Introductory Remarks by the Board of Directors

With more than 20 years of business experience in the travel sector, Asian Trails, a member of the Fairfax Group, is committed to further developing and growing its business. Asian Trails is a travel company powered by technology which acts as an intermediary with a truly global footprint. Service excellence and high customer satisfaction are at the centre of Asian Trails’ global business. For this purpose, we will need to count on the strengths, knowledge and ability of our employees: people who are prepared to “go the extra mile”, and who make the vital difference between Asian Trails and our competitors. Asian Trails will enhance the experience of its current and future
customers and partners by empowering its people, fostering a global network to work smarter and faster through digital – delivering unrivalled, trusted and convenient service and state-of-the-art solutions.

Asian Trails maintains and promotes a corporate culture and behaviour in which honesty, integrity and respect for the law are viewed as essential to achieve its desired success. Asian Trails’ ethical and behavioural principles, which apply throughout all the countries in which it is active, are explained in this Code of Conduct.

The Code of Conduct is intended to serve as a guide to its corporate and employee ethical behaviour. It is supplemented by more detailed internal regulations and guidelines which are applicable to specific geographic areas and/or fields of activities of Asian Trails. Asian Trails Code of Conduct is an integral part of our corporate culture and is binding upon Asian Trails’ Board of Directors, Executive Board/Committee and all personnel of Asian Trails, a member of the Fairfax Group.

All companies, management and individual employees of Asian Trails must do their utmost to identify and prevent any illegal or inappropriate behaviour. Asian Trails encourages the reporting of any breaches of the Code of Conduct to the employee’s superior and to the Chairman of the Board of Directors. All communication to the Chairman of the Board of Directors will be treated as confidential and will not result in any disciplinary action or retaliation against the persons making them, provided they have not consciously abused this facility or committed any offence themselves. The Board of Directors and the Executive Board/Committee will insist on the observance of this Code of Conduct and its provisions. By ensuring such observance, we will all help to further strengthen Asian Trails’ already-high reputation for professionalism, integrity and fairness in its dealings with all its stakeholders.

Asian Trails’ Ethical Values

Asian Trails’ Code of Conduct lays down the binding general principles of ethical behaviour of Asian Trails, a member of the Fairfax Group. The values underlying these principles may be regarded as being shared by everyone working at Asian Trails.

The Code of Conduct is based on the following principles:

• Behaviour with integrity and in compliance with the law;
• The recognition of universal human rights principles;
• Respect for other cultures and opinions;
• Responsibility towards society;
• Care for the environment;
• Loyalty towards Asian Trails and the Fairfax Group.

Scope of Application

Asian Trails’ Code of Conduct is applicable to the Board of Directors, the Executive Board/Committee, all employees as well as to all direct and indirect subsidiaries, business segments, units and areas of activity of Asian Trails and the Fairfax Group whether operating as “Asian Trails” or under different brands or company names.

The internal regulations, guidelines, etc. of Asian Trails shall supplement the rules and values specified in Asian Trails’ Code of Conduct. Asian Trails Code of Conduct is an integral part of Asian Trails’ corporate governance. It is binding on the Board of Directors, the Executive Board/Committees and all other employees of Asian Trails Group. Each employee is personally obliged to abide by Asian Trails Code of Conduct.

Each Managing Director or head of a business unit has to ensure that Asian Trails Code of Conduct is included in staff training as extensively as possible, and shall monitor the observance thereof.

Observance and Reporting

Asian Trails will not tolerate any evidenced violation of Asian Trails’ Code of Conduct. Any such violation will result in disciplinary action. Evidenced failure to observe the values laid down in this Code of Conduct may result in disciplinary action that can extend to dismissal. Such disciplinary action may be taken not only against persons violating Asian Trails’ Code of Conduct, but also against any employees who consciously permit such violation or who attempt to influence or retaliate against subordinates for reporting such violations.

Since constant awareness is the best prevention of all, Asian Trails urges all its employees to report any violation of Asian Trails’ Code of Conduct. Such reporting should primarily be addressed to your superior or your local HR Manager. If your superior is part of the issue you should address directly the head of your business unit. As a last resort, if you fear retaliation and/or if you want to report on a confidential basis you should contact Asian Trails’ Chairman of the Board of Directors (see section 13 below).

All such communications will be treated in strict confidence, and will not result in any disciplinary action against the person making them, even if the alleged violation proves unfounded in the subsequent internal investigation. In contrast, however, any violation of the Code of Conduct by the person making such communications, and any intentionally falsified claim of such violation (such as malicious and improper accusations) will result in disciplinary action.

Conflict Situations

Ethical conflicts

All employees shall familiarize themselves with the good business practice applicable to their area of activity, and shall behave with integrity and in compliance with the law. Asian Trails’ Code of Conduct is intended to provide guidelines on how to behave with integrity for all Asian Trails employees.

It cannot, however, cover all possible situations in which ethical conflicts may arise. As a globally-active company, Asian Trails is confronted with various laws, cultures, manners and customs, and this can lead to situations of uncertainty. Wherever reasonable, Asian Trails shall respect the manners and customs of the countries in which it conducts its business to the extent they comply with applicable law, the Code of Conduct and Asian Trails’ internal regulations and guidelines. Should there be any serious ethical conflict with colleagues and/or their superiors, Asian Trails’ employees should apply common sense judgment in cases in which the best course of action needs to be determined in a particular situation.

In doing so, they may find it useful to ask themselves:

• Have I informed myself adequately about Asian Trails’ values, internal regulations and guidelines as well as applicable law?
• Are the actions I intend to take legal, and do they comply with the applicable values, internal regulations and guidelines?
• Do I have a personal moral objection with the action intended?
• Am I acting fairly, honestly and responsibly?
• Could I justify my actions to my family, my friends and my colleagues?
• Have I adequately considered alternatives?
• Have I consulted my work colleagues and superiors?
• How am I likely to judge my actions with the benefit of hindsight?
• How would I feel if my actions were reported in the media the next day?
• Could Asian Trails lose customers or shareholders if they found out about this?

If there is still uncertainty, about how best to proceed, consult your superior, your local HR representative, the legal department of your business unit or the Chairman of the Board of Directors.

Conflicts of interest

All our business must always be effected with the best interests of Asian Trails in mind. No employee may abuse their position, their knowledge of confidential information or the property of Asian Trails to their personal advantage, nor give preferential treatment to any individual internal or external person or company known to them in a manner which is not in accordance with legal and common local business practice.

All situations which could lead to a conflict between the interests of Asian Trails and the private interests of individual employees should be avoided. In the event of uncertainty, a discussion must be sought between the employee and the employer, in which both parties should seek to resolve the issue in good faith. In the event of remaining doubts, the matter shall be referred to the country’s Managing Director and/or the Chairman of the Board of Directors.

Compliance with the Law and Internal Regulations

Each individual Asian Trails employee is personally obliged to comply with all applicable laws, local rules and regulations as well as with Asian Trails’ internal regulations and guidelines for their jurisdiction and/or area of activity. All employees shall familiarize themselves with the rules, regulations and guidelines which are relevant to their business activity.

Asian Trails’ Managing Directors are responsible for ensuring that the relevant training and monitoring is provided. In view of the international nature of its business activities, Asian Trails is confronted with a wide range of legal frameworks and parameters. In certain individual cases, different views and room for interpretation may exist on legal compliance issues. In such cases, Asian Trails will respect the legally-valid and binding rulings of the courts responsible.

All requisite authorizations must be obtained from the authorities responsible. All Asian Trails employees are obliged to inform its management of any uncertainties they may have regarding compliance with official terms, conditions and requirements.

Corporate Social Responsibility

We strive to act as a good corporate citizen which takes into full account the current and future economic, social and environmental impacts of our business. We acknowledge and live up to our responsibility to support a sustainable touristic development. We seek to adhere to the Global Code of Ethics for Tourism of the UNWTO, which endeavours that source countries, tourist destinations, host communities and businesses maximize the positive economic, social and cultural effects of tourism and fully reap its benefits, while minimizing its negative social and environmental impacts. In order to ensure an effective management of our corporate responsibility:

• We are committed – at the highest level of management – to integrate our principles of corporate responsibility in our core business operations
• We seek an open and transparent dialogue with internal and external stakeholders and actively report on our activities in order to achieve this
• We define strategies and actions which are adopted group- wide and which are based on clear targeting, measurement and monitoring systems
• We aim to continuously improve our sustainability performance.

In particular, we aim to:

• Create opportunities for our colleagues to thrive and develop under fair, healthy and safe conditions of employment
• Monitor our suppliers in meeting the standards of Asian Trails and further improve their sustainability performance
• Develop and continually expand the range and offer of our sustainable products and to strongly engage with our customers in their promotion
• Respect and proactively foster internationally-recognized human rights within our sphere of influence, especially the rights of the most vulnerable of our society. We seek to avoid complicity in human rights abuses and to further develop appropriate response mechanisms
• Minimize our carbon footprint as far as possible and foster resilience to climate change impacts within our value chain. We strive towards a sustainable management of natural resources and the protection of their future productivity.

Cultural Diversity and Non-Discrimination

The diversity of its employees and customers is an opportunity, an asset and a key component within Asian Trails’ corporate culture. Asian Trails employs people from many different nations all over the world. We are proud of this diversity which we actively cultivate, as we believe that it enriches Asian Trails. Diversity demands openness, tolerance and empathy from each and every one of us.

We are committed to ensuring, within our multicultural teams and our working environment, that nobody is harassed or discriminated against for any reason such as their race, religion, belief, nationality, sex, age, sexual orientation or disability. All our dealings with one another shall be characterized by courtesy, fairness, openness and respect, and all our employees shall behave accordingly. Any cases of discrimination or harassment shall be reported immediately to Human Resources and/or the country’s Managing Director and/or the Chairman of the Board of Directors.

Gifts and Hospitality and Corruption

Gifts and Hospitality

Exchanges of small gifts and hospitality are normal tokens of courtesy and friendliness between business partners and colleagues. On no account, however, may they be given, offered or received with the intent or prospect of influencing decision making or other conduct. In certain countries in which Asian Trails is active, the exchange of gifts and invitations is customary.

Such activities can, however, cause problems. The line between permissible gifts and bribery is a fine one. But the prime difference between the two is that bribery jeopardizes the making of an objective decision or proper performance of a function. In the case of bribery, the giver will usually expect some kind of improperly favourable treatment by the recipient in return for their gift or hospitality.

Further guidance as to what is and is not permissible is set out in Asian Trails’ Anti-Corruption Regulation. Particular care must be taken when dealing with a Public Official (as defined and set out in the Anti-Corruption Regulation). In the event of any uncertainty in such cases in terms of the limits of acceptable business practice, employees should consult the country’s Managing Director and/or the Chairman of the Board of Directors.

Corruption

Bribery and corruption are criminal offences in most countries, and may result in substantial fines for Asian Trails and in fines or prison sentences for its employees. A “bribe” in this context is any financial or other advantage which is offered, provided, authorized, requested or received as an inducement or reward for the improper performance of a person’s relevant function or the receipt of which is itself improper (e.g. in breach of any rules or guidelines which apply specifically to the recipient). Further guidance as to what is and is not appropriate conduct is set out in Asian Trails’ Group Anti-Corruption Regulation.

Competition

Asian Trails is an advocate of fair and open competition. Antitrust law may on no account be violated. Any such violation may result in substantial fines for Asian Trails and in fines or prison sentences for its employees. In particular, price-fixing among competitors (verbal, written or in any other form), market allocation, exchange of information and any other practices which may inhibit free competition are prohibited. For details, the relevant internal regulations and guidelines shall be consulted. If there is still uncertainty, consult the country’s Managing Director and/or the Asian Trails Group CEO.

Handling Information

Insider Trading

Insider trading is prohibited.

Material inside information is any information which is non-public and the disclosure of which is capable of triggering a significant change in the price of securities of Asian Trails or other companies. Such information includes, for example, confidential data on financial results, merger or acquisition plans, trading figures or information on other business activities involving major contracts or agreements.

No employee may buy or sell securities of Asian Trails or other companies if they are in possession of inside information pertaining hereto. Potential insiders are prohibited from trading securities of Asian Trails and any other company for a closed period preceding the publication of material non-public information. It is also prohibited to pass on material inside information to third parties (including family members and friends). These restrictions remain in force until such confidential information is made public and has been absorbed by the market.

For details and/or in case of doubt the relevant internal regulations and guide- lines and/or the TCI Group Legal Head shall be consulted.

Data Protection

The privacy of every individual shall be respected and protected. Business secrets shall not be divulged. Asian Trails does not divulge any confidential information about its customers, employees or business partners unless such divulgence is required by law. Personal data may not be acquired by illegal means.

Any processing of personal data must be reasonable. Any employees processing personal data should ensure that such data is correct. Asian Trails shall also provide the technical and organizational means required to ensure that personal data is protected against unauthorized processing. No employee may pass on any confidential information or business secrets of Asian Trails to any third party (including family members or friends), nor use such information or secrets for any inadmissible purpose.

The above obligations shall continue to apply following any termination of employment with Asian Trails. All documents and any other data carriers containing confidential information shall be returned to Asian Trails upon termination of employment.

Communications

External Communications

We are active, transparent and timely in our communications. We have appointed individuals at Asian Trails to communicate to the media. Only these persons are authorized to provide information on Asian Trails’ related issues. We assist the media in their endeavours to report objectively on Asian Trails. We do not comment on rumours.

Internal Communications

We are open and honest in our communications – even on sensitive issues. Our employees shall be informed as comprehensively as possible about development which affect them at Asian Trails and about the company’s business strategy and performance. In difficult situations employees will continue to be informed fairly and with respect.

Information and Communication Tools

Asian Trails’ employees are personally responsible for ensuring that their information and communication tools are used professionally and in compliance with the law and internal regulations and guidelines. Telephone, Internet, fax and e-mail correspondence is considered business related correspondence and should primarily be used for business purposes. For more details concerning usage of information and communication tools the applicable internal regulations and guidelines shall be consulted. Access to, the dissemination of and the storage of data which is of an illegal, immoral, offensive or degrading nature is forbidden.

Use and Protection of Company Property

All employees shall exercise due care and responsibility in their use and handling of Asian Trails’ furnishings and installations and of other company property. We document all transactions and obligations correctly, clearly, truthfully and in a manner which is as comprehensive and timely as possible. All our accounts are maintained in full compliance with legal and accounting requirements and with our own internal regulations and guidelines.

Our internal control system ensures the correctness, the appropriateness and the reliability of our business processes and activities and ensures effective risk management. Asian Trails’ archives shall be maintained properly and in compliance with the relevant legal provisions. Business documents are a valuable company asset and must therefore be handled with the requisite care. All business documentation (including documentation created by employees in the course of their employment) is the sole and exclusive properly of Asian Trails and may not be used by any employee for any illegal purposes.