related Person Transaction Policy.

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https://s1.q4cdn.com/483583335/files/doc_downloads/governance_docs/HOTCorporate%20Opportunity%20Policy%202010.pdf



G4-42 The highest governance body’s and senior executives’ roles in the development, approval and updating of the organization’s purpose, value or mission statements, strategies, policies and goals related to economic, environmental and social impacts.

We maintain strong ethical checks and balances throughout our global organization. Starwood’s Board of Directors has adopted Corporate Governance Guidelines that address issues such as the Board’s composition and committee structure, director responsibilities, qualifications and independence, senior executives performance evaluations, and management-succession planning.

The Board regularly reviews developments in corporate governance and updates Starwood’s Corporate Governance Guidelines and related materials and standards as necessary. The Corporate Governance and Nominating Committee of the Board is responsible for oversight of Global Citizenship issues.

In addition, the Starwood Hotels & Resorts Worldwide Foundation, Inc., is overseen by its own Board of Directors made up of senior executives across Starwood’s organization. The Starwood Associate Relief Fund also has a separate Board of Directors made up of Starwood associates throughout the organization, with a majority of the SARF Directors qualifying as “rank and file.”

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G4-43 The measures taken to develop and enhance the highest governance body’s collective knowledge of economic, environmental and social topics.

The Global Citizenship team is led by Chief Administrative Officer and General Counsel Ken Siegel. Mr. Siegel oversees updates to the Board of Directors and the Governance and Nominating Committee on Global Citizenship issues a minimum of twice a year.

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G4-44 The processes and actions taken for evaluating and reponding to the evaluation of Board performance with regards to governance of economic, environmental and social topics.

The Board of Directors has an annual process for evaluation of performance that is run by the Governance and Nominating Committee and coordinated with third-party legal counsel. The Board self-evaluates on an individual, confidential basis, and an outside firm provides an aggregated feedback report.

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G4-45 Highest governance body’s role in the identification andmanagement of economic, environmental and social impacts, risks and opportunities.

The Board of Directors delegates the management of economic, environmental and social impacts, risks and opportunities to Chief Administrative Officer and General Counsel Ken Siegel, who leads Starwood’s Global Citizenship efforts.

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G4-46 Highest governance body’s role in reviewing the effectiveness of the organization’s risk management processes for economic, environmental and social topics.

The Governance and Nominating Committee of the Board of Directors is ultimately responsible for reviewing the effectiveness of Starwood’s risk management processes as they relate to Global Citizenship efforts.

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G4-47 The frequency of the highest governance body’s review of economic,environmental and social impacts, risks and opportunities.

Starwood’s Global Citizenship team reports to the Board of Directors at least twice per year with a full update on company CSR activities. At quarterly earnings meetings, the Board of Directors reviews a dashboard containing six Starwood goals. Our progress toward the Global Citizenship 30/20 by 20 goals is one of the six goals highlighted.

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G4-48 The highest committee or position that formally reviews and approves theorganization’s sustainability report and ensures that all material Aspectsare covered.

Starwood’s sustainability report is prepared by the Global Citizenship and Global Communications teams in collaboration with Starwood’s global business units. Content is reviewed by global and divisional leadership and the Global Citizenship Steering Committee. Together, Starwood ensures that all material Aspects are covered in the report. The report is reviewed by the CEO, the Chief Administrative Officer and General Counsel, the Chief Human Resources Officer and the Disclosure Committee.

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G4-49 The process for communicating critical concerns to the highest governance body.

Starwood’s Global Citizenship team reports to the Board of Directors at least twice per year with a full update on company CSR activities.

Please refer to our 2015 Amended Annual Report (10-K/A), pp. 49–50, for additional information.

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G4-50 Nature and total number of critical concerns that were communicated to the highest governance body and the mechanism(s) used to address and resolve them.

The top critical Global Citizenship concerns communicated to the Board of Directors in 2015 included water risk, energy cost escalation and availability, and human rights. Addressing these concerns was, and continues to be, a key focus of Starwood’s Global Citizenship strategy.

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G4-51 Remuneration policies for the highest governance body and senior executives, including how performance criteria in the remuneration policy relate to the highest governance body’s and senior executives’ economic, environmental and social objectives.

Please refer to our 2015 Amended Annual Report (10-K/A), pp. 6–45, for information on Board remuneration policies.

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G4-52 Process for determining remuneration. Please refer to our 2015 Amended Annual Report (10-K/A), pp. 6–45, for information on Board remuneration processes.

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G4-53 How stakeholders’ views are sought and taken into account regarding remuneration, including the results of votes on remuneration policies and proposals, if applicable.

Starwood uses compensation consultants to ensure compensation is within set frameworks and market driven. In terms of external stakeholders, hotel owners are allowed to provide feedback on compensation recommendations for certain property roles.

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G4-54 Ratio of the annual total compensation for the organization’s highest-paid individual in each country of significant operations to the median annual total compensation for all employees (excluding the highest-paid individual) in the same country.

Non-Disclosed: This information is not disclosed due to specific confidentiality constraints. Not Disclosed

G4-55 Ratio of percentage increase in annual total compensation for the organization’s highest-paid individual in each country of significantoperations to the median percentage increase in annual total compensation for all employees (excluding the highest-paid individual) in the same country.





GENERAL STANDARD DISCLOSURES: ETHICS AND INTEGRITY


GENERAL STANDARD DISCLOSURES: ETHICS AND INTEGRITY


G4-56 The organization’s values, principles, standards and norms of behavior, suchas codes of conduct and codes of ethics.

With properties in more than 100 countries, our reputation is dependent on daily decisions made across the organization. Our core values – do the right thing, go the extra step, and play as a team – guide our associates in how to interact with guests, customers and other stakeholders. The definition of our value statement includes:

• Go the Extra Step by taking actions that build lasting connections and loyalty.• Play as a Team by working globally and across all teams in the company.• Do the Right Thing by using good judgment and respecting our communities,

associates, owners, partners and the environment.

Please refer to our Company Values Overview, Code of Business Conduct and Ethics, Finance Code of Ethics, Supplier Code of Conduct and Corporate Opportunity & Related Person Transaction Policy for additional information.

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G4-57 The internal and external mechanisms for seeking advice on ethical and lawfulbehavior, and matters related to organizational integrity, such as helplines or advice lines.

Our associates have four avenues to seek advice on ethical and lawful behavior and report ethical concerns. These avenues include:

• Meet in person with a manager, Human Resources representative, the Office of the General Counsel or the Internal Audit office

• Post a message on the 24/7 website HOTEthics.com, anonymously if preferred

• Call Starwood’s 24/7 toll-free helpline from anywhere in the world, anonymously if preferred

• Write to the Audit Committee of the Board of Directors.

Our reporting hotlines are open to external stakeholders including vendors and stockholders. Customer, guest and other external concerns are referred to [email protected]

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G4-58 The internal and external mechanisms for reporting concerns about unethicalor unlawful behavior, and matters related to organizational integrity, such as escalation through line management, whistle-blowing mechanisms or hotlines.

Please refer to our response to G4–57. Fully

http://www.starwoodhotels.com/corporate/about/values/index.html


https://s1.q4cdn.com/483583335/files/doc_downloads/governance_docs/Finance-Code-of-Ethics-(September-2014).pdf




www.HOTEthics.com

SPECIFIC STANDARD DISCLOSURES: ECONOMIC




Economic Performance

G4-DMA Starwood is an owner, operator and franchisor of hotels, resorts and residences across the globe with annual revenues of $5.77 billion in 2015. We set ourselves apart as a company through our people, distinctive brands, providing an exceptional guest experience, and our strong, locally led focus on communities.

For information on our management approaches, please refer to our 2015 10-K, pp. 1–4.

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G4-EC1 Direct economic value generated and distributed, including revenues,operating costs, employee compensation, donations and other communityinvestments, retained earnings and payments to capital providersand governments.

For information on our revenues, operating costs, employee compensation, retained earnings and payments to capital providers and governments, please refer to our financial statements in our 2015 10-K, pp. 2–4, 24–50, 90–98, 105.

Our philanthropic giving enables us to contribute in a way that goes beyond our direct operations. Our approach is aimed at generating positive change on a global scale through cooperation with local communities. We contribute to our communities across 100 countries through targeted philanthropic programs designed to address local priorities.

We carry our philanthropic actions through multiple channels, including corporate giving, the Starwood Foundation, the Starwood Associate Relief Fund (SARF) and property giving. We donated more than USD $5,361,300 to support local and global projects in 2015.The breakdown of giving is as follows:

Corporate giving $883,276Starwood Associate Relief Fund (to 317 associates) $775,513Starwood Foundation(to 25 global and local NGOs) $1,420,433Giving from properties $2,282,078Total (USD) $5,361,300

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G4-EC2 Risks and opportunities posed by climate change that have the potential togenerate substantive changes in operations, revenue or expenditure.

Global climate change presents new risks — both known and unknown – for our operations in communities all over the world. Changes in average air and water temperatures (and the risks associated with these changes) may increase operational costs or lead to changes in guest demand in areas where many of our properties are located. As climate change models predict, rising sea levels and more frequent extreme weather events may cause damage to Starwood hotels in vulnerable locations. We owe it to our guests, associates, owners and the communities we serve to account for climate change in our business strategy.

Climate change risks and opportunities are assessed annually and prioritized in terms of potential materiality and the financial impact on our business as a whole, as well as the likelihood and frequency of occurrence based on each hotel’s climate zone. This assessment by the Global Citizenship team determines the urgency to react to these risks and opportunities, and is executed in partnership with the Operations team.

Please refer to our 2015 10-K, p. 8, and 2015 CDP Investor Report response for additional information.

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G4-EC3 Coverage of the organization’s defined benefit plan obligations. Our goal is to ensure that our associates have everything they need to thrive every day. Through our signature Starwood wellness program, Total Rewards, our associates in eligible positions have access to health and life insurance, retirement savings, continuing education and tuition reimbursement.

Please refer to our 2015 10-K, pp. 90–98, 105 for additional information.

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G4-EC4 Financial assistance from government Non-Disclosed. Not Disclosed

Market Presence

G4-EC5 Ratios of standard entry-level wage by gender compared to local minimum wage at significant locations of operation.

Non-Disclosed. Not Disclosed

G4-EC6 Proportion of senior management hired from the local community at significant locations of operation.

Non-Disclosed. Not Disclosed

Indirect Economic Impacts

G4-EC7 Development and impact of infrastructure and services supported. Starwood has a direct impact on our global stakeholders, including associates, owners, developers and partners throughout our supply chain, and every community in which we have a presence. We pride ourselves on the many ways we share the success of our business. These include the contributions our hotels and resorts make as engines of local economic growth and development, in addition to enhancing tourism, and the impacts we make globally through employment, workforce training, paying taxes, and supporting diverse suppliers and small businesses.

The hospitality industry is responsible, directly and indirectly, for approximately 9.5% of the global economy. This impact has a ripple effect in local communities through taxes, support for small businesses, protection of local natural resources, training and employment.

Through our franchise model, local property owners and entrepreneurs leverage Starwood’s world-class brands to start successful businesses and drive economic growth in their home countries and communities.

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G4-EC8 Significant indirect economic impacts, including the extent of impacts. Delivering a socially and environmentally responsible experience to our guests requires a vast network of suppliers around the world – from local farmers to multinational corporations. When we make small changes to the ways we procure goods and services, the effects are magnified across the 100,000 vendors and partners that make up our supply chain. Our actions to improve supply chain practices often address concerns that are raised by investors, non-profits and suppliers themselves, as well as ensure that guiding principles and policies regarding our supply chain are implemented and adhered to, including our Supplier Code of Conduct.

Our properties around the world engage community organizations in programs and partnerships to preserve culture, and enhance and protect precious ecosystems in addition to their local biodiversity. As a result of this engagement, business is driven to communities for eco-tourism, diving, fishing, hiking and other activities. Near areas of sensitive or preserved ecosystems, such as the marine laboratory in Langkawi, Malaysia, we imbed programs and initiatives to support those ecosystems. In addition, there are other examples, such as the Westin Kids Clubs, which incorporate biophilic design and approaches as well as local cultural and environmental aspects as part of their curriculum.

Our associates embrace the chance to make a difference in the communities where they live and work. Through our volunteer programs, we create value for society and our company while giving associates new experiences and deeper connections to their communities. In 2015, 82% of our properties were actively involved in reporting activities around volunteering in their local communities, collectively giving about 71,105 hours of their time.

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Procurement Practices

G4-EC9 Proportion of spending on local suppliers at significant locations of operation. Whether it is as part of a Global, National, Regional or local contract, where feasible, Starwood strives to enrich local economies by working with diverse suppliers, including artisan vendors. We believe this helps us source a better range of goods to create unique experiences for guests. It also allows us to make informal, sustainable decisions on a local level for that market. For example, in areas or markets where we have multiple properties, one way in which we work to diversify the value chain and utilize local suppliers is through regional procurement services. Within Starwood, a local supplier is defined as a small or large business whose operations are geographically located near the hotel or cluster of hotels. Depending on the product and/or service, they may be in the same neighborhood, city or country. In North America, Starwood supports six regional service hubs, including New York City, Chicago, Boston, Atlanta and Phoenix, that procure over 20% of the total spend for owned, managed and participating franchise hotels.

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SPECIFIC STANDARD DISCLOSURES: ENVIRONMENTAL



G4-DMA Disclosure on Management Approach EN (Environmental Aspects) Our guests value the natural beauty of our properties and their surrounding locations, making it vital to our business to be good stewards of the environment. We seamlessly integrate sustainability into our business in ways that enhance the Starwood experience while improving the efficiency of our operations and addressing local community needs. By reducing our environmental footprint, we aim to play an important part in conserving natural resources and habitats, and maintaining biodiversity in the communities where we operate.

Initiated in 2009, our Environmental Sustainability Policy is based on the following objectives:• Conserve natural resources• Drive sustainable development• Establish and report on key environmental performance indicators• Minimize waste and pollution• Protect ecosystem biodiversity• Raise environmental awareness among our associates, guests and communities

To achieve our energy, emissions and water objectives, we established a goal that aims to reduce energy consumption and greenhouse gas (GHG) emissions per built hotel room by 30% and water consumption by 20% by 2020, from a 2008 baseline. By December 2015, we reduced energy use by 12.84%, carbon emissions by 22.50% and water use by 17.66% per built hotel room across all owned, managed and franchised properties since 2008.

We recognize that the built environment contributes to climate change through energy and resource use. Starwood properties are required to have a third-party energy & water audit and property action plan, and we are developing alternative and renewable energy strategies for all owned, managed, franchised and vacation ownership properties. Element hotels are required to obtain LEED or other another third-party approved certification. As of December 31, 2015, 30 hotels have achieved LEED certification. Further, we fully support our properties that choose to pursue other third-party certifications, including Green Key, where, at the end of 2015, we had 72 certified properties. The Global Citizenship team works closely with the Architecture and Construction team to update standards and specifications to ensure that renovated and new construction properties meet our efficiency and development standards. We are also making adjustments to our fuel mix by selecting fuels with lower emission factors and utilizing more efficient building systems like combined heat and power (CHP) systems. Starwood was the first global hotel company to require franchise properties to report GHG emissions, improving our capacity to address Scope 3 emissions.

Starwood is minimizing waste in more ways than traditional recycling. Some of our properties are growing food on-site to use in restaurants, composting remaining food waste and powering shuttle vehicles with biodiesel fuel made from waste kitchen oil.

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https://www.starwoodhotels.com/corporate/about/citizenship/esp.html



We measure progress against our 30/20 by 20 goals at all properties through our Environmental Impact Assessment System (EIAS+) and an Annual Environmental Impact Survey. We set targets of 100% participation from owned and managed hotels and 75% from franchise hotels for the Annual Environmental Impact Survey. In 2015, 100% of owned, 99.27% of managed and 80.10% of franchise properties completed the survey.

Measuring progress toward our goals also depends on all hotels participating in data collection. In 2015, 100% of owned properties, 98.72% of managed hotels and 71.26% of franchise hotels responded to the annual data-collection process. Overall, 82.6% of global properties completed the survey and participated in data collection.

Materials

G4-EN1 Materials used by weight or volume. Starwood is a hospitality company that owns, manages and franchises hotel properties and is categorized as a service-based organization, therefore this indicator is not applicable.

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G4-EN2 Percentage of materials used that are recycled input materials. Starwood is a hospitality company that owns, manages and franchises hotel properties and is categorized as a service-based organization. However, within supply chain, we currently specify a minimum of 20% pre- and postconsumer content for applicable procured items.

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G4-EN3 Energy consumption within the organization. In 2015, Starwood’s absolute energy consumption was 10,129,483.97 MWh. This number includes data extrapolated for properties that did not report or are unqualified and for all ownership types (owned, managed and franchised) and is broken out as follows:Fuel from nonrenewable sources – 3,823,829.60 MWh (natural gas, gasoline, diesel, propane, #2 fuel oil, #4 fuel oil, anthracite coal, bituminous coal, jet fuel)Fuel from renewable sources – 23,832.31 MWh (bioethanol, biodiesel, biogas)Electricity – 5,386,521.31 MWhHeating – 157,755.16 MWhCooling – 396,101.96 MWhSteam – 341,443.63 MWh

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G4-EN4 Energy consumption outside of the organization. Starwood is a hospitality company that owns, manages and franchises hotel properties and is categorized as a service-based organization, therefore this indicator is not applicable.

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G4-EN5 Energy intensity. In 2015, Starwood’s energy use intensity (EUI) was 113,498 Kbtu per built hotel room. Our 2015 EUI was calculated using validated data from 817 properties (out of 1,297 total properties). This EUI figure encompasses the following energy sources: electricity, steam, chilled water, purchased hot water, natural gas, diesel, propane, gasoline, #2 fuel oil, #4 fuel oil, anthracite coal and bituminous coal, and all of the energy was consumed within the organization.

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G4-EN6 Reduction of energy consumption. In 2015, Starwood’s global energy use per built hotel room declined 0.87% from 2014 (YOY). This reduction was achieved through conservation and energy efficiency initiatives, despite an expanding portfolio. Energy use per built hotel room fluctuated across global regions by the following amounts:

• Asia Pacific: 7.19% decrease• Europe, Africa and the Middle East: 1.88% increase• Latin America: 1.52% increase• North America: 1.70% decrease

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G4-EN7 Reduction in energy requirements of products and services. As of December 2015, Starwood’s global energy use (Kbtu per built hotel room) declined 12.84% compared to 2008. Energy use declined across all of Starwood’s global divisions between 2008 and 2015 by the following amounts:

• Asia Pacific: 18.35% decrease• Europe, Africa and the Middle East: 12.54% decrease• Latin America: 14.53% decrease• North America: 16.54% decrease

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Water

G4-EN8 Total water withdrawal by source. Our properties use water from both municipal water supplies and a variety of nonmetered sources, including surface water, wells and water delivered from other locations or collected from rainwater harvesting. In 2015, 63.87% of Starwood hotels reporting their water consumption were validated for data correctness. For the remaining properties, water use was extrapolated using the metric cubic meters by guestroom.

As of December 2015, Starwood’s global water consumption declined 17.66% per built room compared to 2008. Water consumption declined across all of Starwood’s global divisions between 2008 and 2015 by the following amounts:


In 2015, Starwood’s global water consumption declined 0.48% since 2014 (YOY). Water consumption by global division changed by the following amounts:

• Asia Pacific: 9.36% decrease• Europe, Africa and the Middle East: 4.88% increase• Latin America: 4.92% increase• North America: 2.55% decrease

Starwood’s total water withdrawals for 2015 are 78,706.43 ML and can be broken out as follows:Surface Water – 170.42 MLGroundwater – 483.57 MLBrackish surface water / Seawater – 22.19 MLRainwater – 0.24 MLMunicipal water – 78,030.01 ML

Please refer to our 2015 CDP Water Disclosure response for additional information.

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G4-EN9 Water sources significantly affected by withdrawal of water. Our properties use water from both municipal water supplies and a variety of nonmetered sources, including surface water, wells and water delivered from other locations or collected from rainwater harvesting.

To better understand our water risk globally, we utilize the World Resources Institute’s Aqueduct global mapping tool. The results showed that about 12.48% of our properties are located in areas of high or extremely high overall water risk. We are also developing water conservation measure guidance for all owned, managed, franchised and vacation ownership properties globally.

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G4-EN10 Percentage and total volume of water recycled and reused. The total volume of water recycled in 2015 was 337,363 cubic meters. This total volume represents 0.43% of total water withdrawn.

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Biodiversity

G4-EN11 Operational sites owned, leased, managed in, or adjacent to, protected areasand areas of high biodiversity value outside protected areas.

At the present, Starwood does not have an explicit biodiversity policy at the corporate level, but we included biodiversity as a Critical Area of Focus when we updated our environmental sustainability policy at the end of 2014.

While we have not conducted biodiversity impact assessments, Starwood’s properties that are in UNESCO sites or adjacent to sensitive ecosystems do coordinate locally to ensure proper awareness, compliance and conservation of land and water ecosystems.

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G4-EN12 Significant impacts of activities, products and services on biodiversity inprotected areas and areas of high biodiversity value outside protected areas.

At Starwood, we recognize that our hotels and resorts around the world have a footprint and some of them are located in the world’s most beautiful and species-rich places. While we do not have a formal development-related policy, Starwood recognizes the intrinsic value of our properties in protected areas and areas of high biodiversity value, and we work closely with our owners and local stakeholders to minimize impact and conserve biodiversity. For example, at the Sheraton Grand Rio Hotel & Resort, the property filters all of the surface storm water for both its, as well as other, upstream neighborhoods prior to its being released into the ocean, which protects and conserves the delicate biodiversity of the coast and near-coast ecosystems.

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G4-EN13 Habitats protected or restored. At the corporate level, partnerships with the New England Aquarium, Clean the World, and Conservation International help Starwood reduce its environmental footprint to protect and restore natural habitats, while at the property level, many of our properties work to promote and protect biodiversity. Examples include:

• Le Méridien Bora Bora manages a sea turtle–breeding program that protects and rehabilitates endangered green sea turtles. The program also helps 200 Bora Bora schoolchildren participate in marine wildlife–protection workshops.

• The St. Regis Bahia Beach Resort in Puerto Rico has a prosperous nature program that provides on-site protection of endangered leatherback sea turtles and Caribbean manatees.

• The Andaman, a Luxury Collection Resort, Langkawi, in Malaysia is involved in coral reef conservation. The property has an artificial reef module system that enables conservationists to transplant live coral.

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G4-EN14 Total number of IUCN Red List species and national conservation list species with habitats in areas affected by operations, by level of extinction risk.

One of the major impacts of Starwood operations on Red List species is through our seafood sourcing. In 2015, Starwood launched its Sustainable Seafood Program, which included internal posters and pocket guides that list, by geographical area, seafood species to avoid based on biodiversity and habitat issues, social and health concerns, and international, national and/or scientific endangered/threatened/protected lists.

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Emissions

G4-EN15 Direct greenhouse gas (GHG) emissions (Scope 1). Scope 1: 519,342.67 metric tons CO2e. This includes CO2, CH4, N20 and HFCs. Starwood uses a 2008 baseline year, as this was the first full year in which the organization collected energy data. As of 2015, Starwood’s baseline emissions have not been recalculated. Starwood uses the following carbon emission factor standards:Scope 1 – EPA Climate Leaders Stationary Combustion 2014 UpdateGWP: CO2 – 1; CH4 – 25; N2O – 298 (IPCC Fourth Assessment Report (AR4 – 100 year))Starwood uses The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard as its methodology. Starwood uses an Operational Control boundary for its greenhouse gas inventory.

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G4-EN16 Energy indirect greenhouse gas (GHG) emissions (Scope 2). Location-Based Scope 2: 2,251,117.85 metric tons CO2e.Market-Based Scope 2: 2,307,802.74 metric tons CO2e. Starwood’s Scope 2 emissions factors consist of purchased energy (electricity, steam, chilled water, purchased hot water) from its hotels and corporate office facilities. This includes CO2, CH4, N20 and HFCs. Starwood uses a 2008 baseline year, as this was the first full year in which the organization collected energy data. As of 2015, Starwood’s baseline emissions have not been recalculated. Starwood uses the following carbon emission factor standards:Electricity – International Energy Agency (IEA) (CO2 Emissions from Fuel Combustion 2015 – Year 2013) and US EPA eGRID 2015 (w/2012 data) – AKA eGRID2012Purchased Hot Water, Chilled Water & Steam – US EIA Emission Factors for Steam and Chilled Water; US Energy Information Administration Form EIA – 1605. Voluntary Reporting of Greenhouse Gases – Appendix N.GWP: CO2 – 1; CH4 – 25; N2O – 298 (IPCC Fourth Assessment Report (AR4 – 100 year)Starwood uses The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard as its methodology. Starwood uses an Operational Control boundary for its greenhouse gas inventory.

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G4-EN17 Other indirect greenhouse gas (GHG) emissions (Scope 3).

Scope 3: 1,281,240.01 metric tons CO2e from franchises and Starwood business travel (franchise is equal to 99.05%, and Starwood business travel equals 0.95%).This includes CO2, CH4, N20 and HFCs. Starwood’s franchise emissions consist of the Scope 1 and Scope 2 emissions from Starwood’s franchise hotels. Starwood uses a 2008 baseline year, as this was the first full year in which the organization collected energy data. As of 2015, Starwood’s baseline emissions have not been recalculated. Starwood uses the following carbon emission factor standards:Scope 1 – EPA Climate Leaders Stationary Combustion 2014 UpdateElectricity – International Energy Agency (IEA) (CO2 Emissions from Fuel Combustion 2015 –Year 2013) and US EPA eGRID 2015 (w/2012 data) – AKA eGRID2012Purchased Hot Water, Chilled Water & Steam – US EIA Emission Factors for Steam and Chilled Water; US Energy Information Administration Form EIA – 1605. Voluntary Reporting of Greenhouse Gases – Appendix N.GWP: CO2 – 1; CH4 – 25; N2O – 298 (IPCC Fourth Assessment Report (AR4 – 100 year)Starwood uses The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard as its methodology. Starwood uses an Operational Control boundary for its greenhouse gas inventory.

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G4-EN18 Greenhouse gas (GHG) emissions intensity. Starwood’s GHG emissions intensity ratio is measured on a per built guestroom basis. In 2015, the global ratio was 12.84 mt CO2e / built guestroom. This includes the Scope 1 & 2 emissions from Starwood’s Owned and Managed portfolio, as well as the Scope 3 emissions from Starwood’s Franchise hotels, and this includes the following greenhouse gases: CO2, CH4 and N2O.

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G4-EN19 Reduction of greenhouse gas (GHG) emissions. As of December 2015, Starwood’s global GHG emissions declined 22.50% from a 2008 baseline. GHG emissions declined across all of Starwood’s global divisions between 2008 and 2015 by the following amounts:


In 2015, Starwood’s global GHG emissions per built hotel room declined by 7.66% at owned, managed and franchised properties compared to 2014 (YOY). By global division, GHG emissions per built hotel room changed by the following amounts:

• Asia Pacific: 16.85% decrease• Europe, Africa and the Middle East: 8.51% decrease• Latin America: 4.88% increase• North America: 4.66% decrease

In terms of emissions reduction initiatives that were active within the reporting year (including those in the planning and/or the implementation phases), the following are the total number of projects at each stage of development, and for those in the implementation stages, the estimated CO2e savings:

• Under Investigation – 100 projects with 5,736 total estimated annual CO2e savings in metric tons CO2e

• To Be Implemented – 587 projects with 36,676 total estimated annual CO2e savings in metric tons CO2e

• Implementation Commenced – 9 projects with 202 total estimated annual CO2e savings in metric tons CO2e

• Implemented – 9 projects with 291 total estimated annual CO2e savings in metric tons CO2e

Starwood’s emissions reductions were achieved due to emissions reduction activities and updated emissions factors. Starwood uses The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard as its methodology.

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G4-EN20 Emissions of ozone-depleting substances (ODS). In 2015, Starwood had emissions emanating from one ozone-depleting substance, HCFC-123, totaling 21.50 mt CO2e. The GWP value relative to CO2 (using a 100-year time horizon) used for this calculation came from the IPCC 5th Assessment (2014) and is 79.

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G4-EN21 NOx, SOx and other significant air emissions. Starwood is a hospitality company that owns, manages and franchises hotel properties and is categorized as a service-based organization. In addition, we do not have a corporate fleet or other sources. Therefore, this indicator is not applicable.

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Effluents and Waste

G4-EN22 Total water discharge by quality and destination. Starwood did not calculate its water discharge amounts in 2015. The vast majority of Starwood’s water discharge is domestic sewage. The only relevant water-discharge type would be via groundwater, by way of Starwood’s irrigation practices, but that value has been difficult for Starwood to calculate on a global scale.

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G4-EN23 Total weight of waste by type and disposal method. Non-Disclosed: Starwood is developing mechanisms to track and report these metrics, but data is currently unavailable.

Not Disclosed

G4-EN24 Total number and volume of significant spills. No significant spills reported in 2015. Fully

G4-EN25 Weight of transported, imported, exported or treated waste deemed hazardous under the terms of the Basel Convention2 Annex I, II, III and VIII, and percentage of transported waste shipped internationally.

Hazardous waste was not deemd a material topic according to a 2015 materiality assessment. Fully

G4-EN26 Identity, size, protected status and biodiversity value of water bodies and related habitats significantly affected by the organization’s discharges of water and runoff.

Starwood did not calculate its water discharge amounts in 2015. The majority of Starwood’s water discharge is domestic sewage. Starwood irrigation practices may impact water bodies but have not been deemed a material topic for Starwood.

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Products and Services

G4-EN27 Extent of impact mitigation of environmental impacts of productsand services.

When possible based on its line of business (as Starwood is a service organization), Starwood does endeavor to mitigate the environmental impacts of its products and services. This mitigation is exhibited in many forms, ranging from recycling initiatives to energy and water efficiency programs to offsets. A few of the notable mitigation examples for Starwood that fall within this category are:

• Clean the World (CTW) – Starwood partners with the Clean the World organization to recycle and reuse the soap and shampoo utilized within its properties. CTW takes this partially used and left-behind soap and shampoo, and recycles it into new soap and shampoo products that are made available for hygiene purposes to those in need for either emergency or economic reasons. Since its inception and to the end of 2015, the work between Starwood and CTW has resulted in 524,391 pounds of soap and 433,727 pounds of bottled amenities recycled (over 958,000 pounds of waste diverted from landfills), 2,796,744 new soap bars distributed, 867,454 plastic bottles to the CTW ONE project, and 325,315 pounds of plastic recycled.

• With Starwood’s Make a Green Choice (MAGC) program, guests are given the opportunity to forego housekeeping on a nightly basis. This program allows Starwood to reduce the amount of laundry, as well as the energy and water consumption, during the housekeeping process. A six sigma project was undertaken to determine the environmental savings of this program and identified that for each taker, which is the equivalent of one guest participating in the program for one night, the hotel would save, on average 0.19 kWh of electricity and 25,000 BTUs of natural gas (as well as water and chemical savings). Since its inception (2009) to the end of 2015, this program has saved approximately 1,544,000 kWh of electricity and 2,045,000 therms of natural gas. Using Starwood’s natural gas emissions factor (53.112 kg CO2e/million BTUs – EPA Emissions Factors for Greenhouse Gas Inventories 2014 updated values, GWP – CH4 = 25, NO2 = 298), Starwood and its guests have saved approximately 10,861.40 metric tons of CO2e. Additionally, using the U.S.A. national electricity emissions factor (489.4282 grams CO2/kWh – IEA CO2 Emissions from Fuel Combustion 2015 – Year 2013), this program has saved approximately 760.57 metric tons of CO2e.

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G4-EN28 Percentage of products sold and their packaging materials that are reclaimed by category.

As Starwood is a hospitality company (owns, operates, franchises and manages hotels) and through our 2015 assessment process around materiality, Starwood deemed this area of disclosure not valid upon which to report.

Fully

Compliance

G4-EN29 Monetary value of significant fines and total number of nonmonetary sanctions for noncompliance with environmental laws and regulations.

Starwood does ask for and track input around impacts around noncompliance with environmental laws, both within its annual survey, as well as on an ongoing basis throughout the year, and there were no instances reported that occurred during 2015.

Fully

Transport

G4-EN30 Significant environmental impacts of transporting products, and other goodsand materials used for the organization’s operations and transportingmembers of the workforce.

Starwood has a diverse and expansive supply chain. Engaging with our suppliers to aggregate emissions data from the goods and services we purchase is a challenge that we are working on. Through our work with CDP Supply Chain repsonse, we are hoping to begin using the prescribed best practices for working with some of our largest suppliers on this issue.

We track emissions data related to our associates’ business travels and report them with Scope 3 emissions in our CDP response.

In 2015, five companies for which Starwood is a supplier requested that we submit GHG emissions for their related business with Starwood to CDP Supply Chain.

Fully

Overall

G4-EN31 Total environmental protection expenditures and investments by type. In 2015, Starwood committed USD $75,000 total to fund environmental protection initiatives through global and regional partnerships. The breakdown of funding is as follows:

Water risk $25,000Ocean health and sustainable seafood $50,000Total (USD) $75,000

Additional funding for environmental partners was provided as grants under the Sustainable and Ecological Development focus area of the Starwood Foundation.

Fully

Supplier Environmental Assessment

G4-EN32 Percentage of new suppliers that were screened using environmental criteria. In 2015, 100% of Starwood’s new supplier contracts included our corporate social responsibility clause, which states that vendors must commit to the highest ethical, human rights and environmental standards throughout their organization and in their selection of subcontractors.

New suppliers in high-risk categories, like linens and amenities, are also audited by third-party vendors, including Bureau Veritas (BV), for social criteria. BV’s social compliance audit criteria are based on an audit checklist of 14 key areas for review that are consistent with industry standards.

Fully

G4-EN33 Significant actual and potential negative environmental impacts in the supplychain and actions taken.

Our materiality process identified potentially negative environmental impacts in our supply chain, including GHGs, water consumption, and food and beverage sourcing. While we are in the early stages of tracking these potential negative impacts, we have ongoing strategies for high-risk areas, including a Factory Checklist that is completed by all Furniture, Fixtures and Equipment vendors to highlight potential environmental and social issues as well as vendor best practices. In addition, as part of the RFP process and standard Supply Chain vendor contracts, Starwood requires that vendors uphold our high standards for reducing energy, water and GHG emissions as well as preserving natural resources and biodiversity.

Fully


https://www.cdp.net/en-US/Results/Pages/Company-Responses.aspx?company=17657



Environmental Grievance Mechanisms

G4-EN34 Number of grievances about environmental impacts filed, addressed and resolved through formal grievance mechanisms.

Starwood has several formal mechanisms through which environmental grievances can be filed. Within Starwood’s Code of Business Conduct and Ethics, on pages 37–38, the Code outlines our commitment to Environmental Sustainability and outlines the process through which an associate or individual can submit a grievance, including consulting with one’s supervisor, one’s direct manager or GM, Human Resources, the Office of the General Counsel, Internal Audit or anonymously, where allowed by law, at HOTEthics.com. Anonymous submittals can also be done via toll-free numbers through HOTEthics.

In addition, Starwood has an internal Crisis Communications Team that helps manage environmental grievances that are posted on social media through websites including Facebook, Twitter and Instagram. All postings are monitored, and when a grievance is flagged, it is routed appropriately to ensure that the grievance is addressed.

Partially



www.HOTEthics.com

SPECIFIC STANDARD DISCLOSURES: SOCIAL LABOR PRACTICESAND DECENT WORK



G4-DMA Disclosure on Management Approach LA (Labor Practices and Decent Work Aspects)

Our standard operating procedures facilitate uniform adoption and application of policies on safety, security, the environment and health. These policies cover topics such as workplace violence protection, crisis management and fire protection, and create fundamental standards across our global properties. Starwood policies, resources and training materials are easily accessible to our associates on our global intranet site.

Our policies include:• The Be Safe Associate Program, to ensure our associates are safe and aware of

safety procedures.• Equal Employment Opportunity, to promote diversity and inclusion in our workforce.• We also provide benefits to associates in eligible positions through our Total Rewards

program (see G4-LA2 for additional details).

We collect feedback from employees worldwide through our annual StarVoice survey. We reached a response rate of 96% in 2015, with 86% of our associates saying they were satisfied with Starwood / their hotel as a place to work.

Fully

Employment

G4-LA1 Total number and rates of new employee hires and employee turnover by age group, gender and region.

Depending on hotel management type, different employee-tracking mechanisms are utilized. Starwood has not currently aggregated information from these different systems to provide information on employee hires and turnover based on age, gender and region.

Partially

G4-LA2 Benefits provided to full-time employees that are not provided to temporary or part-time employees, by significant locations of operations.

Starwood is committed to offering benefits programs designed to attract, retain, motivate and reward associates worldwide. We offer competitive wages, health care and incentive plans linked to strong performance.

Offerings vary from country to country, with associates receiving locally competitive packages. In the United States, approximately 47% of our hotel portfolio and therefore a significant location of operation, programs include Health Savings and Flexible Spending Accounts, wellness plans, disability benefits and basic life insurance. U.S. associates can also join a retirement program. Starwood applies benefit offerings to all hotel locations in over 100 countries around the world.

Partially

G4-LA3 Return to work and retention rates after parental leave, by gender. Parental leave coverage regulations differ by country, and Starwood does not currently have a system in place to track global figures of associate utilization of parental leave benefits.

Partially

Labor/Management Relations

G4-LA4 Minimum notice periods regarding operational changes, including whether these are specified in collective agreements.

Non-Disclosed Not Disclosed

Occupational Health and Safety

G4-LA5 Percentage of total workforce represented in formal joint management-worker health and safety committees that help monitor and advise on occupational health and safety programs.


G4-LA6 Type of injury and rates of injury, occupational diseases, lost days and absenteeism, and total number of work-related fatalities, by region and by gender.


SPECIFIC STANDARD DISCLOSURES: SOCIAL LABOR PRACTICES AND DECENT WORK



G4-LA7 Workers with high incidence or high risk of diseases related to their occupation.


G4-LA8 Health and safety topics covered in formal agreements with trade unions. Non-Disclosed Not Disclosed

Training and Education

G4-LA9 Average hours of training per year per employee by gender and by employee category.

We provide various professional development opportunities for associates and managers including eLearning and instructor-led training (ILT). Globally we had 1,685 eLearning and ILT offerings in 2015. Managers averaged 16 ILT hours and nearly 5 eLearning hours. Associates averaged nearly 12 ILT hours and 4 eLearning hours. Starwood does not track employee training by gender.

Fully

G4-LA10 Programs for skills management and lifelong learning that support thecontinued employability of employees and assist them in managingcareer endings.

We support our associates’ following unique career paths through individualized learning and development. From online, individual and classroom experiences to conferences and on-the-job training, we provide opportunities strategically aligned to help associates grow. Our global training programs include:

• Brand Awareness• Compliance Training• Functional Skills Training• General Manager Orientation• Leadership Skills• New Hire Company Orientation• Service Culture

We also help our associates build their career by providing associate development feedback through the 360-degree feedback process.

For associates in our corporate locations, a variety of transition assistance programming is available.

Fully

G4-LA11 Percentage of employees receiving regular performance andcareer-development reviews, by gender and by employment category.

At Starwood, we utilize a variety of talent-management tools to support the ongoing learning and development of our associates and leaders, such as regular performance reviews, succession planning and talent-review meetings, as well as a variety of assessments such as 360-degree planning. It is the expectation that all associates at Owned & Managed hotels and in Corporate locations have regular performance discussions with their managers and are provided ongoing performance feedback. We do not currently track completion of performance reviews by gender or employee category.

Fully

Diversity and Equal Opportunity

G4-LA12 Composition of governance bodies and breakdown of employees per employee category according to gender, age group, minority group membership and other indicators of diversity.

The Starwood Board of Directors represents a diverse body of individuals with a range of professional experience. As of December 31, 2015, we had two female Directors and one Director representing a minority population.

Information on the percentage of employees by gender, age group and other diversity indicators is not currently available by employee category outside of our North America Owned and Managed operations.

Partially




Equal Remuneration for Women and Men

G4-LA13 Ratio of basic salary and remuneration of women to men by employee category, by significant locations of operation.

Non-Disclosed: Starwood is developing mechanisms to track and report these metrics, but data is currently unavailable.

Not Disclosed

Supplier Assessment for Labor Practices

G4-LA14 Percentage of new suppliers that were screened using labor practices criteria. Starwood is launching a new supplier risk program that incorporates labor practices criteria and is currently focused on high-risk probabilities for textiles, and chemicals used in our amenities. The goal of the program is to screen all new suppliers and enhance our audit mechanisms for existing suppliers.

Partially

G4-LA15 Significant actual and potential negative impacts for labor practices in the supply chain and actions taken.

Of the 6 high-risk categories that were identified by an external assessment team, we selected Textiles and Amenities as our initial priority areas, given volume of spend. Within Textiles and Amenities, in 2015 we audited all 26 North America contracted suppliers. An independent third party audits the factories and reviews for noncompliance. The findings are returned to Starwood (yellow/orange/red system based on level of noncompliance), and a Corrective Action Plan (CAP) is provided to the supplier and to Starwood. The third party follows up on the CAP until all noncompliances have been addressed. Occasionally a follow-up audit is required based on the degree of noncompliances found. Starwood would only immediately react to a critical noncompliance and would balance the remaining issues through CAP and/or reinspection.

Partially

Labor Practices Grievance Mechanisms

G4-LA16 Number of grievances about labor practices filed, addressed and resolved through formal grievance mechanisms.



SPECIFIC STANDARD DISCLOSURES: HUMAN RIGHTS



G4-DMA Disclosure on Management Approach HR (Human Rights Aspects) Starwood’s Human Rights Policy, reissued in 2015, commits the company to conducting our business in-line with the principles of the United Nations Universal Declaration of Human Rights. In 2012, we added a clause into our supplier contracts to ensure compliance with our Human Rights Policy.

In 2014, we launched Human Trafficking Awareness Training (see additional details in G4-HR6). As of December 31, 2015, 87% of all owned and managed properties had at least one manager on-property complete the new training. Starwood also conducted a corporate Human Rights Impact Assessment in 2014. Using the results of the assessment, we developed a five-year strategy to address human rights risks and opportunities in our value chain.

In 2015, the Starwood Foundation launched a country-level Human Rights Impact Assessment in Mexico, to identify human and child rights risks and opportunities as a result of the travel and tourism industry.

Starwood properties are often in close proximity to global sports and entertainment venues. These events provide an opportunity to raise awareness of human trafficking risks. We work with industry peers and other partners to eliminate human trafficking by encouraging our guests and associates to report suspicious behaviors.

Fully

Investment

G4-HR1 Total number and percentage of significant investment agreements andcontracts that include human rights clauses or that underwent humanrights screening.

Since 2013, 100% of Starwood vendor contracts originating from the corporate office contain a corporate social responsibility (CSR) clause that states that vendors must commit to the highest ethical, human rights and environmental standards throughout their organization and in their selection of subcontractors. We also require vendors to agree to conduct business in compliance with all applicable laws with respect to labor and human rights including, but not limited to, all laws that support the elimination of exploitative or forced labor. Contracts executed prior to 2013 may have included an earlier version of our CSR clause. The CSR clause is also shared with our divisional teams for use in divisional and/or regional contracts, as appropriate.

Fully

G4-HR2 Total hours of employee training on policies and procedures concerningaspects of human rights that are relevant to operations, including thepercentage of employees trained.

During 2015, Starwood associates globally participated in 12,873 hours of training that addressed human rights risks. Globally, 87%–100% (depending on the training module) of Starwood employees at Owned and Managed hotels and in corporate locations were trained on our Code of Business Conduct and Ethics, which includes our human rights policy and procedures.

Fully

Non-Discrimination

G4-HR3 Total number of incidents of discrimination and corrective actions taken. Non-Disclosed Not Disclosed





Freedom of Association and Collective Bargaining

G4-HR4 Operations and suppliers identified in which the right to exercise freedom ofassociation and collective bargaining may be violated or at significant risk, andmeasures taken to support these rights.

In 2013, we began including a corporate social responsibility clause in vendor contracts, and we finalized a Supplier Code of Conduct in 2014. Our Supplier Code of Conduct and our Human Rights Policy both address labor rights, including freedom of association and collective bargaining. We expect our suppliers to maintain these minimum standards.

In 2014, we also initiated Human Rights and Good Manufacturing Practices audits of a small number of suppliers in higher-risk categories, beginning with textiles and chemicals globally.

In 2015, we issued an enhanced Human Rights Policy that addressed key company and stakeholder group responsibilities with regards to human rights. In addition, the Starwood Foundation partnered with UNICEF to conduct a country-level Human Rights Impact Assessment to identify actual and potential impacts on human and child rights by the hospitality industry in Mexico.

For more information, please refer to our Supplier Code of Conduct and Human Rights Policy.

Fully

Child Labor

G4-HR5 Operations and suppliers identified as having significant risk for incidents ofchild labor, and measures taken to contribute to the effective abolition ofchild labor.

Our Human Rights Policy and our Supplier Code of Conduct prohibit all forms of human trafficking, including the exploitation of children, and all forms of forced, bonded or compulsory labor.

In 2014, we initiated Human Rights and Good Manufacturing Practices audits of a small number of suppliers in higher-risk categories, beginning with textiles and chemicals globally.

In 2015, we issued an enhanced Human Rights Policy that addressed key company and stakeholder group responsibilities with regards to human rights. In addition, the Starwood Foundation partnered with UNICEF to conduct a country-level Human Rights Impact Assessment to identify actual and potential impacts on human and child rights by the hospitality industry in Mexico.


Fully






Forced or Compulsory Labor

G4-HR6 Operations and suppliers identified as having significant risk for incidents of forced or compulsory labor, and measures to contribute to the elimination of all forms of forced or compulsory labor.

As a member of the International Tourism Partnership (ITP), Starwood has committed to uphold ITP’s anti-trafficking policy, provide awareness training, and develop and share best practices. In 2014, we launched our global Human Trafficking Awareness training to all associates at the manager level and above. As of December 31, 2015, 87% of all owned and managed properties had at least one manager on-property complete the training. Our Supplier Code of Conduct also prohibits all forms of human trafficking.

In 2015, we issued an enhanced Human Rights policy that addressed key company stakeholder group responsibilities with regards to human rights. In addition, the Starwood Foundation partnered with UNICEF to conduct a country-level Human Rights Impact Assessment to identify actual and potential impacts on human and child rights by the hospitality industry in Mexico.


Fully

Security Practices

G4-HR7 Percentage of security personnel trained in the organization’s human rights policies or procedures that are relevant to operations.

In 2015, 268 Security personnel at 84 properties were trained in human trafficking awareness. In many properties, Security employees are contracted through third-party firms, therefore we cannot provide the data as a percentage of total employees. Trafficking Awareness Training is available for all employees and required for all managers and above at owned and managed hotels. In addition, Starwood’s Code of Business Conduct and Ethics training, which includes our Human Rights Policy, is required annually for all associates.

Fully

Indigenous Rights

G4-HR8 Total number of incidents of violations involving rights of indigenous peoples and actions taken.


Assessment

G4-HR9 Total number and percentage of operations that have been subject to human rights reviews or impact assessments.

In 2014, Starwood conducted a corporate Human Rights Impact Assessment using the UN Guiding Principles on Business and Human Rights. The assessment addressed potential and actual human rights risk across our operations globally. Using the results of the assessment, we developed a five-year strategy to address human rights risks and opportunities in our value chain.

In 2015, the Starwood Foundation partnered with UNICEF to conduct a country-level Human Rights Impact Assessment in Mexico to identify actual and potential impacts on human and child rights by the hospitality industry. As part of the assessment, over 400 global and local industry stakeholders, including hotel employees and children of employees, were interviewed.

Fully

Supplier Human Rights Assessment

G4-HR10 Percentage of new suppliers that were screened using human rights criteria. Non-Disclosed Not Disclosed

G4-HR11 Significant actual and potential negative human rights impacts in the supply chain and actions taken.


Not Disclosed

Human Rights Grievance Mechanisms

G4-HR12 Number of grievances about human rights impacts filed, addressed and resolved through formal grievance mechanisms.







SPECIFIC STANDARD DISCLOSURES: SOCIETY



G4-DMA Disclosure on Management Approach SO (Society Aspects) The vitality of our business is directly linked to the vitality of our communities. Our commitment to Global Citizenship is aimed at making a lasting difference in the places where we live and work. Starwood and the Starwood Foundation focus our social responsibility efforts on Workplace Readiness, Sustainable & Ecological Development, Disaster Relief, Human Rights and Community Vitality.

In 2014, we launched the Starwood Cares for the Community Portal, with the objective of providing our associates with access to real-time information for volunteering in their local communities. This new portal provides a way for associates to search for volunteer opportunities, sign up for events, track their success and participation, and share best practices.

Once a year, we evaluate our associates’ views of Starwood’s community involvement programs through our associate engagement survey, StarVoice. The 2015 survey showed strong support from managers across the company for associates’ participation in community events, which is consistent with the results from the prior year. Eighty-six% of our associates agree that Starwood management supports participation in events and activities that benefit local communities.

Fully

Local Communities

G4-SO1 Percentage of operations with implemented local community engagement, impact assessments and development programs.

Starwood properties engage communities where we operate. Starwood Cares for the Community is a global volunteerism program that provides associates with coordinated opportunities to become involved in their communities. The Starwood Cares Community Portal is an online system that provides associates access to local volunteer efforts. Associates can track volunteer hours in the portal. In 2015, 72% of Starwood operations had at least one associate active in the Starwood Cares for the Community portal.

Fully

G4-SO2 Operations with significant actual and potential negative impacts on local communities.

Starwood understands that our business can affect natural habitats and resources, local economies and social infrastructure. We do not currently track the number of operations with potential negative impacts on local communities; however, we do have multiple policies in place to avoid and minimize impact, including our Human Rights Policy, Environmental Sustainability Policy and our Antidiscrimination Policy. For more information, please refer to our Policies page on starwoodhotels.com

Fully

Anticorruption

G4-SO3 Total number and percentage of operations assessed for risks related to corruption and the significant risks identified.

Starwood assessed 100% of new property development opportunities for risk of corruption and annually audits its other global operations on a risk-rated basis. Results of assessments inform internal decision-making but are not disclosed due to specific confidentiality constraints.

Fully


http://www.starwoodhotels.com/corporate/about/citizenship/policies/index.html



G4-SO4 Communication and training on anticorruption policies and procedures. In 2014, we added capacity inclusive of the Global Compliance Office, Global Human Resources Ethics function and Internal Audit teams. These resources focus on messaging and support of Starwood’s policies (Code of Conduct, Anticorruption Policy and Finance Code of Ethics) and share responsibility for handling whistle-blower complaints and allegations of wrongdoing submitted through hotlines established and maintained under the Sarbanes-Oxley Act of 2002 and the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Starwood’s Code of Conduct and Anticorruption Policies were refreshed in 2014 for recertification by more than 52,000 associates. In 2015, we achieved a 95% completion rate for all associates and a 100% completion rate for associates titled Vice President and above on the Code of Conduct training. Starwood’s Finance Code of Ethics, updated in 2014, was provided globally to more than 11,000 finance associates in 2015 with a 94% completion rate. The Finance Code of Conduct was distributed to more than 250 of our largest suppliers in North America and distributed by Europe, Africa and Middle East, and Asia Pacific Supply Chain leaders to our other suppliers.

For more information, please refer to our Supplier Code of Conduct and Finance Code of Ethics.

Fully

G4-SO5 Confirmed incidents of corruption and actions taken. Non-Disclosed: This information is not disclosed due to specific confidentiality constraints. Not Disclosed

Public Policy

G4-SO6 Total value of political contributions by country and recipient/beneficiary. In 2015, the Starwood Political Action Committee donated USD $10,000 to various U.S. Congressional candidates, federal election committees and federal political action committees. We contributed $7,500 to 7 Congressional candidates. In addition, a $2,500 donation was made to Hillary for America.

Please refer to the U.S. Federal Election Commission webpage for additional information.

Fully

Anti-Competitive Behavior

G4-SO7 Total number of legal actions for anticompetitive behavior, antitrust and monopoly practices, and their outcomes.


Compliance

G4-SO8 Monetary value of significant fines and total number of nonmonetary sanctions for noncompliance with laws and regulations.


Supplier Assessment for Impacts on Society

G4-SO9 Percentage of new suppliers that were screened using criteria for impacts on society.

In 2013, Starwood utilized a third party to assess over 300 risks in our supply chain. They identified the top 6 risk categories. Starwood then selected the top two categories of textiles and chemicals (liquid amenities) to begin its audit assessments. In 2015, 26 CSR supplier audits were conducted of North America textile and amenity contracted suppliers, utilizing criteria to assess community impact. Given the global nature of our supply chain, audits as a percentage of total suppliers is not available. Please refer to G4-LA15 for additional information.

Partially

G4-SO10 Significant actual and potential negative impacts on society in the supply chain and actions taken.


Not Disclosed

Grievance Mechanisms for Impacts on Society

G4-SO11 Number of grievances about impacts on society filed, addressed and resolved through formal grievance mechanisms.




https://s1.q4cdn.com/483583335/files/doc_downloads/governance_docs/Finance-Code-of-Ethics-(September-2014).pdf

http://docquery.fec.gov/cgi-bin/fecimg/?C00219717

SPECIFIC STANDARD DISCLOSURES: PRODUCT RESPONSIBILITY



Product Responsibility

G4-DMA Describe why the Aspect is material. At a minimum, this includes information on the organization’s impacts, whether positive or negative, related to that Aspect.

Describe any processes the organization used to identify its actual or potential impacts, such as due diligence.

Report how the organization manages the material Aspect or its impacts.

Describe whether the management approach is intended to avoid, mitigate or remediate negative impacts, or enhance positive impacts.

Starwood is a hospitality company that owns, manages and franchises hotel properties and is categorized as a service-based organization. While product responsibility is not an identified material topic for Starwood, the organization utilizes a variety of management approaches for product responsibility through its supply chain management practices, including working directly with vendors to review testing reports, using third-party testing for high-risk product areas and sending out alerts to Starwood properties for listed recalls.

Fully

Customer Health and Safety

G4-PR1 Percentage of significant product and service categories for which health and safety impacts are assessed for improvement.


Not Disclosed

G4-PR2 Total number of incidents of noncompliance with regulations andvoluntary codes concerning the health and safety impacts of products and services during their life cycle, by type of outcomes.

Starwood has not identified any noncompliance with regulations and voluntary codes within this area of disclosure for 2015.

Fully

Product and Service Labeling

G4-PR3 Type of product and service information required by the organization’s procedures for product and service information and labeling, and percentage of significant product and service categories subject to such information requirements.

Starwood has several mechanisms for gathering information on products and services used in our properties. Our global Supplier Code of Conduct applies to all suppliers, and a third-party audit is conducted in areas we identify as high-risk supply chain areas. Starwood’s Furniture, Fixtures and Equipment (FF&E) group has a checklist, used in all factories, that addresses the safe use and disposal of FF&E items in addition to other environmental and social indicators. The FF&E group has its own reporting chain for possible ethics issues and violations in addition to Starwood’s HOTEthics channels.

Information regarding the percentage of total procured services/products subject to these requirements is not currently available.

Partially

G4-PR4 Total number of incidents of noncompliance with regulations and voluntary codes concerning product and service information and labeling, by type of outcomes.


Fully

G4-PR5 Results of surveys measuring customer satisfaction. Starwood provides guests with an opportunity to provide feedback on every stay, whether they decide to do so through surveys, or Ratings & Reviews on our branded websites. The results are used to improve our products and services, and ensure that we are providing our guests with a positive and memorable experience. In addition, our hotels are audited by a third-party inspection firm. These inspections measure compliance with brand standards to ensure that hotels are delivering against our brand-wide quality, conditional and service requirements. Overall, the results and key conclusions from our customer satisfaction surveys and endeavors in this regard have enabled us to know that our ability to meet and exceed expectations is related to performing at, or above, fair market share. We therefore build tools to contain disappointment and to better enable us to meet and exceed customer expectations.

Fully





Marketing Communications

G4-PR6 Sale of banned or disputed products. Starwood has not identified any noncompliance with the sale of banned or disputed products for 2015 and continually strives for awareness and apt handling within this area. As an example, Starwood has received complaints about amenities being produced with micro-beads. Given this, our Supply Chain team researched the amenity products procured and confirmed that our amenities are manufactured with jojoba esters, which are safe for the environment. Starwood continually deals with this area of sensitivity and is considering clarifying product labels.

Fully

G4-PR7 Total number of incidents of noncompliance with regulations and voluntary codes concerning marketing communications, includingadvertising, promotion and sponsorship, by type of outcomes.


Fully

Customer Privacy

G4-PR8 Total number of substantiated complaints regarding breaches of customer privacy and losses of customer data.


Compliance

G4-PR9 Monetary value of significant fines for noncompliance with laws and regulations concerning the provision and use of products and services.

Starwood has not identified any noncompliance with laws or regulations within this area of disclosure for 2015.

Fully


OUR COMPANYNUMBER OF PROPERTIES BY DIVISION IN 2015

180,400 ASSOCIATES

1,297 OWNED, MANAGED OR FRANCHISED HOTELS

15 SVO PROPERTIES

NINE WORLD-CLASS BRANDS

ONE UNIFIED COMMITMENT TO GLOBAL CITIZENSHIP

622NORTH AMERICA

317ASIA PACIFIC

261EUROPE, AFRICA

& THE MIDDLE EAST

97LATIN

AMERICA

49

ABOUT USAt Starwood, our commitment to our local communities and the environment is not only part of who we are, it is also vital for our ongoing business success. We incorporate Global Citizenship work throughout our business, across our brands and at each of our properties around the world.

Our goals, programs and partnerships encourage every associate to be part of something bigger, to do what’s right not only for our business but also for each other, our communities, the environment and the world. By sharing our progress, we promise to continue to provide our guests, associates, customers, communities and owners with a better way to experience the world.

FOR MORE INFORMATION, VISIT SPG.COM/GLOBALCITIZENSHIP

http://spg.com/globalcitizenship

global citizenship at starwood - marriott.com · global citizenship at starwood // 2015 global...

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