Corporate Compliance

Ethical Business Practices

Crystal Cruises is committed to strictly adhering to the highest ethical standards and fair practices in all of our business activities. We expect the highest integrity and 100% commitment to these principles from all Crystal Cruises employees.

Professional standards of behavior are necessary for successful and efficient business operations, and for the benefit and protection of all employees' rights and safety. Crystal Cruises will not tolerate conduct that interferes with company operations, brings discredit to the company and our fleet, or is offensive to our guests, travel professionals, business associates and/or other employees. Our ethical behavior has a profound impact on our organization, our employees and our long-term success.

While representing Crystal Cruises, employees must comply with all laws and regulations; deal honestly with all guests, travel agents, business associates and co-workers; treat others with respect and dignity; and use company resources properly.

Code of Conduct - Conflict of Interest

I. Business Activities and Disclosure

Employees of Crystal Cruises, Inc. ("Crystal") are expected to observe the highest standards of ethical behavior in dealing with others. Employees shall not engage in activities outside the employment of Crystal which may be in conflict with Crystal's interests, including but not limited to providing professional services to a vendor, competitor, travel agency or any distributor of Crystal, including but not limited to travel professionals. Crystal requires that employees disclose in writing to the president of Crystal if they, a family member or significant other presently have or plan to have a financial interest in, or are employed by, any vendor, competitor, travel agency or any distributor of Crystal. No business may be done with any of these entities without the prior written consent of the president of Crystal.

II. Acceptance of Private Consideration and Disclosure

Employees of Crystal may not accept, from travel professionals, customers or vendors, offers of entertainment or gifts that could be deemed excessive based on ethical business custom and practice and social norms, or are likely or intended by the donor to influence business decisions. Such entertainment and gifts include, for example, but are not limited to food and drink, money, items exchangeable for money such as gift certificates, travel and other social invitations.

Vendors should not be expected or requested to provide products or services at a reduced rate or free of charge to a Crystal employee for personal benefit or use because of the employee's position with Crystal, unless such reduced rates or no charge are agreed to by Crystal and arranged to be generally offered to all employees of Crystal. Rate concessions which are part of accepted ethical business custom and practice, and not intended to inappropriately influence business decisions, are not included in this prohibition.

Employees of Crystal shall avoid situations and associations that may interfere with the independent exercise of their judgment, the performance of their responsibilities and the best interest of Crystal. It is extremely important that business be done on behalf of Crystal in the best interests of Crystal, and without considering or receiving any personal benefit. If an employee receives any consideration that is in contradiction to this policy or may be perceived as such, it must be promptly reported to Crystal's Human Resources Department.

III. Provision of Private Consideration to Customers and Vendors

Employees of Crystal shall limit the provision of entertainment to customers and vendors of Crystal to accepted social courtesies. Employees should avoid placing such customers and vendors in situations and associations that may interfere with the independent exercise of their judgment and the performance of their responsibilities in accordance with their code of conduct.

IV. Using Authority to Coerce

Crystal will not tolerate the use of a Crystal employee's authority or position to coerce other Crystal employees into doing business with vendors, suppliers or other companies with whom that individual has a friendship or family or other relationship. Transactions with suppliers and other business partners should be based on an objective assessment of price, service and quality in the interests of Crystal, and no Crystal employee should otherwise attempt to influence another.

V. Violations

Violations of these policies will result in disciplinary action, up to and including termination of employment.