Airbnb Code of Ethics

Airbnb

Code of Ethics

December 2020 2

Hi team,

The original Airbnb team was just the three of us.

Now we’re a team of thousands. As we’ve grown,

we’ve been incredibly intentional about our

culture. At its most basic, culture is our collective

behaviors. Our culture is shaped by things like

our Core Values, shared behaviors and special

traditions. But one of the most important aspects

of our culture is how we treat each other. We want

this to be a company where everyone acts with

integrity — where we’re honest and respectful.

When it comes to how we treat one another, it’s

critical that we’re all on the same page. To help

with this, we’ve dened some simple behavioral

standards in our Code of Ethics. The Code of Ethics

reminds us of our responsibilities as employees

to all of our stakeholders — Guests, Hosts,

Communities, Employees and Shareholders. Simply

put: it outlines our expectations for how we conduct

ourselves. We expect all employees to read it,

understand it and follow it. If we all commit to these

standards, we’ll not only maintain the culture that

makes Airbnb so special, we’ll strengthen it.

To keep the Code of Ethics relevant, we’ll need your

ongoing feedback. If you have questions or you’re

aware of some activity that doesn’t align with these

expectations, please email ethics@airbnb.com.

Thanks for all you do for Airbnb.

Brian, Joe and Nate

Code of Ethics

December 2020 3

Table of Contents

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

21st Century Stakeholder Principles . . . . . . . . . . . . . . . . . . . . 4

Belonging is Everyone’s Responsibility. . . . . . . . . . . . . . . . . . .5

Respectful Relationships . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

Safety & Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Waivers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Final Note . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Code of Ethics

December 2020 4

Introduction

Our culture is built around four Core Values —

Champion the Mission, Be a Host, Embrace the

Adventure and Be a Cereal Entrepreneur. Our Code

of Ethics articulates the principles we must practice

to live up to our values. It claries expectations around

our behavior and reinforces our shared responsibility

for this incredible Airbnb community. The Code of

Ethics applies to all employees, ocers and directors

of Airbnb, Inc. and its subsidiaries. Translated versions

of the Code of Ethics are available at air/ethics.

In addition to the Code of Ethics, we also have policies

and guidelines (and in certain countries, Employee

Handbooks and local legal requirements) that outline

our responsibilities to each other. In several places,

the Code of Ethics refers to specic policies.

21st Century

Stakeholder

Principles

Acting ethically is at the foundation of everything

we do. This means having a Code of Ethics that

is consistent with our vision and in line with our

Stakeholder Principles.

Code of Ethics

December 2020 5

Belonging is

Everyone’s

Responsibility

Manager Responsibilities.

Managers occupy positions of authority and must be

ethical role models. Managers communicate their

commitment to the Code of Ethics by (1) living the

Airbnb Core Values; (2) consistently upholding our

high standards and avoiding even the appearance of

unethical behavior; (3) holding themselves and others

accountable for their decisions and behaviors and (4)

being alert to and taking steps to address, situations

that could violate the Code of Ethics or damage

Airbnb’s reputation.

Employee Responsibilities.

Every Airbnb employee is expected to understand the

requirements described in the Code of Ethics. Before

you make a work-related decision or take action, think

about the Core Values, Stakeholder Principles and the

Code of Ethics. Ask yourself the following questions.

If the answer to any of the questions below is “No”

or “I don’t know,” your decision or action is probably

inappropriate:

• Is this action legal and ethical?

• Is this action aligned with both the spirit and

the letter of the Code of Ethics?

• Is this action aligned with Airbnb Core Values?

• In signicant decisions, have I considered

the impact of this action on each of the

ve stakeholders?

• Will this action seem appropriate to others?

• Would your coworkers be embarrassed or

compromised if this action were to become

known within Airbnb or publicly?

The best way to safeguard our reputation and preserve

our culture is to hold ourselves accountable. No one at

Airbnb has the right to discourage anyone else from

reporting a Code of Ethics issue or to retaliate against

anyone who reports a concern. See “We Prohibit

Retaliation” below.

Ethics Advisor Responsibilities.

The Code of Ethics can’t clarify every real life dilemma,

so we have Airbnb Ethics Advisors — trustworthy,

responsible employee advisors who received

specialized ethics training and can help when you

aren’t sure how to handle a particular situation. Ethics

Advisors can also receive reports of potential Code of

Ethics violations. Email them at ethics@airbnb.com.

Code of Ethics

December 2020 6

Company Responsibilities.

Airbnb will resolve employee questions, concerns and

reports with sensitivity and respect for employee

condentiality to the greatest extent possible.

Consequences of violating the Code of Ethics or

another Airbnb policy will depend on the gravity of

the violation and can result in discipline up to and

including termination.

Everyone’s Responsibilities.

We play by the rules. Airbnb complies with national,

state and local laws and regulations that apply to our

business. As a member of our community, you have a

responsibility to be aware of and comply with the laws

and regulations that apply to your area of responsibility.

If you don’t understand a particular law or regulation

or if you are not sure it applies to you, ask a member

of the Legal team for help.

Reporting and Responses

to Concerns.

We are committed to responding to employee

concerns, complaints and reports. So, please speak up!

If you see, hear or learn of inappropriate behavior, share

your concerns. There are many ways to report issues.

Tell any manager, Talent Partner, member of the Legal

team or Ethics Advisor, all of whom have an obligation

to report any violations they are informed of or witness

directly. Or submit a report through our Ethics Hotline

at airbnbethics.com or through Vault. You may even

report your concerns anonymously. Please review our

Whistleblower Policy for more information.

We will thoroughly, promptly and impartially examine

and address every report of a violation of the Code

of Ethics. We will take appropriate steps to maintain

condentiality, though we cannot guarantee absolute

condentiality or anonymity. Employees are required

to cooperate with investigations conducted by

Airbnb by providing truthful and complete responses

to investigators.

When claims are substantiated in whole or in part,

we will take appropriate action, from training and

coaching, to warnings, to employment termination

or termination of any other business relationship.

We Prohibit Retaliation.

It is a violation of this Code to retaliate against anyone

because they reported a concern, they helped

someone else report a concern, they participated in

an investigation, they exercised a legal right or they

acted according to a company policy. If you suspect

retaliation or have any questions about retaliation,

please let us know. Reach out to any manager, a Talent

Partner, member of the Legal team, an Ethics Advisor

or report a concern at airbnbethics.com.

Code of Ethics

December 2020 7

Respectful

Relationships

Belonging is a concept that denes Airbnb and every

employee in every country should experience and

express it. Because all belonging begins with respect,

these policies outline the minimum expectations for

respectful interactions at work.

We Promote Diversity, Inclusion

& Equal Employment Opportunity.

We believe in equal employment opportunity,

which means we respect and embrace each other’s

dierences. We give every applicant and employee

equal opportunities without regard to characteristics

and statuses protected by country, regional or local

laws. Protected characteristics and statuses around

the world include such things as: race, religion, national

origin, social condition, criminal record, citizenship,

culture, color, gender, gender identity, gender

expression, genetic characteristics, age, disability,

medical condition, pregnancy, marital status, military

status, civil status, HIV status and sexual orientation.

We practice and promote equal opportunity in every

employment-related activity and at every Airbnb

location. We make employment-related decisions

only on the basis of individual ability, performance,

experience and business requirements. Our employees

should be free from discrimination in all aspects of

the employment relationship — from recruitment

and hiring, compensation, performance evaluations,

project assignments, training opportunities,

promotions, to the end of employment.

Please see Airbnb’s Anti-Harassment, Discrimination

& Retaliation Policy for further information, reporting

procedures and Airbnb’s prohibition of retaliation.

Local Employee Handbooks may also apply.

We Do Not Tolerate Harassment

or Bullying.

We’re all hosts at Airbnb. We’re open-minded,

respectful and hospitable. We’re committed to and

look out for each other. Harassment, discrimination

and bullying are incompatible with our values

and are not tolerated. Our Anti-Harassment,

Discrimination & Retaliation Policy explains how we

ensure that our place of work is free of all forms of

harassment, discrimination, bullying and retaliation.

What We Expect.

We expect managers to maintain a healthy, inclusive

work environment — where bullying, discrimination

and harassment are never tolerated.

Managers may not have Personal Relationships

(an ongoing or past romantic or intimate relationship)

which are in violation of the Anti-Harassment,

Discrimination & Retaliation Policy or Conflicts

of Interest Policy.

Code of Ethics

December 2020 8

A healthy, inclusive work environment is not exclusively

a manager’s responsibility. A culture of belonging

requires everyone to act appropriately with co-workers,

contingent workers, vendors and guests and to take

action when necessary to ensure our work environment

free is from bullying, discrimination and harassment.

We Accommodate

(or Make Adjustments for)

Physical or Mental Dierences.

Consistent with our commitment to diversity, inclusion

and equal employment opportunity, we provide

reasonable accommodations to disabled applicants

and employees. Specic policies and practices may

vary by region and local rules, so please check our

Accommodation Policy or contact Talent Operations

or your Talent Partner if you have questions.

When We Say “Mandatory,”

We Mean It.

We oer several mandatory trainings on topics

including harassment, discrimination and others.

All employees globally are required to complete

harassment prevention training. These mandatory

trainings will be assigned to you and your Employee

Handbook may outline the specic mandatory

trainings that apply to you. Failure to complete

these trainings by their assigned deadlines can

result in employee discipline leading up to and

including termination of your employment.

We are Exemplary Guests & Hosts.

We are proud to have so many employees who are

champions of Airbnb’s mission, not just at work, but

also as Homes and Experiences hosts and as Airbnb

guests. As an employee, you literally represent Airbnb

and its values in our community. This is a signicant

responsibility. We expect every employee host to

comply with local laws, including short-term rental

regulations. And as a guest or a host, we expect

every employee to be an exemplary member of the

Airbnb community. Whether hosting or traveling for

business or leisure, an exemplary guest or host always

follows the rules of the listing and our Community

Standards, Party and Events Policy, Host Reliability

Standards and Guest Reliability Standards. Violation

of these standards may result in disciplinary action

up to and including employment termination.

We are Responsible With

Alcohol & Drugs.

Our work environment reflects our hospitality. We

oer many ways to build community — comfy sofas,

board games, ping pong, music, a theater and good

food and drink — to name a few. We respect you and

trust you to use good judgment. We are committed

to ensuring that drugs and alcohol never compromise

employee, guest or community safety and security.

Code of Ethics

December 2020 9

It’s never acceptable to be under the influence of drugs

or alcohol on Airbnb premises or while working such

that your ability to safely and eectively perform your

job or behave appropriately would be impaired. This

prohibition applies to substances including certain

legal and illegal drugs, inhalants and prescription or

over-the-counter medications, whether prescribed for

you or not. No one is allowed to possess, sell, purchase

or distribute illegal drugs on our premises or while

conducting Airbnb business (including at any Airbnb-

sponsored event or in Airbnb-provided transportation).

Please note that in many countries where we operate,

the penalty for drug use is severe and we expect all

employees to observe local laws. If you are unsure

of whether a certain substance is prohibited, please

contact your Talent Partner, member of the Legal team,

an Ethics Advisor or the Security team. In addition,

if you require a medical accommodation involving

the above-mentioned substances or similar, please

review the Accommodation Policy or contact Talent

Operations or your Talent Partner with any questions.

Employees and their guests must be of a legal drinking

age, behave responsibly and follow oce policies with

respect to drinking alcohol at Airbnb oces and at

Airbnb-sponsored events. It is never okay to oer a

drink to anyone (guest, intern or otherwise) who is not

old enough to legally drink alcohol — whether in Airbnb

oces or at Airbnb events. Whenever co-workers

gather, we expect you to treat it like a work setting,

even after-hours or o-site. Work settings are not for

excessive consumption of alcohol and we expect you

to know your limits and treat each other with respect.

We also expect employees to act professionally

when hosting events with alcohol in a work setting.

For instance, employees hosting work events

should serve food, oer non-alcoholic beverages

and respect their colleagues’ decisions (like

when they say they’ve had enough to drink).

Responding to Drug and/or

Alcohol Problems.

If you struggle with addiction, we want you to get help.

If you think you have a drug or alcohol-related problem,

take advantage of Airbnb’s Employee Assistance

Program (“EAP”) to get medical and psychological

help for addiction. We also oer leaves of absence to

employees who need time o from work to participate

in drug or alcohol rehabilitation programs to the extent

appropriate and consistent with applicable law. We

will respond appropriately to drug and alcohol-related

misconduct, so if you have a problem, get help before

alcohol or drugs interfere with your work.

Code of Ethics

December 2020 10

Safety & Security

When we say “Be A Host,” we mean look out for each

other and take care of each other. We’ve worked very

hard to create a safe, secure and healthy environment

to support our mission and values. Every employee

plays a role in protecting the safety and security of

our community.

We Monitor Our Workplace to

Keep Everyone Safe & Secure.

For everyone’s safety and security, Airbnb may need

to inspect company property (like lockers, cubbies,

laptops (including data created or stored on laptops),

databases, huddle rooms, storage areas, etc.) and bags,

boxes or containers brought onto our property (things

that could hide illegal drugs, weapons, stolen property

or other inappropriate material). Of course, we will

consider and comply with local and regional laws that

regulate employee safety, security and privacy.

We are Serious About

Physical Security.

Per our Safety and Security Employee Badge and

Access Control Guidelines, we expect all employees

to take care to maintain the safety and security of our

workplace and to care for our shared investments as

if they were your own.

Please review and become familiar with our Guidelines

which, among other things, require all badge-holders

to keep their badges with them at all times, wear their

badges so they are visible at all times and tell a member

of the Safety and Security team right away if a badge is

lost, stolen or misplaced.

We Take Steps to Reduce the Risk

of and Respond to, Workplace Threats

& Violence.

Nothing is more important than the safety of our

community, so we strictly prohibit violence and threats

of violence. Examples include physical violence,

threats, harassing phone calls, sending threatening or

aggressive emails or other written communication,

stalking and intentionally destroying personal and/or

company property. We don’t permit employees to have

dangerous items like weapons, explosives or rearms

while working or attending any Airbnb function,

whether in our facilities or o-site.

Code of Ethics

December 2020 11

We Prioritize Employee

Health & Safety.

We value our employees and work hard to safeguard

your health and well-being. We try to identify and

correct every potential workplace hazard, but we also

rely on you to alert us to dangers. Please promptly

report any workplace health or safety issue, concern

or incident to AirSecurity by calling +1(415) 728-0104 or

by emailing airsecurity@airbnb.com. Employees can

also report workplace safety and health concerns or

hazards here and must promptly report all work-related

injuries and illnesses here.

We Respect & Protect the Privacy

of Personal Information.

Airbnb wouldn’t exist without the trust of our hosts and

guests. We maintain this trust by restricting access to

personal information of hosts and guests to employees

with a business reason to use it and by asking that our

employees take steps to protect against unauthorized

use or release of this information.

For your protection and the privacy of our community,

don’t access or try to access personal information of

hosts and guests unless you need it to do your job. For

example, don’t use system access rights to check out

a friend or celebrity’s account or to look at the account

of a host with whom you will be staying, even for a

business trip. When you travel for work or pleasure

on Airbnb, you should be in the same position as a

non-employee guest. We regularly monitor employee

access and will not hesitate to terminate any employee

who abuses his or her administrative access privileges.

We Protect Airbnb’s Intellectual

Property & Condential Information.

For our community to keep thriving, we must protect

our intellectual property and condential information.

We should take all steps and precautions necessary to

restrict access to and secure intellectual property or

condential information by, among other things:

• maintaining the condentiality of Airbnb-related

transactions;

• conducting our business and social activities so as

not to risk inadvertent disclosure of condential

information. Review of condential documents in

public places should be conducted so as to prevent

access by unauthorized persons;

• restricting access to documents and les (including

computer les) containing material, non-public

information to individuals on a need-to-know basis

(including maintaining control over the distribution

of documents and drafts of documents);

• promptly removing and cleaning up all condential

documents and other materials from conference

rooms following the conclusion of any meetings

(including erasing any whiteboards or other

viewable information);

• disposing of all condential documents and other

papers, after there is no longer any business or

other legally required need, through shredders

when appropriate;

• restricting access to areas likely to contain

condential documents or material, non-public

information, including individual oces that may

contain such information;

Code of Ethics

December 2020 12

• safeguarding laptop computers, mobile devices,

tablets, memory sticks and other items that contain

condential information, including complying with

Airbnb’s information technology policies to prevent

unauthorized access to devices and/or electronic

information to which you have access; and

• avoiding the discussion of material, non-public

information in places where the information

could be overheard by others such as in elevators,

restrooms, hallways, restaurants, airplanes or

taxicabs.

Those who are involved with material, nonpublic

information, to the extent feasible, should conduct

their business and activities in areas separate from

other Airbnb activities.

Airbnb, not any one individual, owns the condential

information and intellectual property you help create

during your employment. It’s your responsibility to use

it only for Airbnb’s benet and must not be used for any

other purpose. Only share it with anyone outside

Airbnb subject to a nondisclosure agreement. Sharing

condential data online, outside of the systems

authorized by Airbnb, including on third party apps, is

strictly prohibited. You may not use or disclose it for

any other purpose. When you leave Airbnb, you cannot

take any intellectual property you helped develop.

In addition, at Airbnb you also are absolutely prohibited

from using condential information, intellectual

property or trade secrets of others, including but not

limited to your prior employers, in your Airbnb work.

You must also protect the copyrighted information

of others and may not make unauthorized copies

or incorporate it into your own work.

For more information on protecting condential

information and IP, please review your Employee

Invention Assignment and Condentiality Agreement.

We Understand the Importance

of Information Security.

At Airbnb, we maintain the security of our IT systems.

The Policies for Information Security and Privacy

at Airbnb contain important information about

company IT security and data privacy expectations

and requirements, including how to fulll these

expectations and requirements when working in public

places or traveling. You must review, understand and

commit to following these policies.

We do not Engage in Insider Trading.

Insider trading occurs when a person purchases or sells

a security while in possession of material nonpublic

information. Employees who learn material nonpublic

information about Airbnb or companies Airbnb does

business with may not use that information to buy or

sell a security and may not advise any other person to

buy or sell a security based on that information. Review

our Insider Trading Policy for more information.

Speaking to the Press or Public.

Per Airbnb’s Press and Speaker Guidelines, you must

obtain approval from the Communications Team

before making any statements on behalf of or as a

representative of Airbnb (including “o the record,”

“background” or “not for attribution” comments) to

journalists, bloggers, influencers, industry analysts,

investors or otherwise through any public forum, panel

or public speaking engagement. If you inadvertently

make a comment without obtaining advanced approval

from the Communications Team, you must report any

such statements to contact.press@airbnb.com.

December 2020 13

Code of Ethics

We Cooperate with

Government Inquiries.

We may receive inquiries from government agencies.

If you are contacted by a government agency, seek

advice from the Legal Department before responding.

We Maintain Business

Records Responsibly.

We follow legal and business rules that relate to written

and electronic business records. We maintain accurate

books and records and do not tolerate any employee

fabricating books and records. We must ensure that

business records are stored in approved formats,

systems or locations. More specically, you may not

destroy or discard documents and information relevant

to a lawsuit or legal action (in other words, subject to

a “Legal Hold”) without Legal Department approval.

Send an email to [email protected] if you have

questions about documents or information subject

to a Legal Hold.

We Comply With the Oce of

Foreign Assets Control Sanctions.

The U.S. Oce of Foreign Assets Control (“OFAC”)

administers and enforces economic and trade

sanctions programs based on U.S. foreign policy

and national security goals against targeted foreign

countries and regimes and groups of individuals such

as terrorists, narcotics trackers and those engaged

in threats to the national security, foreign policy or

economy of the United States. The regulations prohibit

conducting or facilitating business with “Specially

Designated Nationals” and certain countries. They

are complex and change regularly. Ask the Payments

Compliance team before you conduct Airbnb business

that may raise an OFAC compliance issue.

We Never Engage in Bribery

or Other Forms of Corruption.

Airbnb’s Global Anti-Bribery & Corruption Policy forbids

giving or receiving — either directly or through a third

party — gifts, entertainment or things of value meant

to influence a business decision, policy decision or

create a reciprocal obligation. Bribery and corruption

can result in legal, nancial and reputational harm to

Airbnb, so it’s very important to read and understand

the Global Anti-Bribery & Corruption Policy. If you have

any questions regarding the Anti-Bribery & Corruption

Policy, please contact the Ethics & Compliance team at

abc@airbnb.com.

Code of Ethics

December 2020 14

We Recognize & Avoid

Conflicts of Interest.

A conflict of interest develops when personal loyalties

or interests are or seem to be, at odds with company

interests. Relationships, nancial interests, outside

activities and receiving gifts or entertainment from

vendors, suppliers and partners can lead to the

appearance of a conflict of interest. The appearance of

a conflict raises doubts about the quality of a business

decision and the decision-maker’s integrity. We must

never let conflicts of interest interfere with our loyalty

to Airbnb and should never take personal advantage

of an opportunity that belongs to Airbnb. Review

our Conflicts of Interest Policy and Related Person

Transaction Policy for more information on how we

manage potential conflicts of interest.

We do not Make Corporate

Loans or Guarantees.

Federal law prohibits the Company to make loans

and guarantees of obligations to directors, executive

ocers and members of their immediate families.

We Interact Responsibly

on Social Media.

Members of our community are accountable for what

they do and say on social media. The Airbnb Social

Media Guidelines is our resource for employees. Read

it carefully and ensure you act consistent with it when

engaging on social media.

We Make Accurate Disclosures.

We take actions necessary to ensure full, fair, accurate,

timely and understandable disclosure in our reports

and documents led with the Securities and Exchange

Commission and other public communications.

We Regulate Political Contributions

on Behalf of Airbnb.

Airbnb faces political challenges in various places,

and sometimes engages in the political process

by making contributions to support candidates

and support and oppose ballot measures. The laws

regarding corporate political contributions are

complex and vary from city to city, state to state

and country to country. To minimize mistakes, only

the Chief Legal Ocer and the Head of Global

Policy and Public Aairs and certain individuals

they designate, have the authority to approve

political contributions on behalf of Airbnb. Political

contributions are not limited to cash donations. Paying

for a public ocial or candidate to attend an event or

using company resources (e.g., computers, supplies,

employee time, etc.) to support a campaign could also

be considered improper political contributions.

Code of Ethics

December 2020 15

We Promote Fair Competition.

We insist on the highest levels of integrity and

comply with all antitrust or competition laws.

When we compete, we:

• do not make false claims about our competitors’

products and services, as well as our own;

• avoid making formal or informal agreements

to unfairly restrict competition;

• honor the condentiality of our competitors’

trade secrets;

• develop and implement our business strategies

independently; and

• succeed because of our great people, our

compelling vision, the quality of our product

and our superior marketing.

It’s good business to study our competitors, but only

if we do it fairly, ethically and in compliance with all

laws and regulations that apply to our business. Do not

seek competitor information unless it is reasonable and

lawful to have or use the information.

Competitive information includes anything related

to the competitive environment or to a competitor’s

products, services, markets and pricing or business

plans. Legitimate sources of competitive information

include publicly available news accounts, industry

surveys, competitors’ displays at conferences and

trade shows and information publicly available on

the Internet. It is also acceptable to get competitive

information by obtaining a license to use the

information or purchasing ownership of

the information.

It is never acceptable to seek or knowingly use

competitive information if:

• it is obtained by unethical or illegal means, including

theft, bribery, eavesdropping or unauthorized

tape-recording of a customer or supplier or

unauthorized computer devices, including those

with the intent or the result of evading another

company’s security or privacy mechanisms;

• it includes proprietary information that was

copied, drawn or photographed without the

owner’s permission;

• it was obtained in exchange for compensation,

employment considerations, gifts or anything

else of value;

• it is sent to you in an unsolicited communication

from a supplier, partner or other third party;

• it was solicited from a new hire and is about his/her

former employer; or

• it contains technical or engineering data protected

by trade secret laws.

If you receive or are oered data or information about

a competitor in circumstances which cause you any

concern, you should not distribute it and should seek

advice from the Legal team.

Code of Ethics

December 2020 16

Waivers

Any waiver of this Code of Ethics for the Company’s

directors, executive ocers or other principal nancial

ocers may be made only by the disinterested

members of the Board and will be disclosed to the

public as required by law or Nasdaq Listing Standards.

Waivers of this Code of Ethics for other employees

may be made only by Airbnb’s Chief Legal Ocer.

For the avoidance of doubt, the foregoing does not

apply to any waiver of the separate policies, guidelines

and procedures referenced in this Code of Ethics.

Final Note

YOU are the key to keeping the Code of Ethics relevant

and eective. If you see, hear or learn about a possible

violation of the Code of Ethics, please tell someone:

an Ethics Advisor, any manager or Talent Partner

— or report your concern on airbnbethics.com.

If together we insist on respectful relationships and

a safe and secure workplace, we will ensure that

Airbnb remains a healthy and sustainable workplace

for decades to come.

This Code is not intended to and does not create

any rights in any employee, customer, client, visitor,

supplier, competitor, shareholder or any other

person or entity.