Hilton Worldwide : Political Activity

U.S. Political Contributions and Disclosure Policy

Introduction

It is the general policy of this Company to participate in the free political processes of the local, state and federal governments of the United States, within the restrictions imposed by applicable law, and for the general benefit of the operations of the Company and its shareholders, team members and customers. All such participation shall be accomplished strictly in accordance with all applicable legal restrictions and shall be subject to the public disclosure processes outlined in this policy.

Company Political Activities

State and Local Contributions:Where permitted by law, the Company may contribute directly to state and local candidates, state party committees, and other state and local political entities. The Company will semiannually disclose on its website all Company state and local- level political contributions and expenditures.

527 Committees:When permitted by law, the Company may contribute to 527 political committees. The Company will semiannually disclose on its website all Company political contributions and expenditures.

Non-ProfitOrganizations:For any trade association of which the Company is a member or otherwise contributes, the Company will semiannually disclose on its website the portion of its payments that are used for lobbying and political expenditures as defined by 26 U.S.C. Section 162(e). Additionally, the Company will semiannually disclose on its website all Company contributions made to 501(c)(4) organizations where such contributions are made for a political purpose.

Independent Expenditures:While companies are permitted by law to engage in independent expenditures or electioneering communications to advocate for the election or defeat of federal candidates, the Company does not presently engage directly in such activity at this time.

In the event that the Company does choose to engage in independent expenditures or electioneering communications, that activity will be disclosed here.

Political Action Committee

Federal law does not permit corporations to contribute their own funds to federal candidates, political parties, or most other political committees. U.S. law does permit companies to establish a political action committee to collect employee donations to contribute to federal candidates and other committees regulated by the Federal Election Commission (FEC).

The Company has created the Hilton Worldwide Political Action Committee ("Hilton PAC") for this purpose. Contributions to federal candidates and committees are made only through Hilton PAC, in accordance with FEC regulations. To provide funding for Hilton PAC, the Company periodically solicits voluntary contributions from eligible employees. The Company fully discloses all Hilton PAC activity on reports filed with the Federal Election Commission (FEC), which are publicly available on the FEC website.

Personal Employee Political Activities

To the extent an employee personally engages in political activity, such participation must be on non-working time, without the use of Hilton resources unless otherwise authorized, and in a manner that does not suggest Hilton sponsorship or approval. Hilton does not reimburse employees for any such personal contributions.

Oversight and Governance

The Company maintains an internal policy governing political contributions and personal political activities, and enforces compliance through the General Counsel and Executive Vice President of Corporate Affairs. The Board of Directors of the Company periodically reviews these policies and practices regarding political contributions and expenditures by the Company and its PAC.