CODE OF BUSINESS CONDUCT AND ETHICS

CODE OF ETHICS AND BUSINESS CONDUCT (“Code”)

Introduction

Grand Plaza Hotel Corporation as part of the Millennium & Copthorne Hotels plc (“M&C”) is committed to maintaining the highest possible ethical standards in all its business activities and it is vital to the continued success of the company that we, as employees, behave with honesty, integrity and in compliance with all applicable legal and regulatory requirements. In short, business ethics is relevant both to the conduct of individuals and to the conduct of the organization as a whole.

This policy is issued to all M&C staff worldwide, within all regions, areas and functions and sets out the fundamental standards to be followed by employees in their everyday actions on behalf of the Company describing what each of us can do to safeguard the business including our own reputation. When we are seen to be behaving responsibly and with complete honesty, we can earn the trust and confidence of each other, our customers and suppliers, our shareholders and the communities in which we work.

Further guidance on the Company’s standards in specific areas will be provided through related corporate and regional policies and guidelines, most notably the Anti-Bribery Policy and the Business Hospitality and Gifts Policy.