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BAB434 / AUGUST 2018

Hilton: Combating Human Trafficking in the


Hospitality Industry
Introduction1
In early summer 2018, Maxime Verstraete sat in his office overlooking the plaza of
Hilton’s corporate headquarters in Arlington, Virginia, reflecting on his 16-year career in the
hospitality industry. His first job in a hotel was as a bartender’s assistant for the pool bar at the
Hyatt Grand Hotel in Acapulco, Mexico. Many years later, the last 13 spent with Hilton,
Verstraete had progressed to the position of vice president of corporate responsibility
(CR). The year 2017 involved major changes for both Hilton and for Verstraete personally.
Hilton completed a major corporate restructuring that moved half of its owned properties and
all of its timeshare units out of the company, and Verstraete had been promoted to a new role.
He was now responsible for all of Hilton CR efforts, including sustainability programs, youth
initiatives, and human rights endeavors.2 (See Exhibit 1 for a corporate organizational chart).
Verstraete now was considering many new challenges that lay ahead. One issue in
particular weighed on his mind – how the company would deal with questions of human
trafficking and modern day slavery in the hospitality industry.

About Hilton Worldwide


Hilton Worldwide Holdings, Inc. (Hilton) was a global hospitality company with
more than 360,000 team members working on its behalf around the world.3 Conrad Hilton
founded the company in 1919 when he purchased his first hotel, the 40-room Mobley Hotel in
Cisco, Texas. The company was publicly traded for many decades until it was purchased for
$26 billion and taken private by private equity giant Blackstone Group in July 2007. After
weathering the massive global recession that began shortly after its acquisition, Hilton
relocated its headquarters from Beverly Hills, California, to Arlington, Virginia, and embarked
on a strong recovery. An “asset
1As of July 2018, the company’s formal name was Hilton Worldwide Holdings, Inc.
2 Additional details are available at Hilton’s corporate responsibility website: https://cr.hilton.com/.
3 Team members included both franchised employees and Hilton employees. As of December 2017, approximately

163,000 worked in Hilton corporate offices or at Hilton-owned or Hilton-managed properties. The rest were
employed by independently owned hotels operating as Hilton brands pursuant to franchising arrangements.
This case was prepared by David Nersessian, Associate Professor of Law at Babson College. It was developed as a
basis for class discussion, rather than to illustrate either effective or ineffective handling of a management situation.
The funding for this case was provided by the Teaching Innovation Fund. It is not intended to serve as an
endorsement, a source of primary data, or an illustration of effective or ineffective management.

Copyright © 2018 Babson College and licensed for publication to Harvard Business Publishing. All rights reserved.
No part of this publication may be reproduced, stored, or transmitted in any form or by any means without prior
written permission of Babson College.

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light” strategy focused on non-luxury brands outside the United States fueled new growth. The
growth in overseas management services and franchise arrangements allowed
customers worldwide to find and afford a Hilton at any price point. Blackstone took Hilton
public again in December 2013 in an IPO reflecting an enterprise value of nearly $33 billion,
27% more than Blackstone’s purchase price six years before.
As of December 2017, Hilton offered a portfolio of 14 brands comprising more than
5,284 properties with nearly 856,000 rooms in 105 countries and territories.4 The company
welcomed 160 million guests worldwide in 2017. Hilton competed with other global hotel
chains such as InterContinental Hotels Group, Marriott International, and Wyndham Hotel
Group, as well as with independent hotels and smaller chains in particular markets. Hilton
brands crossed the full hospitality spectrum, offering a wide range of customer experiences in
sleeping rooms (quality, size, furnishings) and guest amenities (restaurants and bars, spa
facilities, meeting and event spaces), depending on budget and location:
 Luxury and lifestyle hotels, such as the Waldorf Astoria Hotels & Resorts, Conrad Hotels
& Resorts, and Canopy
 Full-service hotels, such as Hilton Hotels & Resorts, Curio – A Collection, DoubleTree,
Embassy Suites, and the Tapestry Collection
 Focused-service hotels, such as Hilton Garden Inn, Hampton, Tru, Homewood Suites,
and Home2 Suites
 A timeshare brand, Hilton Grand Vacations
(See Exhibit 2 for more details on Hilton’s brand portfolio).
Hilton’s customer loyalty program, Hilton Honors, had more than 71 million
members who received benefits such as free Wi-Fi, online check-in with Digital Key
(direct to room, skipping the front desk), and flexible direct booking options allowing
members to combine a specific number of Hilton Points with money to pay for stays.
Hilton operated through three business segments: ownership, management, and
franchising. At owned and operated properties, Hilton retained both the real estate and full
control over all hotel operations. Managed hotels were owned by third parties but managed by
Hilton, which operated the property based on a contract with the owner. Franchised hotels were
owned and operated by third parties according to brand standards set out in a franchise
agreement. Franchisees paid Hilton application fees, marketing and program fees, and a variable
royalty depending on hotel profitability. In exchange, Hilton licensed the Hilton brand name and
logo to a franchisee, supported operations through technical assistance, and provided access to a
centralized reservation system and loyalty program membership. Through a separate contract,
franchisees could access Hilton Supply Management services for bulk purchasing of everything
from durable goods to seafood to electricity.
In an effort to sharpen its strategic focus on various segments, in January 2017 Hilton
spun off a substantial portion of its capital-intensive ownership business, consisting of nearly
half of its owned hotels in the United States as well as its timeshare interests. This led to the
formation of two independent, publicly traded companies operating under separate leadership:
Park Hotels & Resorts, Inc. (Park) and Hilton Grand Vacations, Inc. (HGV).

4Unless otherwise specified, data presented in this case was current as of December 31, 2017, as provided in
Hilton’s 2017 Annual Report. Hilton’s Balance Sheets and other financial statements are excerpted at the end of the
case as Exhibits 7-10.
2

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Park, a real estate investment trust (REIT), owned and managed some 70 properties. It
operated as landlord and property manager for residential housing and retail establishments
located within hotel buildings. It also ran the hotels. HGV owned and operated nearly 50
timeshare resorts and had three primary revenue streams: marketing and selling timeshare
intervals, operating timeshare properties and a timeshare membership club, and providing
consumer financing for timeshare purchases. Although Park and HGV were considered
discontinued operations for Hilton itself, both remained directly affiliated through long-term
franchising and licensing arrangements and continued to play a strong role in Hilton’s
worldwide branding presence.
Hilton added more than one hotel daily in 2017 (399 total) and continued to grow
rapidly. As of December 31, 2017, Hilton's development pipeline totaled over 345,000
rooms spread across 2,257 hotels in 107 countries and territories. Some 174,000 of these
rooms involved new construction. More than half of the pipeline (182,000 rooms) was
located outside the United States, including properties in 39 countries and territories
where Hilton had no open hotels. Franchised and managed hotels far outnumbered owned
properties.
Hilton – Market Segments
Hilton Managed for
Type Owned Franchised Third-Party Timeshare
& Managed Owner
Number of
73 4,507 656 48
Properties
Source: Hilton 2017 Annual Report.
The owned and managed segment totaled 22,206 rooms across 73 properties in 2017.
This compared with 833,909 rooms in the franchised, managed, and timeshare segments across
5,211 properties. While much of Hilton’s existing room supply was located within the United
States, most future growth was expected to occur overseas:
Hilton – Rooms by Geographic Distribution

EUROPE, MIDDLE
REGION AMERICAS ASIA PACIFIC
EAST, AFRICA
Existing
Supply 675,000 105,000 68,000

Pipeline 181,000 65,000 99,000


Under
66,000 42,000 66,000
Construction
Source: Hilton 2017 Annual Report.
Despite massive growth and many changes, Hilton’s corporate vision continued as set by
Conrad Hilton himself, "To fill the earth with the light and warmth of hospitality.” (The
company’s vision, mission, and values are reproduced in Exhibit 3).

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About Human Trafficking


According to the International Labour Organization (ILO),5 an estimated 40.3
million people worldwide lived as modern slaves, some 25 million in various forms of forced
labor and 15 million in marriages to which they did not consent. In violation of the most basic
human rights, they lived in reprehensible conditions and worked in industries ranging
from manufacturing, fishing, and mining to domestic servitude. Their wages (if any) were scant,
and these people were treated as movable property with no rights and little regard for their
fundamental dignity as human beings. The transfer of persons in such bondage, often across
international borders, was known as human trafficking.
Human trafficking was the subject of numerous international treaties. One key
instrument was the Palermo Protocol, which supplemented the United Nations Convention
against Transnational Organized Crime.6 The protocol required signatory nations to criminalize
all forms of human trafficking, which it defined as:
[T]he recruitment, transportation, transfer, harbouring or receipt of persons, by means
of the threat or use of force or other forms of coercion, of abduction, of fraud, of
deception, of the abuse of power or of a position of vulnerability or of the giving or
receiving of payments or benefits to achieve the consent of a person having control over
another person, for the purpose of exploitation. Exploitation shall include, at a
minimum, the exploitation of the prostitution of others or other forms of sexual
exploitation, [or] forced labour or services 7
The ILO estimated that trafficking was a $150-billion industry.8 And it was not simply a
problem for the developing world; nearly half of the industry’s net profits came
from industrialized countries. It also was not solely a legal problem. Modern slavery had
roots in complex social, cultural, ethnic, economic, and religious considerations that can vary
considerably from country to country.
Some 16 million persons worldwide were held as “victims of forced labor exploitation in
economic activities such as agriculture, construction, domestic work, and manufacturing.”9
Another dimension of human trafficking involved the global sex trade, where an additional 4.8
million victims, mostly women and children, were forced into prostitution by well-
connected networks of pimps, smugglers, and organized criminals. The ongoing transfer of
enslaved persons was key: perpetrators traded fellow human beings as a means of both
evading detection and increasing profits. Much victimization and sexual exploitation took
place in hotels and other short-term occupancy venues, often unbeknown to the proprietors.

5 International Labour Organization, Global Estimates of Modern Slavery: Forced Labour and Forced Marriage,
September 19, 2017, p.9, http://www.ilo.org/global/publications/books/WCMS_575479/lang--en/index.htm
(retrieved July 27, 2018).
6 United Nations Convention against Transnational Organized Crime, G.A. Res. 55/25, Nov. 15, 2000, 2237 U.N.T.S.

319, Annex II.


7 Protocol to Prevent, Suppress and Punish Trafficking in Persons Especially Women and Children, supplementing

the United Nations Convention against Transnational Organized Crime, Nov. 15, 2000, UN Doc. A/55/383, art.
3(a). 8 International Labour Organization, Profits and Poverty: The Economics of Forced Labour, May 20, 2014,
P.13, https://ec.europa.eu/anti-trafficking/publications/profits-and-poverty-economics-forced-labour-0_en
(retrieved July 27, 2018).
9 International Labour Organization, Global Estimates of Modern Slavery: Forced Labour and Forced

Marriage, September 19, 2017, P.29, http://www.ilo.org/global/publications/books/WCMS_575479/lang--


en/index.htm
4

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(retrieved July 27, 2018).

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Apart from devastating injuries to trafficking victims and their families, sex trafficking
created broad public health impacts, including HIV/AIDS transmission, drug use (often initially
forced on victims by traffickers to keep them docile and under control, but subsequently creating
addiction), pregnancy and children being born into trafficking situations, and linkages to gang
activities and organized crime.
Human trafficking was a criminal offense under federal law of the United States.10 The
Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA) (excerpted in Appendix
1) prohibited involuntary servitude, forced labor, and trafficking individuals to facilitate
these crimes or sexual offenses against the person. It also gave victims the right to recover
damages and attorney’s fees through a civil action in federal court. Claims could be
asserted against perpetrators and anyone else who “knowingly benefits, financially or by
receiving anything of value from participation in a venture which that person knew or should
have known has engaged in an act in violation of [the TVPRA].”11 This could include, for
example, derivative claims against hotel owners / operators based on complicity by their hotel
workers in acts of trafficking and exploitation.
Like all multinational businesses, Hilton’s global operations were subject to the laws of
many countries. Large firms conducting business in the United Kingdom were required to
comply with the Modern Slavery Act 2015 (MSA) (excerpted in Appendix 2). The MSA
criminalized trafficking but also required companies to publish an annual statement detailing
steps taken to prevent modern slavery in their operations and supply chain.12 While the MSA
did not specify compliance standards, it nevertheless created additional risk for a company –
that “consumers, investors and Non-Governmental Organizations [will] engage and/or apply
pressure where they believe a business has not taken sufficient steps.”13
Human trafficking was a global problem, albeit more prevalent in certain parts of
the world than in others. Although on a per capita basis, the greatest number of slaves lived in
Africa, the largest total number of enslaved persons lived in the Asia-Pacific region.14

10 Section 1 of the Thirteenth Amendment to the U.S. Constitution provided that: “Neither slavery nor involuntary
servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the
United States, or any place subject to their jurisdiction.”
11 TVPRA, 18 U.S.C. § 1595(a) (2008).
12 Modern Slavery Act 2015, March 26, 2015, Chapter 30, § 54(1).
13 UK Home Secretary, Transparency in Supply Chains: A Practical Guide (2017), Guidance issued under section 54(9)

of the Modern Slavery Act 2015, p.6, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/


attachment_data/file/649906/Trans parency_in_Supply_Chains_A_Practical_Guide_2017.pdf (retrieved July 20,
2018).
14 International Labour Organization, Global Estimates of Modern Slavery: Forced Labour and Forced Marriage,

September 19, 2017, P.19) (enslaved persons per thousand: Africa – 7.6, Asia-Pacific – 6.1, Europe & Central Asia –
3.9, Arab States – 3.3, and Americas – 1.9), http://www.ilo.org/global/publications/books/WCMS_575479/lang--
en/index.htm (retrieved July 27, 2018.
5

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Hilton: Combating Human Trafficking in the Hospitality Industry
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Worldwide Distribution of Modern Slavery Victims


(~40.3M persons total)
Source: International Labour Organization, Global Estimates of Modern
Slavery: Forced Labour and Forced Marriage, September 19, 2017, p.19

Africa (9.24M) Americas (1.95M)Arab States (0.52M)


Asia-Pacific (24.99M) Europe-Central Asia (3.59M)

9%
23%

5%
1%
62%

Human Trafficking and the Hospitality Industry – Hilton’s


Response
Travel and tourism was one of the world’s largest industries, contributing an estimated
$7.6 trillion (10.2%) to global GDP in 2016, including some 292 million jobs.15 Apart from its
sheer size and impact on labor markets, the hospitality industry was inextricably linked with
trafficking because victims often were exploited in hotel rooms or stayed in hotels during transit.
One study estimated, for example, that in New York City alone, 45% of sexually exploited
youths were victimized in hotels.16
Along with its industry peers, Hilton found itself grappling with the unpleasant reality of
human trafficking. The need to shift gears and enhance efforts in this regard was brought
painfully home to the company through an incident in Chongqing, China. In June 2010, police
discovered a brothel with underage prostitutes operating within an independently-owned
karaoke club located in a Hilton hotel. This incident caused Hilton significant embarrassment
and negative press and led to the hotel’s closure for a period of time. After the Chongqing
incident, Hilton received over 7,500 petitions from Change.org demanding that the company
adopt the model code developed by the anti-trafficking NGO End Child Prostitution and
Trafficking (ECPAT)17 (reproduced in Appendix 3).
Hilton’s experience was part of a broader wave of public sentiment that the hospitality
industry should do more to address human trafficking and sexual exploitation of the vulnerable.
Wyndham Resorts, for example, received 14,000 Change.org petitions after police broke
up a

15 World Travel & Tourism Council, Benchmarking Travel and Tourism,


https://www.wttc.org/economic- impact/benchmark-reports/ (retrieved July 20, 2018) (counting direct
and indirect contributions).
16 No Vacancy For Child Sex Traffickers: Impact Report – The Efficacy of ECPAT-USA's Work to Prevent and Disrupt

the Commercial Sexual Exploitation of Children in Hotels, Sept. 26, 2017, p.7, https://www.ecpatusa.org/novacancy
(retrieved July 20, 2018).
6

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17ECPAT USA, The Tourism Child-Protection Code of Conduct, https://www.ecpatusa.org/code/ (retrieved July
26, 2018).

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child sex trafficking ring operating out of two of its Los Angeles properties, allegedly with hotel
staff assistance at one property.18 Activists seeking clear statements about what hotels were
doing to combat the problem used major high capacity events such as the World Cup and the
Olympics to draw attention to these issues, creating additional logistical problems and other
complications for both corporate officials and individual hotel managers.
At the time of the Chongqing incident, Hilton operations already were aligned with five
out of six principles of the ECPAT code. Corporate responsibility focused on Hilton’s “Travel
with Purpose” program, which engaged primarily with three global social issues: (i)
youth unemployment and opportunity; (ii) community engagement at the local level; and
(iii) the environment, including responsible sourcing and procurement as well as reduction
of carbon, waste, and water footprints. However, the company responded to the
Chongqing incident by conducting a comprehensive internal risk analysis of operations,
policies, and procedures in 2010- 2011. This in turn spurred the development of
partnerships with civil society organizations, training for Hilton team members, and new
policies, procedures, and codes of conduct on human rights and human trafficking.
Hilton signed the ECPAT code in April 2011, making it only the second U.S.-based
hospitality company to do so. Hilton subsequently created several working partnerships with
anti- trafficking NGOs. These included a training program with ECPAT, engaging the
women’s empowerment network Vital Voices, and serving as a board member of the
Global Business Coalition Against Human Trafficking.
In 2014, the company partnered with the Global Fund for Children to create the Hilton
Worldwide Anti-Trafficking Fund, which aimed to help high-risk children overseas to
avoid becoming trafficking victims. In 2015, Hilton also committed to active membership in the
Global Business Initiative on Human Rights. Within an industry organization, the International
Tourism Partnership, Hilton joined the human rights working group. In late 2016, Hilton co-
founded the Stop Slavery Hotel Industry Network in the United Kingdom, which brought
together different actors in the hospitality industry to develop tools to identify and manage risks
of modern slavery.
Through its worldwide internal learning center, Hilton University, Hilton rolled out a
robust training program for managers and other employees to help them recognize signs of sex
trafficking and labor exploitation on Hilton properties. This training was mandatory for general
managers at all Hilton properties, including franchises. Hilton also developed a training module
to help employees identify risks of modern slavery in labor sourcing. The module was rolled out
to all owned/managed hotels in Europe, the Middle East, and Africa. Additional training on the
risks of human trafficking and forced labor in the supply chain appeared in the responsible
sourcing training module, which was mandatory for all procurement leaders, and in the annual
code of conduct training, which was mandatory for all direct employees.
Hilton further engaged in a comprehensive global human rights impact assessment and
supply chain mapping exercise, both of which examined trafficking risks as well as the broader
human rights implications of Hilton’s global operations. This process led to the development of
anti-trafficking corporate policies, such as Hilton’s Human Rights Policy (excerpted in Exhibit
4). Implementation efforts focused on addressing trafficking issues as presenting safety,
security, and compliance risks for hotels. For example, the company updated all contracts with
outsourcing

18 Change.org, Stop Wyndham Hotel Staff from Supporting Child Sex Trafficking in Wyndham Hotels,
8

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https://www.change.org/p/stop-wyndham-hotel-staff-from-supporting-child-sex-trafficking-in-wyndham-hotels
(retrieved July 20, 2018).

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agencies contracting with owned and managed properties in Europe, the Middle East, and Africa,
to require an audit on such issues every two years.
Hilton continued to address the risks of human trafficking in other aspects of its business
operations. Despite the social repugnance and high-profile nature of such offenses,
Hilton’s internal analyses revealed that enterprise risks arising out of sexual exploitation
on Hilton- branded properties were relatively low, although ongoing training and
monitoring remained essential. Verstraete and his team thus increasingly turned their attention
to other dimensions of human trafficking and modern slavery in the hospitality industry,
including risks arising outside the United States. This involved mitigating other trafficking
risks associated with: (i) Hilton’s extensive supply chain for purchasing, especially from
higher risk industries such as seafood and agriculture; (ii) violations in the labor markets for
hotel workers, such as debt bondage for individuals recruited or subcontracted through
unscrupulous labor brokers; and (iii) major construction projects for new hotels around the
globe.19
To address these risks, Hilton set out a Code of Conduct (excerpted in Exhibit 5) for
direct employees, with the expectation that business partners, such as suppliers and franchises,
also would uphold its principles. The Code provided expressly that “Hilton must never allow any
Hilton properties, products, or services to be used in any manner that supports or enables any
form of abuse and exploitation.” The Code of Conduct also detailed Hilton’s commitments to
human rights and labor rights.
The commitments in Hilton’s Code of Conduct were mirrored in the company’s
Responsible Sourcing Policy (reproduced at Exhibit 6), which guided its procurement of all
goods and services. Hilton’s policy also encouraged, but did not require, suppliers to hold their
own subcontractors and suppliers to the same commitments Hilton specified for its own
supplier relationships. Engaging with its supply chain remained an ongoing area of focus and
commitment, and Hilton continued to develop its strategy to reach different tiers of suppliers
(such as its own suppliers’ subcontractors and sub-suppliers).
Another important limitation on Hilton’s policies and procedures was that they were
limited to Hilton employees, defined as employees working at Hilton corporate headquarters
and at its owned and managed properties. This was due to the structure of franchise agreements,
where franchises were legally responsible for development and implementation of management
policies. In certain cases, applicable law and/or contractual restrictions limited Hilton’s ability
to prescribe certain behaviors to franchises. But because the risks of human trafficking
continued to threaten Hilton’s brand in all ownership categories worldwide, the company
needed to determine how best to address human trafficking risks at franchised locations as well.

Conclusion
Verstraete knew he had a lot to think about. What were the most important issues to
tackle first, and what decisions should be made about them? How could Hilton sustain
momentum in its anti-trafficking efforts and align its policies across all company functions? And
what implications did Hilton’s efforts in anti-trafficking have for broader questions of human
rights and business? From a strategic perspective, how far outward in its extended supply chains
for goods and services should Hilton try to manage trafficking issues? How could Hilton extend
anti-

19 Hilton did not build its own franchised hotels. Owners hired builders and controlled the entire construction
8

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process. However, Hilton’s name was on the new building and therefore was associated with the project and its
manner of construction throughout.

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trafficking initiatives to franchisees, particularly those operating in parts of the world where
labor violations were far more common?
Once decisions were made, how could anti-trafficking measures be implemented (people,
processes, and systems / tools)? How could such measures ensure that Hilton could continue to
enhance guest experience, grow its pipeline of new hotels and affiliates, limit legal risks and
liability, and return value to shareholders? Was the CR department optimally positioned within
the Hilton organization to achieve these aims, and what internal departments and personnel
must Verstraete bring on board in order to succeed? How did requirements and desires of
external stakeholders – national, regional, and local governments, industry groups, and NGOs
and advocacy organizations – come into play as potential roadblocks or helpful partners?
Apart from the issues Verstraete already was aware of, one question troubled him even
more when it came to human trafficking in the hospitality industry: What don’t I see?

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Exhibit 1
Hilton Organizational Chart

CEO

Global
LegalCorporate EMEAAmericasAsia- ChiefChief Development, Customer
CFO HR Affairs Commercial Architecture,
Pacific OfficerOfficerDesign &
Construction

Corporate
Responsibility

Communications

Government
Affairs

Source: Company Interviews. Additional details are available at: http://ir.hilton.com/corporate-


governance/management (retrieved July 20, 2018).

10

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Exhibit 2
Hilton’s Brand Portfolio
Countries / % of
Brand Chain/Scale Properties Rooms Selected Competitors
Territories Total
Four Seasons, Mandarin
Waldorf
Luxury 12 27 9,579 1.1% Oriental, Peninsula, Ritz
Astoria Carlton, St. Regis
Fairmont, Intercontinental,
Conrad Luxury 24 34 10,709 1.3% JW Marriott, Park Hyatt,
Sofitel
Upper Hyatt Centric, Joie De Vivre,
Canopy 2 2 287 %
Upscale Kimpton, Le Méridien
Hyatt Regency, Marriott,
Upper
Hilton 88 578 211,423 24.7% Renaissance, Sheraton,
Upscale Sofitel, Westin
Autograph Collection,
Curio Upscale 15 48 10,548 1.2% The Unbound Collection
Crowne Plaza, Delta,
Doubletree Upscale 41 520 123,773 14.5% Holiday Inn, Hyatt, Radisson,
Renaissance, Sheraton
Ascend Collection,
Tapestry Upscale 1 4 467 0.1% Tribute Portfolio
Courtyard, Hyatt Regency,
Embassy Upper
6 245 57,216 6.7% Marriott, Renaissance,
Suites Upscale Sheraton
Aloft, Courtyard, Four
Hilton Upper
37 771 111,438 13.0% Points, Holiday Inn, Hyatt
Garden Inn Upscale Place, Springhill Suites
Comfort Suites, Courtyard,
Upper
Hampton 21 2,338 237,334 27.7% Fairfield Inn, Holiday Inn
Midscale Express, Springhill Suites
Best Western, Comfort Inn
Tru by Hilton Midscale 1 9 911 0.1% & Suites, La Quinta,
Quality Inn, Sleep Inn
Element, Hyatt House,
Homewood
Upscale 3 451 51,305 6.0% Residence Inn,
Suites Staybridge Suites
Candlewood Suites,
Home-2 Upper Hawthorn Suites,
2 204 21,015 2.5%
Suites Midscale TownePlace Suites,
WoodSpring Suites
Hyatt Residence,
Marriott Vacation Club,
Hilton Grand Timeshare 3 48 8,101 0.9%
Vistana Signature
Vacations Experiences, Wyndham
Vacations Resorts
(1) The table above excludes five unbranded properties with 2,009 rooms, representing approximately 0.2 percent
of total rooms. HGV had the exclusive right to use [its] Hilton Grand Vacations brand, subject to the terms of a
license agreement with [Hilton].
(2) The table excludes less known regional competitors.

Source: Hilton 2017 Annual Report (excerpted directly from original).

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Exhibit 3
Hilton’s Vision, Mission, and Values
Our Vision
To fill the earth with the light and warmth of hospitality – by delivering exceptional experiences
– every hotel, every guest, every time.
Our Mission
To be the most hospitable company in the world – by creating heartfelt experiences for Guests,
meaningful opportunities for Team Members, high value for Owners and a positive impact in
our Communities.
Our Values
[H]ospitality – We're passionate about delivering exceptional guest experiences.
[I]ntegrity – We do the right thing, all the time.
[L]eadership – We're leaders in our industry and in our communities.
[T]eamwork – We're team players in everything we do.
[O]wnership – We're the owners of our actions and decisions.
[N]ow – We operate with a sense of urgency and discipline.

Source: https://www.hilton.com/en/corporate/ (retrieved July 20, 2018) (excerpted directly from


original).

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Exhibit 4
Hilton Human Rights Policy
1. SCOPE

The Human Rights Policy applies to Hilton’s corporate offices and Hilton-owned, leased and
managed hotels. Hilton expects its suppliers and business partners to comply with all laws and
regulations, and is committed to working with and encouraging its owners, franchise partners,
and others in its value chain to uphold this Policy’s principles in their own operations and
business relationships. Hilton’s Responsible Sourcing Policy is aligned with the expectations and
commitments of this Policy.
2. COMMITMENT

Human rights are the basic rights and freedoms inherent to all human beings. Hilton is
committed to complying with the law in every country and region in which we operate. Where
national law and international human rights standards differ, or are in conflict, Hilton shall
respect the law of the land, while seeking ways to advance international human rights consistent
with this Policy. As a signatory to the United Nations (UN) Global Compact, Hilton endeavors to
conduct business operations in a manner that respects human rights, as defined in the Universal
Declaration of Human Rights and to avoid complicity in human rights abuses. Prohibited
conduct under this policy includes, but is not limited to, the following:
 Using forced or slave labor, including prison, bonded, or debt labor. This prohibition
includes transporting, receiving, trafficking, harboring, recruiting or transferring, of
persons by means of threat, force, coercion, abduction, or fraud.
 Requiring Team Members* and temporary employees to pay for their employment.
 Employing individuals who are under 15 years of age or the lawful age of employment
(whichever is higher).
 Failing to comply with applicable laws and regulations regarding compensation, hours of
work, overtime and benefits.
 Failure to respect Team Members’* right to freedom of peaceful assembly and
association, including their right not to be compelled to belong to an association and
their right to choose whether or not to be represented for collective bargaining purposes.
 Failure to respect the right of freedom of opinion and expression, including the freedom
to hold opinions without interference provided, however, that the exercise of such rights
does not interfere with the safe and efficient performance of work by persons on working
time.
 Failure to respect Team Members’* and guests’ privacy rights. Hilton is committed to
safeguarding information gathered for legitimate business purposes in a reasonable
manner and in accordance with laws.
Harassment & Non-Discrimination. Hilton values diverse people, talent and ideas. We do
not tolerate any form of harassment or discrimination based on any personal characteristic,
including race, color, gender, religion or nationality.
Safe & Healthy Work Environment. Hilton is committed to the health and safety of our
Team Members*, our guests, and business colleagues. Each Team Member* and business
partner is responsible for understanding and complying with all applicable safety and health
laws and
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guidelines. In addition, each Team Member is responsible for identifying and responding to
health and safety hazards and security concerns.
Prohibition Against Human Trafficking, including Sexual Exploitation. Hilton condemns
all forms of slavery, forced labor, human trafficking and commercial exploitation. As signatories
of the ECPAT Tourism Child-Protection Code of Conduct, Hilton is fully committed, in each and
every one of the markets in which we operate, to protecting individuals from all forms of abuse
and exploitation. Hilton expects Team Members* as well as business partners to help us meet
this commitment.
3. ADDRESSING HUMAN RIGHTS IMPACTS

Hilton addresses human rights impacts in the following ways:


 Hilton requires all Team Members* to take training on our Code of Conduct, which
includes a commitment to human rights as set out in this Policy.
 Hilton strives to conduct human rights due diligence to determine actual and potential
human rights impacts in our value chain, and seeks to mitigate these impacts through
reasonable measures.
 Hilton seeks to continually strengthen its due diligence processes by tracking and
integrating findings back into its policies and procedures.
 Hilton communicates with its stakeholders both internally and externally regarding how
it addresses impacts and publishes progress in its annual corporate responsibility report.
 Hilton seeks to establish and strengthen mechanisms to report and investigate known or
suspected human rights violations.
4. GOVERNANCE

Hilton operates at a global scale, with a complex supply chain. For the latest figures of the
company’s structure, please refer to www.ir.hilton.com
For the latest updates on risk mapping and actions taken, please refer to Hilton’s annual corporate
responsibility report: www.cr.hilton.com
This statement should be read in conjunction with all relevant Hilton policies and guidance,
including but not limited to the following ones:
 Code of Conduct
 Responsible Sourcing Policy
This policy statement has been developed by Hilton in consultation with external stakeholders,
including government, non- governmental organizations, industry bodies, academia and key
business partners.
* Team Members include employees of Hilton at corporate offices, owned, managed, leased and
timeshare properties. Franchise employees include employees at independently owned and
operated franchised properties. While franchisees and their employees are not employed by
Hilton, they are a large part of Hilton’s brands and culture of hospitality.
Hilton reserves the right to amend or modify this Human Rights Policy. Last updated December
2017.
Source: https://www.hilton.com/en/corporate/ (retrieved July 20, 2018) (excerpted directly from
original).

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Exhibit 5
Excerpts – Hilton Code of Conduct
CODE OF CONDUCT
This Code of Conduct is applicable to all employees, officers, and directors of Hilton Worldwide
Holdings Inc. and its subsidiaries (collectively, “Hilton”), and to the employees of all hotels
owned, operated or managed by Hilton. Within this Code, we collectively refer to all who must
follow its principles and policies as Team Members.

GLOBAL CITIZENSHIP – HUMAN RIGHTS


Hilton complies with the employment and labor laws in every country and region in which we
operate. We respect and support fundamental human rights for all people, and we are never
complicit in human rights abuses. We expect our suppliers and business partners to commit to
the same. This means, among other things, that:

 We will not employ individuals who are under 15 years of age or the lawful age of
employment (whichever is higher) in any country in which we operate.
 We will comply with all wage and compensation requirements as defined under applicable
local laws and regulations, including those relating to minimum wages, and at a minimum
provide legally mandated benefits.
 We will not exceed maximum hours of work defined by applicable law and will
appropriately compensate overtime.
 We will not use forced labor, including prison, bonded or debt labor, physical punishment
or abuse, slave labor or trafficked persons. Forced labor includes coercion such as threats,
violence, and the retention of identity documents or non-payment of wages that traps a
worker in a job they might otherwise want to leave. Workers must consent to employment
and have the freedom to leave at any time, with reasonable notice.
 We respect the ability of Team Members to exercise their lawful right of free association.
 We respect the lawful rights of our Team Members to choose (or not choose) collective
bargaining representation.
 We are committed to the health and safety of our Team Members and comply with all
applicable health and safety laws and guidelines.

DO
 Conduct due diligence on labor agencies to make sure they are licensed and meet Hilton
standards prior to hiring contractors and Team Members through them.
 Notify the Legal Compliance Team immediately in the event of a concern about labor
trafficking, forced or bonded labor.

DO NOT
 Allow employees or contractors to pay recruitment fees. If it is found that fees have been
paid, report the matter to Human Resources or the Legal Compliance Team.
 Ask to control employee personal bank accounts for any reason.
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Hilton is a proud signatory of the United Nations Global Compact. We recognize that companies
have a responsibility to respect human rights across their operations as set out in the UN
Guiding Principles on Business and Human Rights and as defined in the Universal Declaration
of Human Rights.

GLOBAL CITIZENSHIP – PROHIBITION AGAINST HUMAN TRAFFICKING


Hilton condemns all forms of human trafficking and commercial exploitation, including the
sexual exploitation of men, women or children. As signatories of the ECPAT Tourism Child-
Protection Code of Conduct, we are fully committed, in each and every one of the markets in
which we operate, to protecting individuals from all forms of abuse and exploitation. We expect
our Team Members as well as our business partners to help us meet this commitment. Sex
trafficking and sexual tourism is a large and growing problem worldwide, and Hilton must never
allow any Hilton properties, products, or services to be used in any manner that supports or
enables any form of abuse and exploitation.
Source: Hilton Code of Conduct, May 2017, pp. 3, 21, http://ir.hilton.com/corporate-
governance/governance-documents/code-of-conduct (retrieved July 20, 2018) (excerpted directly from
original).

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Exhibit 6
Hilton Responsible Sourcing Policy
Hilton Commitment to Travel with Purpose
Travel with Purpose is Hilton's corporate responsibility commitment to providing shared value
to its business and communities in four areas – creating opportunities for individuals to reach
their full potential; strengthening communities where Hilton operates; celebrating cultures and
the power of travel; and living sustainably through the measurement, analysis and improvement
of the company's use of natural resources.
Hilton team members are expected to act with the highest standard of integrity when
conducting Hilton business. Integrity means doing what’s right, all the time, and encouraging
those around us to do the same. This culture of integrity that governs our team members, and
the way we interact with our guests, our business partners, and the communities where we
operate is the key to our Mission to be the preeminent hospitality company. As part of our
commitment to Travel with Purpose we seek to do business with partners that share our high
standards when it comes to integrity.
The Hilton Code of Conduct holds the company to the highest ethical standards, particularly
during challenging situations. The Code of Conduct provides guidance about how we all must
work together to maintain the highest ethical standards in the hospitality business. We expect
our suppliers to adhere to the fundamental principles outlined in our Code of Conduct, which
are reflected in this Responsible Sourcing Policy.
The Responsible Sourcing Policy outlines the standards expected of Hilton suppliers. Suppliers
are encouraged to have appropriate management systems in place and take steps to comply with
this Policy, including transparency concerning policies and practices and related employee
education. We encourage our suppliers to hold their suppliers and subcontractors accountable
to these standards.
Hilton reserves the right to conduct unannounced assessments, audits and inspections of
supplier facilities to ensure that reasonable efforts are being taken by our suppliers to operate in
a manner consistent with the fundamental principles of this Responsible Sourcing Policy.
Violations may lead to disciplinary action, including termination of the supplier relationship for
repeated violations or noncompliance.
For the purposes of this document "Supplier" means any company, corporation or other entity
that sells, or seeks to sell goods or services to Hilton.
Fundamental Principles
Legal Compliance Hilton abides by our high standards of business ethics everywhere we
operate. Our Code of Conduct is clear – we comply with all applicable laws. Sometimes our
standards exceed those requirements, but they never fall below them. We expect our business
partners in their interactions with Hilton and their activities on Hilton’s behalf to work together
with us to support this commitment to integrity. If suppliers witness or suspect conduct that is
inconsistent with this Policy or the law, we want to know about it. Suppliers can raise concerns
about business ethics to their Hilton Supply Management main point of contact. The Hilton
Hotline website – www.hiltonhotline.com -- is also available as a confidential mechanism to
report concerns.
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Purchasing Practices We strive to be fair and impartial in our dealings with suppliers and
outside contractors. Purchasing decisions must be based on legitimate, defined criteria,
including quality, service levels and price. We honor the terms and conditions of contracts, pay
in a timely manner, and protect the confidentiality of the proprietary information of suppliers
and outside contractors.
Fair Dealing Hilton strictly prohibits team members from giving, paying, offering or
promising anything of value to any person for the purpose of influencing official action or
gaining an improper advantage. This prohibition applies both to activities undertaken directly
by team members and to activities that may be undertaken by third parties on behalf of Hilton.
Protecting & Using Information Hilton is committed to safeguarding and handling third
party information in accordance with applicable laws, our policies, contractual obligations, and
in a manner that protects privacy, preserves customer and team member trust, and meets our
shareholders’ expectations. Hilton does not tolerate the inappropriate acquisition, possession or
use of proprietary, confidential or trade secret information of Hilton’s competitors or other third
parties, such as vendors, suppliers, owners and former employers.
Bribery & Other Corrupt Practices Hilton is committed to conducting its business in
compliance with all laws prohibiting bribery and other corrupt practices. As a U.S. based
company, Hilton’s business operations around the world must comply not only with local anti-
corruption laws, but also with laws that globally apply to Hilton’s business activities, such as the
U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act. These anti-corruption laws prohibit
Hilton from offering or giving “anything of value” to a government official or their family
members to influence that person in his or her official duties or to encourage improper or
unlawful conduct.
Human Rights Hilton complies with the employment and labor laws in every country and
region in which we operate. We support fundamental human rights for all people and expect our
suppliers to uphold the same standards. This means, among other things, that:
 We will not employ individuals who are under 15 years of age or the lawful age of
employment (whichever is higher) in any country in which we operate.
 We comply with all wage and compensation requirements as defined under applicable
local laws and regulations, including those relating to minimum wages and at a
minimum provide legally mandated benefits.
 We will not exceed maximum hours of work defined by applicable law and will
appropriately compensate overtime.
 We will not use forced labor, including prison, bonded or debt labor.
 We will not allow physical punishment or abuse of any team member.
 We respect the ability of team members to exercise their lawful right of free association.
 We respect the lawful rights of our team members to choose (or not choose) bargaining
representation.
Harassment & Non-Discrimination Hilton does not tolerate any form of harassment or
discrimination based on any characteristic protected by applicable law. Any behavior,
communication, or other conduct that creates an intimidating, offensive, abusive or hostile work
environment, or that otherwise interferes with any team member’s ability to perform his or her
job is unacceptable.
It is the policy of Hilton to employ qualified persons without regard to the individual’s sex, color,
race, religion, national origin, age, disability, sexual orientation, gender identity or any other
protected group status as defined by and subject to applicable local laws. This policy describes
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the Company’s commitment to equal employment opportunity, which supports the attraction
and

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retention of a diverse workforce that will enhance the Company’s competitiveness in attracting
customers, corporate partners, and owners.
Diversity We seek to understand our unique global communities, while developing culture,
talent and marketplace strategies that cultivate a work environment of inclusiveness. We will
maintain our competitive position by valuing and leveraging the diversity of our team members,
guests, suppliers, partners and owners. It is the policy of Hilton to actively encourage diverse
suppliers who provide quality products at competitive pricing to participate in our contracting
and subcontracting activities.
Safe & Healthy Work Environment Hilton is committed to the health and safety of our
guests, team members and business colleagues. Each team member and supplier is responsible
for understanding and complying with all applicable safety and health laws and guidelines. In
addition, we are each responsible for identifying and responding to health and safety hazards
and security concerns.
Prohibition Against Human Trafficking Hilton condemns all forms of human trafficking
and commercial exploitation, including the sexual exploitation of men, women or children. As
signatories of the ECPAT Tourism Child-Protection Code of Conduct, we are fully committed, in
each and every one of the markets in which we operate, to protecting individuals from all forms
of abuse and exploitation. We expect our team members as well as our business partners to help
us meet this commitment. Sex trafficking and sexual tourism is a large and growing problem
worldwide, and Hilton must never allow any Hilton properties, products, or services to be used
in any manner that supports or enables any form of abuse and exploitation.
Commitment to our Communities As a world leader in travel and tourism, Hilton
recognizes our responsibility to create shared value wherever we do business. We actively
support a wide variety of issues and organizations material to our business and encourage all of
our team members and business partners to volunteer or participate in the economic and social
development of their local communities as they deem appropriate.
Anti-Money Laundering Team members are prohibited from engaging in or facilitating
transactions anywhere in the world that involve funds that were derived from illegal activities
and expect the same from our suppliers. Hilton must comply with all applicable anti-money
laundering laws, rules and regulations of the U.S. and all other countries where we do business.
Therefore, we must carefully scrutinize all payments and transactions with customers, vendors,
business partners, agents and affiliates. We will not accept any funds or make any payments that
appear to be derived from illegal activities.
Animal Welfare Hilton is committed to the humane treatment of animals. Hilton encourages
its suppliers to implement humane procedures to prevent the mistreatment of animals at all
times, including when they are raised, cared for, transported, and processed.
Commitment to the Environment Hilton continually strives to minimize the amount of
waste we generate and energy we consume. Our goal is to continually move towards the use of
renewable materials and biodegradable substances wherever practicable and financially feasible.
As Hilton provides information to its stakeholders on how we effectively manage our
environmental performance, we further rely upon our suppliers to provide similar information
and work collectively toward this goal.
Throughout the term of the relationship, and otherwise at Hilton’s request, Supplier shall
provide information on its efforts to identify, monitor and minimize the environmental impacts
of its operations. Objectives should include:

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 At a minimum, ensure compliance with local, state and national environmental legislation.
 Strategically look to minimize its environmental footprint, and identify program
successes in this area.
 Minimize the use of endangered and non-renewable raw materials wherever practicable
and feasible.
 Incorporate the use of recycled materials where practicable and feasible in the
manufacturing process.
 Implement programs to recycle waste resulting from the manufacturing process
 Seek operational processes that result in energy savings.
 Implement the use of sustainable alternatives to fossil and unnatural materials and
processes where applicable.
 Continue to educate themselves and Hilton on the concept of sustainability as it relates
to their business.
 Participate in industry standardization programs as they are developed related to
sustainability.
Sustainable Forestry Hilton expects its vendors and their suppliers of wood and paper
products to maintain compliance with laws and regulations pertaining to their operations and
the products they manufacture. Hilton will not purchase wood or paper products made with
illegally harvested or traded wood.
Transparency and responsible sourcing in our supply base is important and therefore Hilton
gives preference to recycled and certified products and those protecting High Conservation
Value Forests, avoiding natural forest conversion and ensuring protection of human, civil and
labor rights wherever feasible. We understand there are many forest certification options and
will give preference to Forest Stewardship Council (FSC) certified products based on regional
risk and if all other product attributes are equal.
We consider certifications legitimate if they have independent governance, multistakeholder
inputs (including board representation), independent certification with independent auditors,
complaints and appeal process, transparency, and open participation.
Hilton reserves the right to amend or modify this Responsible Sourcing Policy. Last
Updated March 2017.
Source: https://www.hilton.com/en/corporate/ (retrieved July 20, 2018) (excerpted directly from
original).

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Exhibit 7
HILTON WORLDWIDE HOLDINGS INC.
CONSOLIDATED BALANCE SHEETS
(in millions, except share data)
December 31,
2017 2016
ASSETS
Current Assets:
Cash and cash equivalents $ 570 $ 1,062
Restricted cash and cash equivalents 100 121
Accounts receivable, net of allowance for doubtful accounts of $29 and $27 998 755
Prepaid expenses 111 89
Income taxes receivable 36 13
Other 171 39
Current assets of discontinued operations — 1,478
Total current assets (variable interest entities - $93 and $167) 1,986 3,557
Intangibles and Other Assets:
Goodwill 5,190 5,218
Brands 4,890 4,848
Management and franchise contracts, net 909 963
Other intangible assets, net 433 447
Property and equipment, net 353 341
Deferred income tax assets 113 82
Other 434 408
Non-current assets of discontinued operations — 10,347
Total intangibles and other assets (variable interest entities - $171 and $569) 12,322 22,654
TOTAL ASSETS$14,308$26,211

LIABILITIES AND EQUITY


Current Liabilities:
Accounts payable, accrued expenses and other $ 2,150 $ 1,821
Current maturities of long-term debt 46 33
Income taxes payable 12 56
Current liabilities of discontinued operations — 774
Total current liabilities (variable interest entities - $58 and $124) 2,208 2,684
Long-term debt 6,556 6,583
Deferred revenues 97 42
Deferred income tax liabilities 1,063 1,778
Liability for guest loyalty program 839 889
Other 1,470 1,492
Non-current liabilities of discontinued operations — 6,894
Total liabilities (variable interest entities - $271 and $766) 12,233 20,362
Commitments and contingencies - see Note 20

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Equity:
Preferred stock, $0.01 par value; 3,000,000,000 authorized shares, none issued or
outstanding as of December 31, 2017 and 2016 — —
Common stock (1) , $0.01 par value; 10,000,000,000 authorized shares, 331,054,014
issued and 317,420,933 outstanding as of December 31, 2017 and 329,351,581
issued and 329,341,992 outstanding as of December 31, 2016 3 3
Treasury stock, at cost; 13,633,081 shares as of December 31, 2017 and 9,589
shares as of December 31, 2016 (891) —
Additional paid-in capital (1) 10,298 10,220
Accumulated deficit (6,596) (3,323)
Accumulated other comprehensive loss (742) (1,001)
Total Hilton stockholders' equity 2,072 5,899
Noncontrolling interests 3 (50)
Total equity 2,075 5,849
TOTAL LIABILITIES AND EQUITY $ 14,308 $ 26,211

(1) Balance as of December 31, 2016 was adjusted to reflect the 1-for-3 reverse stock split that occurred on January 3, 2017. See Note 1:
"Organization" for additional information.
(Notes to consolidated financial statements omitted)

Source: Hilton 2017 Annual Report (excerpted directly from original).

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Exhibit 8
HILTON WORLDWIDE HOLDINGS INC.
CONSOLIDATED STATEMENTS OF OPERATIONS
(in millions, except per share data)
Year Ended December 31,
2017 2016 2015
Revenues
Franchise fees $ 1,382 $ 1,154 $ 1,087
Base and other management fees 336 242 230
Incentive management fees 222 142 138
Owned and leased hotels 1,450 1,452 1,596
Other revenues 105 82 71
3,495 3,072 3,122
Other revenues from managed and franchised properties 5,645 4,310 4,011
Total revenues 9,140 7,382 7,133

Expenses
Owned and leased hotels 1,286 1,295 1,414
Depreciation and amortization 347 364 385
General and administrative 434 403 537
Other expenses 56 66 49
2,123 2,128 2,385
Other expenses from managed and franchised properties 5,645 4,310 4,011
Total expenses 7,768 6,438 6,396

Gain on sales of assets, net — 8 163

Operating income 1,372 952 900

Interest expense (408) (394) (377)


Gain (loss) on foreign currency transactions 3 (16) (41)
Loss on debt extinguishment (60) — —
Other non-operating income, net 23 14 51

Income from continuing operations before income taxes 930 556 533

Income tax benefit (expense) 334 (564) 348

Income (loss) from continuing operations, net of taxes 1,264 (8) 881
Income from discontinued operations, net of taxes — 372 535
Net income 1,264 364 1,416
Net income attributable to noncontrolling interests (5) (16) (12)
Net income attributable to Hilton stockholders $ 1,259 $ 348 $ 1,404

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Earnings (loss) per share (1) :


Basic:
Net income (loss) from continuing operations per share $ 3.88 $ (0.05 ) $ 2.67
Net income from discontinued operations per share — 1.11 1.60
Net income per share $ 3.88 $ 1.06 $ 4.27
Diluted:
Net income (loss) from continuing operations per share $ 3.85 $ (0.05 ) $ 2.66
Net income from discontinued operations per share — 1.11 $ 1.60
Net income per share $ 3.85 $ 1.06 $ 4.26

Cash dividends declared per share (1) $ 0.60 $ 0.84 $ 0.42

(
Weighted average shares outstanding used in the computation of basic and diluted earnings (loss) per share and cash dividends declared per share for
the years ended December 31, 2016 and 2015 was adjusted to reflect the 1-for-3 reverse stock split that occurred on January 3, 2017. See Note 1:
)
"Organization" for additional information.
(Notes to consolidated financial statements omitted)

Source: Hilton 2017 Annual Report (excerpted directly from original).

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Exhibit 9
HILTON WORLDWIDE HOLDINGS INC.
CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME
(in millions)
Year Ended December 31,
2017 2016 2015
Net income $ 1,264 $ 364 $ 1,416
Other comprehensive income (loss), net of tax benefit
(expense):
Currency translation adjustment, net of tax of $32, $19,
and $(8) 161 (159) (134)
Pension liability adjustment, net of tax of $(8), $(2), and
$10 22 (57) (15)
Cash flow hedge adjustment, net of tax of $(7), $2, and
$4 13 (2) (7)
Total other comprehensive income (loss) 196 (218) (156)

Comprehensive income 1,460 146 1,260


Comprehensive income attributable to noncontrolling
interests (5) (15) (12)
Comprehensive income attributable to Hilton
stockholders $ 1,455 $ 131 $ 1,248

(Notes to consolidated financial statements omitted)

Source: Hilton 2017 Annual Report (excerpted directly from original).

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Exhibit 10
HILTON WORLDWIDE HOLDINGS INC.
CONSOLIDATED STATEMENTS OF CASH FLOWS
(in millions)
Year Ended December 31,
2017 2016 2015
Operating Activities:
Net income $ 1,264 $ 364 $ 1,416
Adjustments to reconcile net income to net cash provided by operating
activities:
Depreciation and amortization 347 686 692
Gain on sales of assets, net — (9) (306)
Loss (gain) on foreign currency transactions (3) 13 41
Loss on debt extinguishment 60 — —
Share-based compensation 74 65 124
Amortization of deferred financing costs and other 15 32 38
Distributions from unconsolidated affiliates 1 22 26
Deferred income taxes (727) (79) (479)
Changes in operating assets and liabilities:
Accounts receivable, net (210) (143) (47)
Inventories — 15 (39)
Prepaid expenses (15) — (27)
Income taxes receivable (24) 84 35
Other current assets 7 (2) 32
Accounts payable, accrued expenses and other 51 232 90
Income taxes payable (43) 28 13
Change in timeshare financing receivables — (54) (49)
Change in deferred revenues 55 (219) (212)
Change in liability for guest loyalty program 29 154 64
Change in other liabilities 8 199 154
Other 35 (23) (120)
Net cash provided by operating activities 924 1,365 1,446
Investing Activities:
Capital expenditures for property and equipment (58) (317) (310)
Acquisitions, net of cash acquired — — (1,402)
Proceeds from asset dispositions — 11 2,205
Contract acquisition costs (75) (55) (37)
Capitalized software costs (75) (81) (62)
Other (14) (36) 20
Net cash provided by (used in) investing activities (222) (478) 414
Financing Activities:
Borrowings 1,824 4,715 48
Repayment of debt (1,860) (4,359) (1,624)
Debt issuance costs and redemption premium (69) (76) —

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Dividends paid (195) (277) (138)

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Cash transferred in spin-offs of Park and HGV (501) — —


Repurchases of common stock (891) — —
Distributions to noncontrolling interests (1) (32) (8)
Tax withholdings on share-based compensation (31) (15) (31)
Net cash used in financing activities (1,724) (44) (1,753)

Effect of exchange rate changes on cash, restricted cash and cash equivalents 8 (15) (19)
Net increase (decrease) in cash, restricted cash and cash equivalents (1,014) 828 88
Cash, restricted cash and cash equivalents from continuing operations, beginning
of period 1,183 633 628
Cash, restricted cash and cash equivalents from discontinued operations,
beginning of period 501 223 140
Cash, restricted cash and cash equivalents, beginning of period 1,684 856 768
Cash, restricted cash and cash equivalents from continuing operations, end of
period 670 1,183 633
Cash, restricted cash and cash equivalents from discontinued operations, end of
period — 501 223
Cash, restricted cash and cash equivalents, end of period $ 670 $ 1,684 $ 856

(Notes to consolidated financial statements omitted)

Source: Hilton 2017 Annual Report (excerpted directly from original).

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Appendix 1
Trafficking Victims Protection Reauthorization Act of 2008
Forced Labor – 18 U.S.C. § 1589
(a) Whoever knowingly provides or obtains the labor or services of a person by any one of, or by
any combination of, the following means—
(1) by means of force, threats of force, physical restraint, or threats of physical restraint to
that person or another person;
(2) by means of serious harm or threats of serious harm to that person or another person;

(3) by means of the abuse or threatened abuse of law or legal process; or

(4) by means of any scheme, plan, or pattern intended to cause the person to believe that, if
that person did not perform such labor or services, that person or another person would
suffer serious harm or physical restraint,
shall be punished as provided under subsection (d).
(b) Whoever knowingly benefits, financially or by receiving anything of value, from participation
in a venture which has engaged in the providing or obtaining of labor or services by any of the
means described in subsection (a), knowing or in reckless disregard of the fact that the venture
has engaged in the providing or obtaining of labor or services by any of such means, shall be
punished as provided in subsection (d).
(c) In this section:
(1) The term “abuse or threatened abuse of law or legal process” means the use or threatened
use of a law or legal process, whether administrative, civil, or criminal, in any manner or for
any purpose for which the law was not designed, in order to exert pressure on another
person to cause that person to take some action or refrain from taking some action.
(2) The term “serious harm” means any harm, whether physical or nonphysical, including
psychological, financial, or reputational harm, that is sufficiently serious, under all the
surrounding circumstances, to compel a reasonable person of the same background and in
the same circumstances to perform or to continue performing labor or services in order to
avoid incurring that harm.
(d) Whoever violates this section shall be fined under this title, imprisoned not more than 20
years, or both. If death results from a violation of this section, or if the violation includes
kidnaping, an attempt to kidnap, aggravated sexual abuse, or an attempt to kill, the defendant
shall be fined under this title, imprisoned for any term of years or life, or both.

Trafficking Victims Protection Reauthorization Act of 2008


Civil Remedy – 18 U.S.C. § 1595
(a) An individual who is a victim of a violation of this chapter may bring a civil action against the
perpetrator (or whoever knowingly benefits, financially or by receiving anything of value from
participation in a venture which that person knew or should have known has engaged in an act
in violation of this chapter) in an appropriate district court of the United States and may recover
damages and reasonable attorneys fees.
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(b)
(1) Any civil action filed under this section shall be stayed during the pendency of any
criminal action arising out of the same occurrence in which the claimant is the victim.
(2) In this subsection, a “criminal action” includes investigation and prosecution and is
pending until final adjudication in the trial court.
(c) No action may be maintained under this section unless it is commenced not later than the
later of—
(1) 10 years after the cause of action arose; or
(2) 10 years after the victim reaches 18 years of age, if the victim was a minor at the time of
the alleged offense.

Source: William Wilberforce Trafficking Victims Protection Reauthorization Act of 2008, Pub. L. No.
110–457, 122 Stat. 5044

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Appendix 2
UK Modern Slavery Act 2015
§ 1 – Slavery, Servitude and Forced or Compulsory Labour
(1) A person commits an offence if –
(a) The person holds another person in slavery or servitude and the circumstances
are such that the person knows or ought to know that the other person is held in
slavery or servitude, or
(b) The person requires another person to perform forced or compulsory labour and
the circumstances are such that the person knows or ought to know that the other
person is being required to perform forced or compulsory labour.
[. . . .]
(3) In determining whether a person is being held in slavery or servitude or required to
perform forced or compulsory labour, regard may be had to all the circumstances.
(4) For example, regard may be had –
(a) To any of the person’s personal circumstances (such as the person being a child,
the person’s family relationships, and any mental or physical illness) which may
make the person more vulnerable than other persons;
(b) To any work or services provided by the person, including work or services
provided in circumstances which constitute exploitation within section 3(3) to
(6).
(5) The consent of a person (whether an adult or a child) to any of the acts alleged to
constitute holding the person in slavery or servitude, or requiring the person to perform
forced or compulsory labour, does not preclude a determination that the person is being
held in slavery or servitude, or required to perform forced or compulsory labour.
§ 2 – Human Trafficking
(1) A person commits an offence if the person arranges or facilitates the travel of another
person (“V”) with a view to V being exploited.
(2) It is irrelevant whether V consents to the travel (whether V is an adult or a child).
(3) A person may in particular arrange or facilitate V’s travel by recruiting V, transporting or
transferring V, harbouring or receiving V, or transferring or exchanging control over V.
(4) A person arranges or facilitates V’s travel with a view to V being exploited only if –
(a) The person intends to exploit V (in any part of the world) during or after the
travel, or
(b) The person knows or ought to know that another person is likely to exploit V (in
any part of the world) during or after the travel.
[. . . .]

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§ 54 – Transparency in Supply Chains etc.


(1) A commercial organisation within subsection (2) must prepare a slavery and human
trafficking statement for each financial year of the organisation.
(2) A commercial organisation is within this subsection if it –
(a) Supplies goods or services, and
(b) Has a total turnover of not less than an amount prescribed by regulations made
by the Secretary of State.
[. . . .]
(4) A slavery and human trafficking statement for a financial year is –
(a) A statement of the steps the organisation has taken during the financial year to
ensure that slavery and human trafficking is not taking place –
(i) In any of its supply chains, and
(ii) In any part of its own business, or
(b) A statement that the organisation has taken no such steps.
(5) An organisation’s slavery and human trafficking statement may include information about

(a) The organisation’s structure, its business and its supply chains;
(b) Its policies in relation to slavery and human trafficking;
(c) Its due diligence processes in relation to slavery and human trafficking in its
business and supply chains;
(d) The parts of its business and supply chains where there is a risk of slavery and
human trafficking taking place, and the steps it has taken to assess and manage
that risk;
(e) Its effectiveness in ensuring that slavery and human trafficking is not taking place
in its business or supply chains, measured against such performance indicators as
it considers appropriate;
(f) The training about slavery and human trafficking available to its staff.
(6) A slavery and human trafficking statement –
(a) If the organisation is a body corporate other than a limited liability partnership,
must be approved by the board of directors (or equivalent management body)
[. . . .]
(7) If the organisation has a website, it must –
(a) Publish the slavery and human trafficking statement on that website, and
(b) Include a link to the slavery and human trafficking statement in a prominent place
on that website’s homepage. [......]

Source: Modern Slavery Act 2015, March 26, 2015, Chapter 30

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Appendix 3
The Tourism Child-Protection Code of Conduct
The Tourism Child-Protection Code of Conduct is the only voluntary set of business principles
travel and tour companies can implement to prevent child sex tourism and trafficking of
children. The Code is a joint venture between the tourism private sector and ECPAT. Companies
that endorse The Code are supported by ECPAT-USA to:
1. Establish a policy and procedures against sexual exploitation of children.
2. Train employees in children's rights, the prevention of sexual exploitation and how to
report suspected cases.
3. Include a clause in contracts throughout the value chain stating a common repudiation
and zero tolerance policy of sexual exploitation of children.
4. Provide information to travelers on children's rights, the prevention of sexual
exploitation of children and how to report suspected cases.
5. Support, collaborate and engage stakeholders in the prevention of sexual exploitation of
children.
6. Report annually on their implementation of Code related activities.

*Signatories are required by the Code of Conduct Steering Committee to pay annual fees based
on their revenues per year.
Source: ECPAT USA, The Tourism Child-Protection Code of Conduct, https://www.ecpatusa.org/code/
(retrieved July 26, 2018) (excerpted directly from original).

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