SPB Hospitality

Workplace Recording Policy

Effective 6/1/2020

Purpose

SPB Hospitality ("Company") restricts photos and sound recordings ("recordings" are further defined below) in the workplace that has not been authorized by the Company for the following reasons: Recording could endanger the Company's confidential business information and trade secrets by creating a recorded record of such information that could result in disclosure of that information to unauthorized individuals.

Recording customers, business partners, vendors, suppliers, independent contractors and others who do business with the Company without their consent could damage these business relationships because the recording could be viewed by the person recorded as an invasion of privacy or as a demonstration of lack of trust.

Recording in places where team members or others reasonably can expect privacy, such as restrooms, locker rooms, and changing areas, could be viewed by the person recorded as an invasion of privacy.

Recording without the consent of all parties who are recorded may be unlawful in CA, FL, IL, MD, MI, MT, NV, PA, or WA where the Company conducts business. The Company seeks to foster a work environment and corporate culture that encourage collaboration, the free exchange of ideas, and spontaneous and candid discussions about the challenges we at the Company address on a daily basis. Recording of conversations defeats these objectives because it can have a chilling effect on participants in conversations, especially when confidential matters are being discussed.

Restrictions On Recording By Team Members

Team members are prohibited from recording while performing job responsibilities and/or during working time, whether on-site or off-site, in the following circumstances: 1. When the recording would capture the Company's confidential business information or trade secrets unless the recording has been made to advance the Company's business interest and has been authorized by General Counsel. Trade secrets may include information regarding the development of systems, business processes, products, know-how and technology. Confidential business information may include non-public financial data, such as estimates of financial performance; sensitive business information, such as marketing strategies, product launches, and pricing policies; plans for the acquisition or disposition of corporate assets; information about customers; information about team members obtained by virtue of a team member's job responsibilities; and the Company's attorney-client communications or other internal business-related confidential communications.

2. When the recording would record any prospective or current customer, business partner, vendor, supplier, independent contractor or other person who may or does do business with the Company without that person's consent;

3. When the recording would be made in any place where team members or others reasonably can expect privacy, such as restrooms, locker rooms, and changing areas; 4. When the recording would record the voice of anyone on Company's premises located in California unless all parties to the recorded communication consent to the recording before it starts or the recording would be permitted by applicable law without the consent of all parties to the communication for another reason.

5. The Company will not construe or apply this Policy in a way that interferes with team members' recording of communications with each other concerning wages, hours or working conditions or recording of allegedly unsafe working conditions.

Permitted Recoding of Team Members for the Company's Business Purposes The above restrictions do not apply to use of a recording device authorized by the Company for the Company's legitimate business purposes, including, but not limited to the following: 1. routine security operations;

2. internal investigations (when approved by legal counsel); 3. customer service and other calls with customers for regulatory, quality assurance or training purposes;

4. communications customarily recorded by authorized Company personnel for subsequent rebroadcast to unavailable attendees, such as training courses and leadership communications; 5. marketing and team member engagement-related events (note, however, that express written consent may be required before using a recording or image for commercial or other external purposes); or

6. when required by applicable law or when approved by legal counsel. In the circumstances listed above, the Company will obtain the consent of all parties to the communication, before recording, if required to do so by applicable law. Company's Use And Disclosure Of Permitted Recordings The Company may review, audit, monitor, access, delete, and/or disclose any permitted recording

(described above) to ensure compliance with these standards and related Company and business policies and guidelines; to protect the security of Company, and assure Company's compliance with applicable law and regulatory requirements and business obligations; or for any other reason permitted by law. Definitions

"Recording" under this policy includes taking video or images (film, digital, and any other means) with or without a voice component, or recording of any conversation or communications, regardless of whether the conversation or communication takes place in person, over the telephone, or via any other communications device or equipment; regardless of the method used to record; and regardless of where the conversation or communication takes place (as long it occurs while performing job responsibilities for the Company or during working time); and whether on or off the Company's premises. "Recording" also includes capturing sound through any mechanism or device which is capable of recording or amplifying a conversation (other than a device used to mitigate a hearing impairment), including, but not limited to, tape-recorders, microcassette recorders, video cameras, digital or analog recorders, applications ("apps") on a smartphone or tablet, wearable technology, or any other mechanism or device capable of storing or amplifying sounds.

Enforcement

Team members should report incidents of unauthorized recordings via the Employee Relations Hotline found in the Handbook. Team members who violate this policy may be subject to disciplinary action, up to and including termination of employment. Any exceptions to this policy must be authorized in writing by the Chief Human Resources Office or General Counsel. Employee Signature Date

Digitally Sign