At Starline Investment, transparency and disclosure are not only regulatory requirements—they are core elements of our identity and long-term strategy. We believe that clear, consistent, and proactive communication fosters trust, mitigates risk, and strengthens relationships with our global hotel investors, business partners, portfolio companies, and stakeholders.

Our commitment to responsible and ethical conduct is guided by our Corporate Responsibility & Governance Principles, which outline our expectations regarding integrity, sustainability, corporate accountability, and fiduciary responsibility. These principles shape every decision we make and every partnership we form.

Disclosures

As an international firm specializing in hospitality investments, we uphold a high standard of transparency in all aspects of our business operations. We provide in-depth, timely disclosures that cover:

• Operational Highlights: Including key performance indicators (KPIs) for each hotel asset and updates on strategic initiatives.
• Financial Performance: Consolidated financial statements, fund-level reporting, and detailed breakdowns of returns, asset values, and cash flow.
• Risk and Compliance Metrics: Documentation of internal controls, risk mitigation strategies, and audit outcomes.
• Governance and Oversight: Information on board structure, decision-making processes, and ethical guidelines.

All disclosures are aligned with global financial reporting standards and are made available through our Investor Relations Portal, which includes downloadable reports, filings, and performance dashboards.

Principles for the Acquisition and Use of Data

We view data as a critical enabler of operational excellence and investment insight. At Starline, our approach to data is centered on value creation, responsible use, and legal compliance. Our data governance framework includes:

• Performance Analytics: Real-time tracking of occupancy rates, RevPAR (Revenue per Available Room), ADR (Average Daily Rate), and guest satisfaction metrics.
• Market Intelligence: Aggregated and anonymized data used to evaluate regional demand trends, pricing benchmarks, and competitive positioning.
• Data Security and Privacy: End-to-end encryption, third-party audits, and strict access controls. All data handling follows global privacy regulations such as the
  • General Data Protection Regulation (GDPR).
• Compliance Training: Regular training for employees and partners on data ethics and compliance obligations.

Regulatory Bodies

Starline Investment maintains full regulatory compliance across all jurisdictions where we operate. We are committed to transparency and oversight through:

• Licensing: All investment activities are carried out by properly licensed and registered entities.
• Jurisdictional Compliance:
  • United States: Registered with the Securities and Exchange Commission (SEC)
  • Local Authorities: In compliance with national tourism and real estate investment regulators
• Cross-Border Standards: We follow international tax, anti-money laundering (AML), and Know Your Customer (KYC) requirements.
• Internal Audit and Legal Review: Periodic assessments of all business units to ensure consistent application of global standards.

Industry Standards and Affiliations

As advocates for transparency, sustainability, and ethical investing, Starline is actively involved in global industry initiatives that aim to improve corporate responsibility in the hospitality sector.

• We participate in advisory committees focused on:
  • Environmental Responsibility: Reducing the carbon footprint of hospitality assets
  • Labor Standards: Promoting fair wages and workplace safety
  • Corporate Governance: Enhancing stakeholder engagement and board accountability

Our Commitment

Transparency is not a checkbox—it is a culture we embed throughout our firm. Whether you are an investor, operator, or partner, you can expect clear communication, consistent disclosures, and an unwavering focus on integrity and accountability.

For more information on our transparency and compliance practices, please reach out directly to our Investor Relations team.