VENDOR ETHICS STATEMENT

Hard Rock believes that the conduct of its Vendor Partners reflects upon Hard Rock itself and affects Hard Rock’s reputation. Hard Rock requests compliance from its vendors on the following business practice standards:

1. Confidentiality Information

    

   Vendor Partner will not disclose any trade secrets, confidential information, knowledge, data, know-how, or any other information deemed ‘confidential’ during or after the term of this relationship without written approval from Hard Rock.

    

2. Vendor Registration

    

   To conduct business with Hard Rock, any of its affiliated properties, or any of its entities, Vendor Partners must be registered and approved through our Vendor Registration Program. This includes any and all transactions, regardless of dollar value. Vendors that have not satisfied this requirement are not authorized to conduct business with Hard Rock or any of its properties or entities.

    

3. Purchase Order

    

   A Purchase Order (PO) will be issued for all goods, services, samples, donations etc. regardless of dollar value by the Purchasing Department unless otherwise agreed to in an executed agreement.

    

4. Gifts

    

   Gifts to Hard Rock employees are strictly prohibited as they may create the appearance of a conflict of interest. A Gift for the purpose of this document include, but are not limited to: payments, fees, services, privileges, vacations, trips, personal loans, entertainment, inducements or other special considerations or other favors of any nature.

    

   1. Vendor acknowledges and agrees Hard Rock employees are not authorized to accept gifts.

    

   1. A violation of this provision may impact the business relationship with Vendor Partner on current and future business.

    

   1. Vendor acknowledges and agrees that gifts/donations that have the opportunity to benefit all employees are acceptable upon approval of the General Manager/SVP/President/Head of Procurement. (i.e. items donated for employee picnic, charity events, conferences, etc.)

    

5. Vendor Commitments

    

   Hard Rock integrates the following standards to achieve the highest ethical, environmental, and social responsibility in its business practices and encourages Vendor Partner to do the same.

    

   1. Animal Welfare

    

   Vendors agree to treat animals humanely by ensuring that all animals have minimal stress, fear and pain. Good animal welfare consists of appropriate shelter, management, nutrition, humane breeding, humane handling, and humane slaughter. Alternatives to animal testing should be used whenever possible.

    

   1. Fair Business Practices

    

   Vendors must abide by fair business practices, including truthful and accurate advertising. Deal fairly in all relationships and avoid taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or other unfair-dealing practice.

    

   1. Labor

    

   Hard Rock expects its vendors to treat their workers with dignity and respect, and to uphold their human rights. Working hours comply with applicable laws and benchmark industry standards, whichever affords greater protection. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment, verbal abuse and/or other forms of intimidation shall be prohibited.

    

   1. Freely Chosen Employment

    

   No vendor will use any form of slavery or forced labor; this includes involuntary prison labor.

    

   1. Child Labor

    

   Hard Rock has a zero-tolerance policy of exploitation of children and vulnerable adults.

   Vendors must comply with all age-related working restrictions as set by applicable local and federal law and adhere to international standards as defined by the International Labor Organization (ILO) regarding age-appropriate work when applicable.

    

   1. Human Trafficking Compliance

    

   Vendors shall comply with all applicable human rights laws, statutes. Vendors are strongly encouraged to implement due diligence procedures for their own suppliers, subcontractors and other participants in their supply chains, to ensure that there is no human rights violations, including but not limited to slavery, child labor or human trafficking in their supply chain.

    

   1. Health, Safety and Respect for Environment

Hard Rock expects vendors to provide a healthy and safe working environment, and to be environmentally responsible to minimalize any adverse impacts of operations on the environment. Vendors are encouraged to conserve natural resources, to reuse and recycle and to avoid use of hazardous materials where possible.

Vendors shall use best practices to ensure the safe and lawful handling, movement, storage, recycling/reuse or management of waste, air emissions and wastewater discharges. Vendors shall endeavor to reduce or eliminate waste of all types, including water and energy, and are encouraged to implement appropriate conservation measures through their maintenance and production processes and by recycling, re-using or substituting materials.

Vendors shall have appropriate processes in place where applicable to identify, prevent and mitigate any risk of a chemical spill or other event that would pose a threat to worker safety and/or to the environment. These processes include emergency plans in the case of an unsafe event and response procedures should such an event occur.

The provisions of this Ethics Statement do not constitute maximum standards and should not be used to prevent companies from exceeding these standards. Companies are expected to comply with applicable laws and, where the provisions of laws and this Ethics Statement address the same subject, to apply that provision which affords the greater protection.

By signing this Ethics Statement, the Vendor represents and warrants that it meets or exceeds Hard Rock’s standards and will continue to do so throughout its term as an authorized Vendor. In the case Hard Rock becomes aware of any actions or conditions not in compliance with this Ethics Statement, Hard Rock reserves the right to request corrective measures up to and including termination of our relationship unless Vendor has an executed contract that will govern this lack of compliance.