VACATION RENTALS EXPERTS Business Partner Code of Conduct As a leader in travel, vacation rentals and holiday homes properties marketplace, VACATION RENTALS EXPERTS sets high ethical standards for business conduct. We also apply these standards to ourselves and our Business Partners.

The VACATION RENTALS EXPERTS Business Partner Code of Conduct (the “Code”) helps ensure that VACATION RENTALS EXPERTS Business Partners share our commitment to an ethical marketplace.

For the purposes of this Code:

“Vacation Rentals Experts” refers to any VR Experts, VACATION RENTALS EXPERTS GROUP, and any other VR Experts -affiliated entity.

“Business Partners” refers to suppliers that contract to provide VACATION RENTALS EXPERTS with any product or service and other organizations that contract with VACATION RENTALS EXPERTS to accomplish its mission, and includes the employees, agents and contractors of Business Partners.

“Business Partners” does not include VACATION RENTALS EXPERTS Accredited Businesses or VACATION RENTALS EXPERTS National Partners unless they form a contractual relationship with VACATION RENTALS EXPERTS beyond their accreditation by VACATION RENTALS EXPERTS or membership in VACATION RENTALS EXPERTS as apply.

VACATION RENTALS EXPERTS expects that Business Partners will conduct their business with or on behalf of VACATION RENTALS EXPERTS in compliance with the Code. As appropriate, preference will be given to Business Partners that demonstrate greater commitment to this Code and ethical standards generally.

1. Start with Trust Although Business Partners are independent individuals or business entities, their actions may impact and reflect upon VACATION RENTALS EXPERTS. Business Partners should understand and comply with the Business Partner Code and monitor their compliance through their own administrative processes.

2. Maintain Legal and Regulatory Compliance In their work on behalf of VACATION RENTALS EXPERTS Business Partners will conduct their business activities in full compliance with applicable laws and regulations in all jurisdictions in which they operate, including laws and regulations on bribery, corruption and prohibited business practices in the countries in which they conduct business.

Business Partners will not make any offer, payment, consideration or benefit of any kind which constitutes an illegal or corrupt practice, either directly or indirectly on behalf of VACATION RENTALS EXPERTS as an inducement or reward for entering into a contract or in connection with the provision of any goods or services under a contract.

3. Advertise Honestly

3.1 Business Partners that advertise or solicit accreditation, sponsorship or any other financial support on behalf of VACATION RENTALS EXPERTS should ensure that all VR Experts-related advertising or solicitations comply in all respects with V R EXPERTS policies related to accreditation, the VACATION RENTALS EXPERTS Code of Advertising, and all laws, regulations and guides relating to advertising, solicitations, sponsorship and disclosure of non-deductibility of contributions.

3.2 Business Partners may use VACATION RENTALS EXPERTS trademarks logos etc only

(1) to create products, materials or websites for direct use by VACATION RENTALS EXPERTS or

(2) as specifically permitted by VACATION RENTALS EXPERTS policies. Unless VACATION RENTALS EXPERTS has granted permission, Business Partners should not use the VACATION RENTALS EXPERTS name or other VACATION RENTALS EXPERTS marks on Business Partners’ materials, including websites and URLs. Business Partners should not use the VACATION RENTALS EXPERTS name or other VACATION RENTALS EXPERTS marks in a manner that represents or infers Business Partners to be VACATION RENTALS EXPERTS or VR Experts’S Business Partners’ OR employees to be employees of VR Experts.

3.3 VACATION RENTALS EXPERTS does not endorse specific products or services unless specifically provided by VACATION RENTALS EXPERTS policies. Business Partners should not publicize their business relationships with VACATION RENTALS EXPERTS or identify VACATION RENTALS EXPERTS as a customer without specific permission from VACATION RENTALS EXPERTS in writing, and then only in the manner, context and language approved by VR Experts . This provision does not prohibit VACATION RENTALS EXPERTS from participating in affinity programs consistent with VACATION RENTALS EXPERTS policies.

4. Safeguard Data and Privacy

4.1 Business Partners should ensure the security and confidentiality of VACATION RENTALS EXPERTS proprietary information; business, charity, consumer and donor information entrusted to VR Experts; and data about visitors to VACATION RENTALS EXPERTS domains (collectively, “Confidential Information”). Business Partners should have policies and procedures in place to prevent disclosure of Confidential Information to unauthorized parties. In their work on behalf of VACATION RENTALS EXPERTS Business Partners should maintain physical, technical and procedural safeguards in compliance with applicable laws, technology and information security requirements applicable to VR Experts, and any specifications established by VACATION RENTALS EXPERTS for access to VACATION RENTALS EXPERTS information technology systems and VACATION RENTALS EXPERTS domains.

4.2 Business Partners that, and in their work on behalf of VACATION RENTALS EXPERTS interact with visitors to their own websites should disclose in a Privacy Statement/Policy or elsewhere on their websites the following: what information they collect, with whom it is shared, how it can be corrected, how it is secured, how policy changes will be communicated, and how to address concerns over misuse of personal data.

4.3 Business Partners that, in their work on behalf of VACATION RENTALS EXPERTS collect identifying information of businesses or individuals should respect contact preferences regarding contact by telephone, fax and e-mail, and communicate changes in preferences to VR Experts .

4.4 Business Partners that, in their work on behalf of VACATION RENTALS EXPERTS handle payment card information will certify annually their compliance with the Payment Card Industry Data Security Standard (PCI DSS).

4.5 Business Partners that administer VACATION RENTALS EXPERTS email systems will adopt Domain- based Message Authentication, Reporting & Conformance (DMARC) specifications. 4.6 Business Partners whose product or service collects information about or track visitors to any VACATION RENTALS EXPERTS domain will certify that their product or service supports VR Experts ’s compliance with the Digital Alliance Self-Regulatory Principles, including the Self- Regulatory Principles for Online Behavioral Advertising (OBA Principles), the Multisite Data Principles (MSD Principles) and the Mobile Guidance (MG) (collectively, the Principles).

Business Partners that subcontract or otherwise engage other companies to fulfill any obligations under VACATION RENTALS EXPERTS contracts should ensure that such companies’ products or services are also compliant with the Principles.

The Principles can be accessed at (  http://vacationrentalsexperts.pennistonemedia.com/privacy-policy/  ) and here (  http://vacationrentalsexperts.pennistonemedia.com/terms-of-use/  ). Further, Business Partners will not transfer any information collected from any VACATION RENTALS EXPERTS domain for any purpose beyond the scope of activities necessary to fulfil their responsibilities under contracts with VACATION RENTALS EXPERTS without providing to VR Experts’s Chief Information Officer an explanation of the proposed data transfer and use and receiving express permission for such transfer and use.

5. Embody Integrity

5.1 Business Partners should demonstrate commitment to ethical practices in their business conduct and performance of services and production of products on behalf of VR Experts. Business Partners will comply with VACATION RENTALS EXPERTS policies affecting their relationship with VR Experts.

5.2 Business Partners should share VR Experts’s commitment to maintaining a work place where people are treated with dignity and respect. In their work on behalf of VACATION RENTALS EXPERTS Business Partners will follow all applicable wage, benefit, child labor, workplace safety, discrimination and labor laws.

While we recognize and respect cultural differences, in their work on behalf of VACATION RENTALS EXPERTS Business Partners will not engage in discrimination based on age, race, color, religion, sex, gender identity, pregnancy, national origin, citizenship status, disability, sexual orientation, marital status, domestic partner status or veteran status.

5.3 VACATION RENTALS EXPERTS depends on the trust and confidence of our other businesses relationships, our clients, consumers and general respect for others. It is important that we avoid activities that create actual or perceived conflicts of interest.

VACATION RENTALS EXPERTS employees are not permitted to give or receive anything of value intended to influence a decision. Business Partners will not offer gifts that could be perceived to influence sound business judgment.

VACATION RENTALS EXPERTS makes purchasing decisions based on the merit of Business Partners’ products and services, not on gifts, entertainment or other business courtesies.

6. Report Violations of the Code Business Partners should report a possible violation of the Code that directly affects VACATION RENTALS EXPERTS or the transaction with P VR Experts. Business Partners are encouraged to work with their primary contact at VACATION RENTALS EXPERTS (or his or her supervisor) to resolve the situation.

If this is not possible or appropriate, reports may be made to an officer of the contracting VACATION RENTALS EXPERTS entity or the VACATION RENTALS EXPERTS General Counsel / Legal Representatives.

August 14th,2016

 

Vacation Rentals Experts