Travelzoo Code of Ethics for Senior Officers

Travelzoo is committed to conducting business in full compliance with applicable laws, rules, regulations, and the highest standards of ethical conduct, including accurate financial disclosures as required by law. This Code of Ethics applies to the Company's Chief Executive Officer, Chief Financial Officer, and Controller (collectively, "Senior Officers") and provides clear guidelines for fulfilling your duties.

As a Senior Officer, you must not only adhere to all applicable laws but also champion honest and ethical conduct while upholding Company policies. Your leadership role involves fostering a culture of integrity and compliance, creating an environment where employees feel safe raising concerns, and addressing compliance issues promptly.

Compliance with Laws, Rules, and Regulations

You must comply with all laws, rules, and regulations governing our business operations and report any suspected violations as outlined in the "Compliance with Code of Ethics" section below.

Conflicts of Interest

Maintain honesty and ethics by properly managing actual or apparent conflicts between personal and professional interests. No Senior Officer may engage in investments, accept positions or benefits, participate in transactions, or act in ways that create or appear to create conflicts without fully disclosing all relevant facts to the Audit Committee of the Board of Directors and obtaining their prior written approval.

Disclosures

Company policy mandates full, fair, accurate, timely, and understandable disclosures in all filings with the Securities and Exchange Commission, submissions, and public communications, in strict compliance with applicable laws. As a Senior Officer, promote and adhere to standards, policies, and procedures that ensure this compliance.

Compliance with Code of Ethics

Report any known or suspected violations of laws, rules, regulations, or this Code immediately to the Chairman of the Audit Committee. Retaliation against good-faith reporters is strictly prohibited.

Violations may lead to disciplinary action, including termination. The Audit Committee, or its designees, will determine appropriate responses.

Waivers of Code of Ethics

To request a waiver, fully disclose circumstances to the Audit Committee. Amendments and waivers will be publicly disclosed as required by law.

No Rights Created

This Code articulates fundamental principles, policies, and procedures for Senior Officers. It does not create rights for any employee, customer, supplier, shareholder, or other party.

Officer Consent

I have received, read, and understand Travelzoo’s Guide to Business Conduct and Ethics. I agree to comply with all provisions and consent to their terms.

Signature of Officer: ____________________________

(Print or type name): ____________________________

Date: ____________________________

Witness: ____________________________