Code of Conduct & Workplace Ethics

Compliance with The Law

We are accountable for our actions and we honor our commitments. Our shared goal of honest and ethical action in everything we do drives our success.

We are committed to ensuring that every action we take is in full compliance with the law – and in keeping with our ethics.

Responsibility of Employees

As Sentinel Tech employees, here are just a few ways we can ensure we act ethically in every situation:

• Always be honest in our business dealings internally and externally;

• Always act in accordance with the Code, Company policies and laws and regulations;

Responsibility of Employees

When you face difficult decisions at Sentinel Tech, take the time to think and consider the legal and ethical issues. Don’t give in to pressure and rush your decision. Carefully consider the implications of your actions. Always ask:

• Is it honest and fair?

• Is it consistent with the Code and the law?

• Does it make you feel good about yourself and the Company?

• Would you feel comfortable reading about your action if it is reported in the media?

• No financial targets, production numbers or other individual or corporate goal ever justifies violating the Code or the law.

Responsibility of Managers

Managers have additional responsibilities and serve as role models. Managers lead by example by demonstrating a commitment to acting with integrity every day and ensuring employees feel comfortable asking for help and raising concerns.

Managers are responsible for acting quickly if there is a violation of the Code or the law. If an employee reports a suspected violation, managers must be responsive to employee concerns, taking action when it is appropriate, and seeking help when needed. We want to create an environment where everyone is encouraged to speak out and report concerns in good faith without fear of retaliation

Here are some specific ways that you, as a manager, can fulfill these obligations.

1. Promote an ethical culture through personal leadership

• Do not create or tolerate an environment where staff members feel pressured to bend the rules.

2. Prevent and report problems

• Respond to staff members who raise concerns in a way that makes them feel secure and at ease sharing their issues.

3. Prevent retaliation

• Never engage in retaliatory behavior.

• Ensure employees are not subjected to any reprisals for reporting violations.

The Importance of Speaking Up

A culture that encourages us to voice our opinions and concerns will help us be an ethical company and keep Sentinel Tech a great place to work. If something does not feel right, each of us should feel empowered to act. When you see or suspect misconduct, speak up promptly.

We are committed to treating each other in a fair, respectful and honest manner in all interactions in the workplace. Good communication is a key to successful teamwork. We owe it to each other to be respectful and professional, even when we disagree. Our diversity of people and ideas is what makes us great

Equal opportunity
“We recognize and respect everyone as a unique individual.”

We pride ourselves in having a diverse workplace where each employee is expected to treat others with dignity, courtesy and respect.

We begin by hiring, promoting and compensating employees based on their ability to perform the job, without regard to gender, age, race, color, national origin, religion, sexual orientation or gender identity. We do not tolerate employment discrimination in the workplace.

Harassment-Free Workplace
“We encourage people to treat others the way they want to be treated themselves.”

We strive to create a work environment free of discrimination and harassment. We don’t tolerate bullying, abuse or any behavior that interferes with someone’s work or that creates a hostile work environment. No matter what form harassment takes – whether physical, sexual, verbal or non-verbal, in person, via email, over the phone or on the Internet – it is unacceptable. We do not allow religious staff gatherings or prayer meetings of any faith at our hotels.

We all have a responsibility to know what harassment is so we can report it promptly when we see it. Harassment is offensive conduct that interferes with an employee’s ability to work. Harassment can involve sexual conduct or references to a personal characteristic. Examples include racial slurs, off-color jokes and unwelcome sexual advances. Harassment can occur between members of the same sex or the opposite sex; between vendors, contractors, or employees; and in the office, at off-site work-related events or even outside office hours.

We speak up if we suspect discrimination, harassment or other inappropriate workplace behavior. By providing this information to a manager, Human Resources, or Legal, we help ensure these matters are addressed quickly and we promote the integrity of our workplace.

Religious discrimination is treating individuals differently in their employment because of their religion, their religious beliefs and practices. It also includes treating individuals differently in their employment because of their lack of religious belief or practice. We must be fair and protect not only people who belong to traditional organized religions such as the Christian, Muslim, Jewish, or other faiths, but all people who have sincerely held religious, ethical, or moral beliefs. This also applies to job applicants as well as employees.

Sexual harassment can also be verbal or non-verbal. Words or gestures can be just as offensive as physical acts and contact. Jokes, stories and off-color comments can be sexually harassing and potentially create a hostile work environment.

Sentinel Tech investigates all reports of harassment and keeps these reports as confidential as possible.

Workplace Safety

We all share responsibility for ensuring that Sentinel Tech is a safe and secure place to work. This means we should be aware of our surroundings and participate in emergency preparedness and business continuity planning. We all must follow posted safety procedures and comply with all Company policies and applicable laws. We report injuries and unsafe conditions in a timely manner to our manager. We don’t tolerate workplace violence of any kind, including intimidation or threats. If you see inappropriate behavior, you must speak up immediately.

Drugs and Alcohol

Sentinel Tech is a drug-free workplace. From time to time, the Company may sponsor events where alcohol is served. You are always expected to drink responsibly at Company-sponsored events or choose not to consume alcohol.

Gifts and Entertainment

We never give or receive inappropriate gifts or entertainment. Strong personal and professional relationships with our customers and other business partners are essential to our success. we avoid using gifts and entertainment as a means to improperly influence our business partners.

Accurate Accounts and Records

We have an obligation to our business and others who rely on us, to ensure that our accounts and records are always complete, accurate, timely, and understandable. These records are critical for internal decision making, and for reporting to government agencies and the market. Accurate records protect our reputation for integrity.

This means that we never falsify, forge, backdate, or improperly alter any Company document. We ensure that all transactions are lawful, recorded in the proper account, and in accordance with all Company internal controls. All reports to regulatory authorities must be full, fair, accurate, timely and understandable.

Return of Company Property

We are responsible for all Company property or documents issued to us. We return all such property and documents immediately upon request or upon termination of employment.

Confidential and Proprietary Information

Sentinel Tech’s intellectual property and trade secrets represent significant, strategic investments that are critical to our Company’s success. These assets set us apart from our competitors and include:

• Confidential information about Sentinel Tech, our affiliates, suppliers, customers, and employees;
• Personal data of users, such as contact information, financial data, or other sensitive information, whose use is governed by our Privacy Policies; and
• Our copyrights, trademarks and patents.

To safeguard these assets, we never disclose our confidential information or trade secrets to anyone who does not have a business reason to have the information. We do not disclose such information to others outside the Company without management approval, and we use a non-disclosure agreement or other confidentiality provision approved by Legal to protect the Company’s interests.

Employee Information

We take seriously our responsibility to protect the confidentiality of Employee Personal Information and to safeguard it from improper access, use or disclosure. All information relating to any employee (or former employee) including medical records or employment history is confidential, and we only use that information for relevant and appropriate business purposes. You must not share this information with anyone, either inside or outside Sentinel Tech, who does not have a business need to know it.

Investigations

We investigate reports of observed or suspected Code violations promptly, thoroughly and in accordance with our legal obligations. Confidentiality is maintained to the fullest extent possible. We are all obliged to cooperate with investigations and provide complete, accurate and truthful information. We look to our designated Business Ethics Officers and their delegates to investigate and resolve the issues associated with suspected violations.

Discipline

In order to protect Sentinel Tech and our employees, we take prompt action regarding any conduct that violates the Code and/or the law. We may determine that remedial action (such as training, enhanced controls, coaching or communication) or disciplinary action is necessary. Disciplinary action is reviewed in conjunction with Human Resources and employees’ managers.

Privacy

Customers who entrust us with their personal information expect us to protect their privacy. Privacy matters at Sentinel Tech. Depending on your job responsibilities you may have access to our customers’ personal data, including their contact details, financial account information and transaction data. We must safeguard our customers’ information. Share our customers’ information only for legitimate business purposes.

We do not share customer information with third parties, or any colleague who doesn’t have a business need to know.

Money Laundering

It is critical that we prevent our systems from being used for illegal activities such as money laundering and illicit transactions.

Money laundering is a crime in which the proceeds of criminal activity are moved through a series of financial transactions designed to disguise the true source of funds. If you suspect that a Sentinel Tech service or product is being used to launder funds, you are legally obligated to report the matter to your manager.

Bribery and Corruption

It is illegal for any of our businesses to engage in bribery. We do business on the merits of our services and not based on any form of bribery or unethical business practice. The bribery of any individual, governmental official or otherwise, is a serious matter which can lead to criminal sanctions and financial penalties against our Company and individual employees.

Environmental Stewardship

We view ourselves as environmental stewards. We have a responsibility and a commitment to minimize our direct and indirect impact on natural resources. As such, we promote sustainable commerce, implement green business practices within our operations, and support environmental causes through volunteering and philanthropy.

We comply with applicable environmental laws and Sentinel Tech environmental policies. Our respect for the environment guides us to minimize environmental hazards, conserve and protect natural resources, and manage our energy usage.

Community Involvement and Charitable Contributions

We believe in creating opportunity and making a difference in the world. We balance our business goals with our commitment to communities. We develop meaningful connections through our involvement with civic, charitable and philanthropic organizations.

You should carefully examine any requests to the Company for charitable donations and obtain the necessary approvals for corporate charitable gifts under the Corporate Giving Policy. You should seek proper approval before acting as a Sentinel Tech representative at any community event, donating Sentinel Tech funds or making contributions in Sentinel Tech’s name.