LRA Internal Audit Checklist

SWFA.01.04- If a swimming pool or other recreational body of water is present, there are no diving boards, diving platforms or trampolines for use by the guests.

SWFA.01.05- If a swimming pool is present, all steps entering or exiting the pool must have a handrail.

SWFA.01.08- If swimming pool or wading pool is present, property must comply with all aspects of the ANSI/APSP-7 2006 standard entitled "American National Standard for Suction Entrapment Avoidance in Swimming Pool, Wading Pools, Spas, Hot Tubs, and Catch Basins." A licensed professional mechanical engineer or a licensed commercial pool builder must review the physical installation for compliance with the referenced standard and certify compliance. Such certification must include Starwood's standard language in a letter on their company letterhead. The certification letter must be dated and filed at the property and produced upon demand. The physical installation inspection and certification process must recur every three years.

SWFA.01.10- If communal whirlpool is present, property must comply with all aspects of the ANSI/APSP-7 2006 standard entitled "American National Standard for Suction Entrapment Avoidance in Swimming Pool, Wading Pools, Spas, Hot Tubs, and Catch Basins", including Section 7.1 contained therein regarding the Safety VacuumRelease System. A licensed professional mechanical engineer or a licensed commercial pool builder must review the physical installation for compliance with the referenced standard and certify compliance. Such certification must include Starwood's standard language in a letter on their company letterhead. The certification letter must be dated and filed at the property and produced upon demand. The physical installation inspection and certification process must recur every three years.

SWFA.01.12- If a communal whirlpool is present, whirlpool must be equipped with an operable, clearly marked emergency shut-off switch that is accessible within the whirlpool area. Such shut-off switch must be located within 20 feet / 6.1 meters from the whirlpool. This switch must completely shut down all mechanical components.

SWFA.01.13- If a swimming pool is present, permanent deck depth markers in both feet and meters must be displayed. (The infinity edges of a pool do not require depth markers. For overflow pools, if there is a deck present, depth markers are required on the deck only.)

SWFA.01.13- If a swimming pool is present, permanent deck depth markers displayed uniformly on all sides of the pool, that are accessible from the deck, (maximum perimeter distance between markings is 25 feet / 7.62 meters), including the side with the access stairs.

SWFA.01.13- If a swimming pool is present, permanent deck depth markers, each numerical character in the swimming pool depth mark must be a minimum of 4 inches / 10cm high and be in contrasting color with the background;

SWFA.01.13- If a swimming pool is present, permanent deck depth markers should be clearly visible and legible. <br>

SWFA.01.14- If a swimming pool is present, permanent water line depth markers in both feet and meters must be displayed. (The infinity edges of the pool do not require depth markers. For overflow pools, if there is a deck present, depth markers are required on the deck only).

SWFA.01.14- If a swimming pool is present, permanent water line depth markers displayed uniformly on all sides of the pool (maximum perimeter distance between depth markings is 25 feet / 7.62 meters). Water line depth markers are not required to be located on the pool stairs.

SWFA.01.14- If a swimming pool is present, permanent water line depth markers, each numerical character must be a minimum of 4 inches / 10 cm high and be in contrasting color with the background.

SWFA.01.14- If a swimming pool is present, permanent water line depth markers should be clearly visible and legible. <br>

SWFA.01.15- If a swimming pool is present, at a minimum, one "NO DIVING" sign is prominently displayed at or near a main entrance of the pool, in English at a minimum. "No Diving" International symbol is preferred. This stand-alone signage is in addition to the "no diving" symbol at each depth marker and the Pool Rules sign.

SWFA.01.15- Properties must have permanent "NO DIVING" markings, with minimum of 4 inch / 10cm letters, along the deck of the pool at or near each depth marking (maximum distance of 25 ft. / 7.62 meters between markings). A permanent (minimum of 4 inches / 10cm) "NO DIVING" international symbol is preferred.

SWFA.01.16- If a swimming pool is present, local safety rules and regulations must be prominently posted in the pool area in English at a minimum. At a minimum, general Pool Rules must be posted at the main entrance and/or towel booth (if applicable) and must include the hours of operation. It is acceptable for the hours of operation to be stated on a separate sign, prominently posted, at or near the Pool Rules sign. For pool/whirlpool combinations, where the whirlpool is directly connected to the pool, the hours of operation, of the whirlpool, may be stated on the same sign as the swimming pool.

SWFA.01.17- If a communal whirlpool is present, local safety rules and regulations must be prominently posted in the whirlpool area in English at a minimum. At a minimum, the Whirlpool Rules must be posted and must include the hours of operation. It is acceptable for the hours of operation to be stated on a separate sign, prominently posted, at or near the Whirlpool Rules sign. For pool/whirlpool combinations where the whirlpool is directly connected to the pool, the hours of operation of the whirlpool may be stated on the same sign as the swimming pool. However, the whirlpool rules sign must be separate from the swimming pool rules sign.

SWFA.01.18- If a swimming pool is present, swimming pool area must be lit at all times for night viewing and observation of the bottom of the pool, unless the pool area can be physically secured while the pool is closed.

SWFA.01.19- If a swimming pool is present, for pools over 5 feet / 1.5 meters deep only - The transition point of the pool from the shallow area to the 5 foot/1.5 meter deep area of the pool shall be visually set apart with a contrasting pool bottom color, row of floor tile, a painted line, or similar means using a color contrasting with the bottom. Where this is not possible a float line shall be provided running parallel to the deep side of the pool and securely anchored to the pool sides. In instances where the slop begins prior to the 5ft/1.5M mark, it is acceptable to have the float line or contrasting transition point located at that point.

SWFA.01.20- If a swimming pool is present, the following items are available and clearly visible within each pool area:<br>1) At least two life preserver rings, in good condition, attached to untangled ropes a minimum of 2/3 of the maximum width of the pool which are visible and easily accessible (coiled loosely). <br>2) A shepherd's hook is available and easily accessible at least 12 feet / 3.6 meters in length, or longer as required by local code; <br>3) One, clearly marked, no-dial emergency telephone or "call box" at each hotel's designated pool area(s) connected to a 24 hour staffed location, subject to local regulations. If a call box is used, it must allow for 2-way communication. "Emergency Phone" signage must be in place OR a red phone may be substituted for signage. Red casing for the phone is also acceptable.

SWFA.01.21- If a swimming pool is present, and the pool is unattended, sign must be posted noting that it is unattended, preferably, "No Lifeguard on Duty" in English at a minimum. It is acceptable for this notice to be included on the Pool Rules sign.

SWFA.01.22- If a communal whirlpool is presen, maximum water depth does not exceed 3' 6" / 1.06 meter measured from the water line.

SWFA.01.22- If a communal whirlpool is presen, Step treads and whirlpool deck has slip resistant surfaces.

SWFA.01.22- If a communal whirlpool is presen, maximum water temperature is 104F / 40C degrees.

SWFA.01.22- If a communal whirlpool is presen, Whirlpool steps are provided with a handrail. <br>

SWFA.01.22- If a communal whirlpool is presen, there are a minimum of two, clearly marked, permanent depth markings in feet and meters for any sized whirlpool. Such depth markers must be located on the deck OR posted signage.

SWFA.02.01- The following safety and security equipment are in place and fully functional in all room-entry doors at all times: <br>1) Reprogrammable, card/key access<br>2) Unobstructed door viewer on guestroom door (no scratches) <br>3) Primary locking device - minimum 1 inch / 2.5 cm deadbolt <br>4) Secondary, non keyed, locking device. U-bolt (no chains or slide bolts) or Securichain (TM) brand is acceptable as a secondary locking device. <br>5) Self-closing door mechanism <br>6) Safety and security instructions and evacuation plan on the back of the guestroom entry door (or for panel or glass doors, may be on wall adjacent to door), posted in English at a minimum. <br>7) If connecting doors are in place, the doors must have two locks. One lock must be a 1" deadbolt with blank back plate. The second lock can be a non-keyed, 'operable' door lever (knob) with spring-loaded latch that extends into the strike box securing the door. The door is then opened by turning the lever and retracting the latch. The opposite side of the door must be equipped with a blank backplate to prevent the door from being opened from the adjoining room. A U-bolt type security device can also be used as a second lock. If a non-operable (dummy) door lever (knob) is used where the latch does not catch when entering into the strike box, then this does not constitute a secondary locking device and a U-bolt type security device is required.<br>

SWFA.02.08- The bathtub and shower surface must be as follows: <br>1) The bathtub surface is slip resistant <br>2) The shower surface is slip resistant

SWFA.02.09- Crib must be offered and must comply with the following: <br>1) LAD & EAME must have the Foundations Portable Steel Crib only OR the 2450 Pinnacle Compact Crib (model 1331195 or 1331095) <br>2) No missing/broken hardware or slats <br>3) Only a fitted crib sheet and a fitted mattress pad are permitted to be provided with the crib. Note: a crib blanket may be provided only upon guest request at no charge. No other items are to be included with the crib, i.e., no bumper pads, pillows, toys, etc.) <br>4) Firm and tight fitting mattress <br>5) Parent Instruction Card in English at a minimum (Spec can be found in the Starwood Asset Library)

SWFA.02.10- When servicing a guestroom with the door closed, (preferred method), an "Attendant on Duty" sign is placed on the door / doorknob to notify returning guests that an associate is working in the room. If the room is serviced with the door open, the housekeeping cart must be placed in front of the doorway to prevent access.

SWFA.02.10- When servicing a guestroom with the door open, any guest or any other person that enters the room must be required by the associate to validate their access to the room by proving that the key does in fact open the guest room door. This applies to electronic, mechanical or other locking systems.

SWFA.02.11- If a safe is present in the guestroom, it must have a clearly visible, local legal disclaimer sticker. The disclaimer sticker can be attached in any of the following ways: - directly to the outside of the safe; - directly to the inside of the safe door; or - adjacent to the outside of the safe.

SWFA.02.13<br>1) All associates whose job function requires crib setup has completed the crib certification training program with the associate certificate on file.<br>2) Cribs may only be delivered and set up by a crib certified associate.

SWFA.03.05- If not already imbedded in glass, at minimum, a window decal/distraction pattern, at 5 feet / 1.5 meters from the floor, on glass doors and/or any full length glass panel(s). This standard shall not apply to glass window panels that have a ledge/knee wall of 18 inches / 45 cm or more from the floor. All glass panels that have a ledge/knee wall less than 18 inches / 45 cm must have a distraction pattern. If a full length glass panel is 2 ft. / 61cm wide or less, a distraction pattern is not required, regardless of whether or not a knee wall is in place.

SWFA.03.09<br>1) House telephones, in all public areas, are programmed for direct ring-down to a 24-hour staffed location and not capable of direct dialing to guestrooms. <br>2) If elevators are present, a house phone must be present at each elevator landing on guestroom floors.

SWFA.03.10- All AEDs must be accessible to members of the public (may not be placed behind any desk) and be clearly visible, with adequate signage. An AED should be placed at the following locations (where present): <br>1) Guest check-in area. Properties with multiple check-in areas in dispersed buildings should have an AED at each building's check-in area. <br>2) The nearest location outside the Security Operations Center (only required if th Security Operations Center is continuously staffed 24hr/day. <br>3) If a fitness center is present, inside the fitness center <br>4) If a golf course is present, the nearest location outside the golf pro-shop area<br>5) An AED maintenance vendor log must be in place, performed in accordance with manufacturer recommendations OR evidence of a weekly maintenance check performed by the AED program coordinator (for each AED). Minimum requirements for the weekly self-check must include 1) the date of check 2) who performed the check and 3) whether or not the AED is fully functional.

SWFA.03.13- At least one CO detector must be present in EACH area of the property containing fuel burning appliances. All CO Detectors must be connected to the building fire alarm system control panel.

SWFA.03.14- Control of Allergen program must be in place per EAME Procedure for Controlling Allergens, as per local legislation. Countries which are members of the European Union (EU) must fully comply with the EU Regulation on the Provision of Food Information to Consumers in particular allergens. Any other Country in EAME are strongly encouraged to apply the Starwood Allergen Policy. <br>1) Control of Allergen program must be in place per EAME Procedure for Controlling Allergens, as per local legislation. Countries which are members of the European Union (EU) must fully comply with the EU Regulation on the Provision of Food Information to Consumers in particular allergens. <br>2) Countries which are members of the European Union (EU) must insert the following disclaimer, in every menu (restaurant, bar, in-room dining and banqueting and catering menus), drink cards as well as buffet signage. We welcome enquiries from customers who wish to know whether any dishes contain particular ingredients. Please inform us of any allergy or special dietary requirements that we should be made aware of, when preparing your menu request. <br>3) All food handlers have been trained on the Principal 14 Food Allergens and training records have been entered on Diligence. <br>4) Chef's menu cards are readily available for all food and beverages served throughout the hotel; including guest amenities.

SWFA.04.01- The property operator confirms the guest's name prior to transferring calls to the guestroom. The operator does not transfer calls to guestrooms unless the caller knows the first and last name of the guest.

SWFA.04.02- Guests are asked to present a valid photo ID at check-in. Identification is requested of arriving guests to verify the name, but no information from the ID is photocopied or recorded, unless required by local law.

SWFA.04.03- Associates respect guest privacy by never giving out guest names, information or room numbers to a third party

SWFA.04.04- <br>1) Associates position themselves in front of the guestroom security viewer with their name tag and/or brand pin visible to the guest and announce their department. The associate ensures the guestroom door is completely closed as they depart. <br>2) The associate ensures the guestroom door is completely closed as they depart.

SWFA.04.05- Persons without a key are denied guestroom access. When contacted, the associate must refer the guest to the front desk for an additional key. Guests are required to present photo identification to be verified prior to granting room access. AP/LAD/EAME - Properties in countries that scan/photocopy passports upon guest check-in, if required by applicable law, may confirm the identity of the guest by viewing the scanned/photocopied passport photo for likeness AND asking the guest to confirm his/her date of birth as listed in the passport information.

SWFA.04.06- During Check-in, the following method of acquiring keys must be used:<br>1) Room number is indicated in writing on the key packet, and not stated out loud. The guest name is not permitted to be written on the key card or key packet.

SWFA.06. 02- If a fitness center is present, one, clearly marked, no-dial emergency telephone or "call box" is located in the fitness center connecting to a 24-hour staffed location subject to local regulations. If a call box is used, it must allow for 2-way communication. "Emergency Phone" signage must be in place, (Spec can be found in the brand signage packages), OR a red phone may be substituted for signage. Red casing for the phone is also acceptable.

SWFA.06. 04- If a fitness center is present, the Fitness Center Rules must be prominently posted in English at a minimum.

SWFA.07.02- Luggage storage is available 24/7. The storage area must be secured and only accessible by authorized staff and guests.

SWFA.07.03- Luggage Claim checks include limits of liability and are provided for each piece of luggage.

SWFA.07.04- Safe deposit boxes are available near the front desk for guest use at no charge. Safes in guestrooms do not eliminate need for this standard. <br>1) Signatures from Guest & Hotel Representative are required to verify access, for each entry <br>2) Guests are advised of lost key liability and that there are no duplicate keys