E-Mail and Internet Policy

Introduction

This policy must be issued to all employees within InterContinental Hotels who are involved or
may become involved in the use of computers. It is intended to safeguard the employee and
the company and ensure the equipment is used properly. Employees have a personal
responsibility in relation to the use of computers and this policy is intended to provide rules and
guidelines to ensure employees meet those responsibilities.

InterContinental Hotels (“Company”) views the Internet and e-mail as essential tools for
employees. However, the use of those tools can expose the organisation to technical,
commercial and legal risks if they are not used sensibly. The aim of this policy document
(“Policy”) is to:

• provide guidance on the use of the internet and e-mail at work to minimise the
Company's exposure to these risks;
• explain what employees can and can't do;
• provide some explanation of the legal risks that employees need to be aware of
in connection with their use of the internet and e-mail;
• to explain the consequences for employees and the Company if rules set out in
this policy are not followed.

ANY BREACH OF THE RULES IN THIS POLICY COULD RESULT IN DISCIPLINARY

ACTION WHICH COULD LEAD TO DISMISSAL. MISUSE OF E-MAIL AND THE INTERNET
AND/OR BREACH OF THIS POLICY COULD ALSO LEAD TO CIVIL OR CRIMINAL
ACTIONS AGAINST INDIVIDUAL EMPLOYEES OR THE COMPANY.

Part A – Employee Usage Rules

Part B – A Guide to the Legal Issues relating to use of E-mail and the Internet
Part C – E-mail Etiquette
Part D – Laptop Security and Best Practice

PART A
Employee Usage Rules

Permitted and prohibited uses

You may use the Company's e-mail system and World Wide Web access for business use
subject to the rules in this Policy. You may also use the Company's e-mail system and
World Wide Web access for personal use provided that such use is kept to a reasonable
level, does not interfere with your job and does not otherwise breach this policy. However,
you must not under any circumstances use any chatlines or bulletin boards on the Internet.

Personal use does not include use for commercial gain or the purposes of any other
business or employment interest.

Where permitted by local law, the Company reserves the right to monitor personal e-mails
against compliance with this code and the law generally.
Offensive Material

You must not under any circumstances use the Company's e-mail system or Internet access
to download, send, receive or view any materials that;

a) could cause offence to any person, for example by reason of

• any sexually explicit content
• any sexist or racist remarks / jokes
• remarks relating to a person's sexual orientation, religion, disability or age

b) you know or ought to know are illegal. (See for example Part B Breach of Copyright and Part B
Obscene Materials)

Monitoring

The Company gives you herewith notice that, wherever permitted by local law, it reserves
the right to monitor and inspect your Internet usage and any e-mails sent by you using the
Company's e-mail system including personal messages at any time. Such monitoring is
intended to ensure that this Policy is being adhered to and is effective and that the Company
and its employees are acting lawfully.

You should therefore use other methods of permitted communication for any messages you
wish to keep private.

All connections to the Internet from the Company are monitored and recorded in log files.
Such monitoring of Internet usage is solely to ensure that this policy is being adhered to and
that the Company and its employees are acting lawfully. These files record information of
which site has been accessed and by whom. They are liable to be checked on a regular
basis.

Confidentiality and sensitive information

Please remember that e-mails are not necessarily a secure way of sending information.

You should also be aware that e-mail messages, like paper based documents, can be
required to be produced in legal proceedings. If you would not like an e-mail to be produced
in court, please refrain from using e-mail. You should assume that every e-mail you send or
receive could potentially be used as evidence in legal proceedings. (See Part B Defamation, Part
B Protection of Personal Data and Part B Unwanted Contracts for further guidance)

Viruses

Certain types of e-mail attachments (e.g. software, computer games, executable files, etc)
and software downloaded from the Internet may contain computer viruses or other harmful
content. This can seriously disrupt the Company's computer systems. The company
therefore reserves the right to block data types commonly associated with these types of
threat.

Furthermore, you must not open, download or copy any e-mail attachments or software from
the Internet or disk unless they have been checked for viruses and harmful content. If you
are in any doubt, contact your IT department. (See also Part B Breach of Copyright)

Any employee who knew or ought to have known that he or she is distributing a computer
virus or any harmful code using the Company's e-mail system may be dismissed, or
otherwise dealt with in accordance with the relevant disciplinary procedure.
Security

Do not in any circumstances disclose your user password to any unauthorised person
outside of the Company's IT help-desk.

Do not impersonate any other employee when sending an e-mail and do not (otherwise than
visibly so as to identify yourself) amend messages received for the purposes of onward
transmission.

You are responsible for the security of your computer and e-mail box and must not allow use
by any unauthorised person.

Do not volunteer to receive e-mail from sites on the Internet. Do not supply your e-mail
address to sites that provide promotional goods or services via e-mail unless there is a real
business need for you to do so.

Never provide your e-mail address on the Web. Advertising your e-mail address in
newsgroups, chat rooms and other public web forums makes it easy for someone else to
send you Unsolicited Email.

Remember. Treat e-mail in the same way as you would treat a letter or fax. Do not e-
mail a message that you would not shout in a crowded room or that you would not
want read out in court.

PART B
A Guide to the Legal Issues
relating to use of E-mail and the Internet

Introduction

This section of the Policy is intended to give employees guidance on the most important
legal issues which may arise from their use of the Company's e-mail system and Internet
access.

It is very important that you read this section to understand those issues as this will help
you, and the Company to avoid problems.

These are not just theoretical issues. If the law is broken then this could lead to one or more
of the following consequences;

• Civil and/or criminal liability for yourself and the Company;

• Disciplinary action against you including your possible dismissal.

Bullying and Harassment

The Company intends that all employees will be treated with dignity at work, free from
harassment and bullying of any kind. Harassment by e-mail could include sending sexist or
racist jokes, making sexual propositions or general abuse.

Harassment can be general bullying, on the ground of sex, race disability, sexual
orientation, age, religion. It can constitute a criminal offence.
Breach of Copyright

Materials that you encounter on the Internet or receive by e-mail are likely to be protected by
copyright. This will apply to written materials, software, music recordings, graphics and
artwork and video clips.

Only the owner of the copyright, or other persons who have the owner's consent, can copy
those materials or distribute them.

If you copy, amend or distribute any such materials without the copyright owner's consent,
then you may be sued for damages by the copyright owner. The Company may also be
liable and, in some circumstances, criminal liability can arise for both you and the Company.

Be particularly careful not to copy text or to download software or music unless you are sure
you have permission to do so. Always check the materials in question to see if they contain
any written prohibitions or permissions before you copy or download them.

Never download any software, music recordings or other materials that you know to be
fakes or "pirate (unauthorised) copies".

Unwanted Contracts

Any exchange of e-mail messages can lead to a contract being formed between yourself, or
the Company, and the other person. Contracts can arise easily; all that is required is the
acceptance of an offer with the intention that legal obligations should arise and some
payment or other consideration being made for the performance of those obligations.
Breach of contract can expose the Company to a claim for damages.

Contracting by e-mail is subject to the same requirements as any other form of contract. You
must adhere to the Company's established policies and procedures about purchasing and
contracting.

Never commit the organisation to any obligations by e-mail without ensuring that you have
the authority to do so. If you have any concerns that what you are doing will form a contract,
contact your legal department. Mark all e-mails relating to actual contractual negotiations
"Subject to Contract".

You should also ensure that any person with whom you wish to enter into a contract is
adequately identified. All e-mail contracts should require the use of digital signature
technology to ensure that their identity is affirmed and to ensure the integrity of the content
of the contract. Please contact your IT department for guidance on the use of digital
signatures, and your purchasing department for information as to your companies approach
to electronic contracts before starting any electronic correspondence which could be
contractual.

Defamation

If you send an e-mail (NB even an internal e-mail), or post any information on the internet,
which contains any remarks which may adversely affect the reputation of another
organisation or person, you will be exposing both yourself and the Company to the risk of
legal action for defamation.

This is a real risk. Other companies have been sued for the defamatory contents of e-mails
sent by employees and have been required to pay out considerable sums as a result.
 You must not therefore send or circulate any materials on the internet or by e-mail that
contain any negative remarks about other persons or organisations unless you are very sure
that what you are saying is not defamatory and is factually correct. If in doubt, do not send it.

Obscene Materials

You must not under any circumstances use the Company's e-mail system or Internet access
to access, display, circulate or transmit any material with a sexual content.
This may constitute a criminal offence and both you and the Company could be liable, it
could also be a serious disciplinary offence.

The display on screen of material with a sexual content and/or its transmission to another
may also amount to sexual harassment - for which you could be liable.

Protection of Personal Data

Please note that the Company is required to comply with legislation concerning the
protection of personal data. Failure by the Company to adhere to that legislation could
expose the Company to civil liability and to enforcement action by the data protection
authorities.

The obligations of the Company under that legislation are complex but you can help ensure
compliance by adhering to the following rules:

• Do not disclose any information about a person in an e-mail or on the Internet

which you would object to being disclosed about yourself.
• Be particularly careful when dealing with information concerning a person's race,
sexual orientation, political beliefs, trade union membership, religion, health or
financial matters.
• Do not send any personal data outside the European Union.

Please refer to the Company's Data Protection Policy for further guidance on this area.

PART C
E Mail Etiquette

In addition to abiding by the formal policy statements above, employees should also adopt the
following etiquette when using e-mail. Please also note any additional best practice guides in
force within your employing division.

Urgent messages should not be sent by e-mail. They are better sent by telephone /
voicemail or pager. Also avoid flagging e-mails to others as urgent – if it’s urgent, pick
up the phone.

Message distribution should be limited to those who are capable of using or actioning
the information contained in the message. Users should resist the temptation to "copy for
information".

Descriptive Titles should be used to describe the contents of the e-mail so that readers
can easily organise and prioritise the selection of e-mails for opening.

One subject per message is encouraged where possible to ensure that filing of
messages needs only to be undertaken once.
 Messages should be polite and as short as possible - remember that e-mails may be
forwarded on to others (only put in an e-mail what you say face to face).

Messages should be formatted for easy reading - white space is not wasted space, it
can greatly improve clarity. Similarly a normal mixture of upper and lower case letters
makes the message easier to read. Messages using all uppercase are difficult to read
and are not recommended.

Attachments - where possible avoid sending more than one or two attachments. This
can waste recipient's time. Attachments should be merged where possible, e.g. two or
more word documents, in order to reduce user time in opening multiple attachments.
However, this will need to be balanced by the effort required on the sender to merge
attachments and potential filing requirements.

Attachments should only be sent to those to whom they are relevant and should never
be used to describe other attachments. They should not be used at all when the
message can be conveyed in the body of the e-mail itself. Where attachments occur the
mail message should include information about the size of the attachment in pages or k
bytes.

Total message size should never exceed 10Mb for any email sent either internally or
to the Internet. If your email exceeds this margin you should consider using an
alternative method for data transfer e.g. burning the data to a CD. If you require
assistance, contact you IT Department.

Digitised Signatures should not be used to sign off any e-mail. They usually take up a
large amount of space and constitute an overhead on the Group's networks during
transmission.

Wide Audience e-mail e.g. event notification, general administrative notices, company
announcements, menus and vacancies should where possible be posted to a bulletin
board for the user to access as and when required thereby leaving the INBOX for
appropriate business use.

Out of Office Assistant should be used appropriately, and where possible give an
alternative means of contact or support.

Avoid sending unnecessary e-mail. If there is no compelling reason to send the mail,
consider not sending it at all. This is good practice. If a recipient associates your address
with unsolicited emails, your e-mails may be ignored.

PART D
Laptops – Security & Best Practice

Laptops - Security

Laptops and other mobile devices carry with them additional security risks. The very fact that
they are portable makes them more prone to being lost or stolen. There are costs associated
with providing replacement hardware. In addition the loss or disclosure of business or personal
information contained on the mobile device may have serious repercussions.

• Laptops and other computer equipment must not be left unattended in vehicles or any public
place. Employees must take reasonable precautions to prevent theft of computer
equipment. The company will investigate any loss of computer equipment and should the
 employee be found to be negligent in their duty to adequately secure the equipment they
may be asked to contribute to the cost of replacement.

• Computer equipment, software or removable media may not be removed from the work site
for any purpose not directly connected to the employee's duties.

• Employees who use computers or computerised equipment shall exercise reasonable care
of the hardware, software and information contained thereon.

• If an IHG technology device provided to an individual is damaged or lost due to negligence

or careless actions of the user, IHG may require the individual to bear the cost of repair or
replacement.

Laptops - Best Practice

When accessing the network via your laptop, there are a few areas of best practice that you
should keep to.

• PAL (dial up) is not free. The "free phone" number if selected means that the surcharge
element of the call is billed centrally but the individual is still accountable for the cost. The
"free phone" surcharge is typically $6/hour opposed to normal usage charges which are
typically $2.10/hour.

• Only use the "free phone" number when working from a hotel bedroom as the call + the
surcharge is likely to be less than the hotel tariff.

• If you are working in a hotel you should always try to access a network connection point to
retrieve your e-mail. If this is not possible, and you use PAL remote access you should use
the normal numbers (contained in the drop down menu) as this will undoubtedly be the most
cost effective method of connection.

• When working from other locations such as home, do not use the "free phone" number as
the normal numbers are cheaper.

• Avoid browsing the Internet when connected remotely. The response will be slow and
remember time costs money.

• Do not leave your PC connected for long periods just to simply send/retrieve e-mail.
- Sign on
- Synchronize
- Sign off
- Work off-line – create and “send” e-mails
- Sign on again – automatically sends e-mails

I confirm I have read and fully understood the above ‘Policy’, and agree to abide by it.

Signed: _____________________________________ Dated: ___________________

PRINT NAME:___________________________________________________________