Vendor code of conduct

Last Update: 19/09/2023

Expedia Group is committed to promoting a positive work environment and maintaining the highest levels of ethics and integrity. Expedia Group requires its Vendors be committed to these same principles. Our Vendors’ business and labor practices (and those of their subcontractors) must comply with all applicable laws, agreements between any member of Expedia Group and Vendor as well as the requirements of this Vendor Code of Conduct. All Vendors will be required to educate and, when appropriate, train their representatives to ensure they are aware of Expedia Group's expectations regarding their behavior.

The policies summarized below are not exhaustive, and there may be other conduct not explicitly listed that would be unacceptable.


Ensuring people are treated with dignity and respect is fundamental to Expedia Group’s continued success and the sustainability of the communities where we do business. To that end, we practice and seek to work only with Vendors who respect human rights as well as equal opportunity in the workplace.

Ensuring people are treated with dignity and respect is fundamental to Expedia Group’s continued success and the sustainability of the communities where we do business. To that end, we practice and seek to work only with Vendors who respect human rights as well as equal opportunity in the workplace.

Vendors represent and warrant that:

  • Cooperate with Expedia Group’s commitment to a workforce free of harassment and unlawful discrimination. Vendors must not engage in discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender identity, marital status, sexual orientation, union membership, or political affiliation;
  • Provide a safe and healthy work environment and fully comply with all applicable health and safety laws, regulations and practices. Adequate steps shall be taken to minimize the causes of hazards inherent in the working environment and establish a hygienic work environment. Emergency response procedures will be established and maintained;
  • Use only voluntary labor and prohibit the use of human trafficking in their operations. The use of forced labor by an Expedia Group Vendor and/or its subcontractors is prohibited. Workers must not be required to surrender government issued ID, passports or work permits as a condition of working and may only hold such documents as necessary to complete legitimate administrative and immigration processing;
  • Prohibit the use of child labor. Employees shall not be under the legal minimum working age of the respective region or shall not be less than 16 years of age (whichever is higher). Expedia Group supports the development of legitimate workplace apprenticeship programs for the educational benefit of younger people and will not do business with those who abuse such systems;
  • Treat workers with respect and dignity. All forms of offensive behavior, including insulting, violent, abusive, demeaning, harassing or bullying conduct towards workers, are prohibited.
  • Pay living wages under humane conditions. All workers shall be provided with clear, written information about their employment conditions with respect to wages before they enter employment and as needed throughout their term of employment. Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the express permission of the worker concerned. All disciplinary measures should be recorded. Wages and benefits paid for a standard working week must, at a minimum, meet national legal standards;
  • Not require workers to work more than the maximum hours of daily labor set by local laws and ensure that overtime is voluntary and paid in accordance with local laws and regulations;
  • Keep employee records in accordance with local and/or national regulations.


Vendors shall, without limitation:

  • Comply with the anti-corruption laws of the countries in which it does business and with the United States Foreign Corrupt Practices Act and the United Kingdom Bribery Act. Vendors shall not make any direct or indirect payments or promises to foreign government officials for the purposes of inducing the individual to misuse his/her position to obtain or retain business;
  • Not offer or accept bribes or other means of obtaining undue or improper advantages to anyone for any reason, whether in dealings with governments or the private sector;
  • Be honest, direct and truthful in discussions with regulatory agency representatives and government officials;
  • Protect worker whistleblower confidentiality and prohibit retaliation against workers who report workplace grievances. Vendors must create a system for workers to submit grievances anonymously;
  • Not offer gifts to Expedia Group employees of more than minimal value. Expedia Group employees are prohibited from accepting such gifts without prior approval from an Expedia Group senior executive and may not solicit gifts of any value;
  • Not buy or sell Expedia Group securities while in possession of information regarding Expedia Group’s operations that is not available to the investing public and that could influence an investor’s decision to buy or sell Expedia Group securities;
  • Be upfront and disclose any conflicts of interest with Expedia Group including Expedia Group employees; and
  • Prohibit and actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorism or other criminal activities.


Vendors represent and warrant that:

  • They will comply at all times with, and will not engage in conduct that would result in penalties under or cause Expedia Group to violate or be exposed to penalties under, all sanctions, export control, and anti-boycott laws, regulations, orders, directives, designations, licenses, and decisions of the European Union, the United Kingdom, the United States of America, and of any other country with jurisdiction over activities undertaken in connection with their engagement with Expedia Group;
  • Neither they, nor any of their Affiliates nor any of their respective directors, officers, agents, or employees are a Sanctions Target (i.e., is listed on any list of designated parties subject to trade controls restrictions maintained by (a) the EU or its Member States; (b) the United Kingdom, including the Office of Financial Sanctions Implementations; (c) the U.S., including the U.S. Treasury Department’s Office of Foreign AssetsControl, (d) the United Nations or (e) any other country with jurisdiction over activities undertaken in connection with their engagement with Expedia Group);
  • They are not 50% or more owned or controlled, directly or indirectly, individually or in the aggregate, by one or more Sanctions Targets;
  • They are not ordinarily resident, incorporated, or headquartered in any territory that is or becomes subject to comprehensive U.S. economic sanctions (for example Cuba, Iran, North Korea, Syria, and specified regions of Ukraine).


As a leader in the travel industry, sustainable tourism is an important focus for Expedia Group’s corporate citizenship efforts. Our primary objective is to enhance the geographical character— the environment, culture, aesthetics, and well-being of local residents—at travel destinations around the world. We strive to operate sustainably, in order to minimize the environmental impact of our activities.

Vendors must:

  • Obtain and keep current all required environmental permits, approvals and registrations and comply with operational and reporting requirements, as applicable;
  • Monitor and control waste generated from operations before disposing in accordance with applicable laws;
  • Characterize, monitor, control and treat regulated air emissions before discharging in compliance with applicable laws.

Expedia Group expects its Vendors to participate in social programs which benefit the communities in which they operate. This includes programs which serve the public good through the partnerships with local communities designed to contribute to economic growth and social opportunity. Examples include libraries, vocational schools and learning centers which promote an awareness of global cultures and perspectives.