Code of Ethics

Travelzoo (“Travelzoo” or the “Company”) is committed to conducting our business in accordance with applicable laws, rules and regulations and the highest standards of business conduct, and to preparing full and accurate financial and legal disclosure in compliance with applicable law. This Code of Ethics, applicable to the Company’s Global Chief Executive Officer, Chief Accounting Officer, General Counsel, General Managers and other senior leaders of the Company (together, "Senior Officers") and the Company’s board of directors (the “Board” and collectively with Senior Officers, “Covered Persons”), sets forth specific policies to guide you in the performance of your duties for the Company.

As a Covered Person, you must not only comply with applicable law, you also must engage in and promote honest and ethical conduct and abide by the Company's policies and procedures that govern the conduct of our business. Your leadership responsibilities include creating a culture of ethical business conduct and commitment to compliance, maintaining a work environment that encourages employees to raise concerns, and promptly addressing employee compliance concerns.

Compliance With Laws, Rules And Regulations

You are required to comply with the laws, rules and regulations that govern the conduct of our business and to report any suspected violations in accordance with the section below entitled "Compliance With Code Of Ethics."

Conflicts Of Interest

Your obligation to conduct the Company's business in an honest and ethical manner includes the ethical handling of actual or apparent conflicts of interest between personal and professional relationships. No Covered Person shall make any investment, accept any position or benefits, participate in any transaction or business arrangement or otherwise act in a manner that creates or appears to create a conflict of interest unless the Covered Person makes full disclosure of all facts and circumstances to, and obtains the prior written approval of, the Audit Committee of the Board.

Disclosures

It is Company policy to make full, fair, accurate, timely and understandable disclosure in compliance with all applicable laws and regulations in all reports and documents that the Company files with, or submits to, the Securities and Exchange Commission and in all other public communications made by the Company. As a Covered Person, you are required to promote compliance with this policy and to abide by Company standards, policies and procedures designed to promote compliance with this policy.

Compliance With Code Of Ethics

If you know of or suspect a violation of applicable laws, rules or regulations or this Code of Ethics, you must immediately report that information to the Chairman of the Audit Committee of the Board. No one will be subject to retaliation because of a good faith report of a suspected violation.

Violations of this Code of Ethics may result in disciplinary action, up to and including termination or dismissal. The Audit Committee of the Board shall determine, or shall designate appropriate persons to determine, appropriate action in response to violations of this Code of Ethics.

Waivers Of Code Of Ethics

If you would like to seek a waiver of this Code of Ethics you must make full disclosure of your particular circumstances to the Audit Committee of the Board. Amendments to and waivers of this Code of Ethics will be publicly disclosed as required by applicable law and regulations.

No Rights Created

This Code of Ethics is a statement of certain fundamental principles, policies and procedures that govern the Covered Persons in the conduct of the Company's business. It is not intended to and does not create any rights in any employee, customer, user, supplier, competitor, shareholder or any other person or entity.

Consent

I have received, read and understand Travelzoo’s Guide to Business Conduct and Ethics, as well as this Code of Ethics. I, hereby agree to comply with all of provisions of each policy and consent to the terms thereof.

Signature of Covered Person

____________________________

____________________________

(print or type name)

____________________________

(Date)