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This Financial Restatement Recovery Policy (this “Recovery Policy”) is adopted by Booking Holdings Inc. (the “Company”) as of December 1, 2023, as required by Section 10D of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), Rule 10D-1 under the Exchange Act, and the applicable Nasdaq Stock Market listing standards (collectively, the “Recovery Rules”). The purpose of this Recovery Policy is solely to comply with the Company’s obligations under the Recovery Rules and is not intended to obligate the Company to recover more than is necessary to comply with the Recovery Rules. This Recovery Policy is intended to apply independently of all other clawback, recoupment, or forfeiture policies, agreements or other arrangements of the Company (including the Company’s Incentive-Based Compensation Clawback Policy) (collectively, “Other Clawback Policies”), subject to the terms and conditions set forth herein. All capitalized terms used but not defined in the body of this Recovery Policy have the definitions set forth in Section G.

Each Executive Officer is subject to this Recovery Policy and is required to execute a Recovery Policy Participation Agreement in the form attached as Exhibit A. Failure by an Executive Officer to execute a Recovery Policy Participation Agreement does not impact the applicability or enforceability of this Recovery Policy.

If the Company is required to prepare a Covered Financial Restatement, the Company will seek reasonably promptly the recovery of any Excess Incentive Compensation received by a Specified Officer during the three Completed Fiscal Years immediately preceding the applicable Triggering Date. The Company’s obligation to recover Excess Incentive Compensation from a Specified Officer is not dependent on if, or when, the applicable restated financial statements are filed. A Specified Officer will be required to forfeit or repay the Excess Incentive Compensation within a reasonably prompt period of time determined by the Compensation Committee following the date such Specified Officer is informed that such Specified Officer has received Excess Incentive Compensation from the Company Group, and the Compensation Committee shall determine such period of time by taking into consideration all applicable facts and circumstances. Any action by the Company to recover Excess Incentive Compensation under this Recovery Policy from a Specified Officer shall not, whether alone or in combination with any other action, event or condition, be deemed (i) “good reason” or term of similar import or to serve as a basis for a claim of constructive termination under any benefit or compensation arrangement applicable to such Specified Officer, or (ii) to constitute a breach of a contract or other arrangement to which such Specified Officer is party.

Subject to the Recovery Rules, the Compensation Committee has discretion to determine the method by which Excess Incentive Compensation is recovered from the applicable Specified Officers; provided, that (i) to the extent the applicable Excess Incentive Compensation consists of amounts that have been received by, but not yet paid to, such Specified Officer, such unpaid amounts shall be forfeited; (ii) to the extent any remaining Excess Incentive Compensation consists of amounts paid to such Specified Officer in shares of Company common stock that are still held by such Specified Officer, such Specified Officer shall be entitled to satisfy the

obligation to repay such Excess Incentive Compensation by returning such shares of Company common stock; and (iii) without limiting the foregoing, such Specified Officer shall have the discretion to elect to repay any Excess Incentive Compensation in any combination of cash or shares of Company common stock. Any Excess Incentive Compensation received by a Specified Officer that has subsequently been forfeited prior to payment thereof (including as a result of termination of employment or breach of contract) shall be deemed to have been repaid in accordance with this Recovery Policy.

To the extent that the application of this Recovery Policy would provide for recovery of Incentive Compensation that the Company recovers pursuant to Section 304 of the Sarbanes-Oxley Act or Other Clawback Policies, the amount the relevant Specified Officer has already reimbursed the Company will be credited to the required recovery under this Recovery Policy. There shall be no duplication of recovery under this Recovery Policy, Other Clawback Policies, and the Sarbanes-Oxley Act.

The Company must seek to recover Excess Incentive Compensation pursuant to this Recovery Policy except to the extent the conditions of (i), (ii), or (iii) of this sentence are satisfied, including the Company’s compliance with any additional requirements set forth in the applicable Recovery Rules related thereto, and the Compensation Committee has made a determination that recovery would be impracticable: (i) the direct expense paid to a third party to assist in enforcing this Recovery Policy would exceed the amount to be recovered; (ii) recovery would violate home country law of the Company where the applicable law was adopted prior to November 28, 2022; or (iii) recovery would likely cause an otherwise tax-qualified retirement plan, under which benefits are broadly available to employees of the Company, to fail to meet the requirements of 26 U.S.C. 401(a)(13) or 26 U.S.C. 411(a) and regulations thereunder.

This Recovery Policy shall be governed by and construed in accordance with the laws of the State of Delaware without regard to conflicts of law thereof or of any other jurisdiction. Any dispute, controversy or claim arising out of or relating to this Recovery Policy shall be resolved by confidential final and binding arbitration by three arbitrators conducted in New York City, New York, or such other location agreed by the parties hereto, administered by and in accordance with the then-existing American Arbitration Association rules. Any dispute regarding the scope of the arbitration (including the matters subject to arbitration and any legal issues arising in the arbitration) shall be resolved by the arbitrators. The determination of the majority of the arbitrators shall be final and binding on the parties. The parties shall each bear their own expenses in connection with any dispute under or relating to this Recovery Policy.

The Company’s Compensation Committee (the “Compensation Committee”) has the full power and authority to interpret, and make determinations under, this Recovery Policy, consistent with the Recovery Rules. All determinations and decisions made by the Compensation Committee pursuant to this Recovery Policy are final, conclusive, and binding on all persons, including each member of the Company Group, its respective affiliates, stockholders, and employees. To the extent not inconsistent with the Recovery Rules, the Compensation Committee may delegate its authorities under this Recovery Policy to the Chair of the Compensation Committee.

This Recovery Policy shall only apply to Incentive Compensation received on or after October 2, 2023. The Board may amend this Recovery Policy from time to time in its sole discretion. This Recovery Policy shall not limit the rights of the Company to take any other actions or pursue other remedies that the Company may deem appropriate under the circumstances, applicable law, or Other Clawback Policies. This Recovery Policy and determinations and decisions made by the Compensation Committee pursuant to this Recovery Policy shall be binding and enforceable against all Specified Officers and their beneficiaries, heirs, executors, administrators, or other legal representatives. Any Excess Incentive Compensation recovered pursuant to this Recovery Policy may be publicly disclosed in the Company’s discretion, subject to applicable law.

“Completed Fiscal Year” means (i) any completed fiscal year of the Company and (ii) any transition period resulting from a change in the Company’s fiscal year within or immediately following any such fiscal year except that a transition period between the last day of the Company’s previous fiscal year-end and the first day of its new fiscal year that comprises a period of nine to 12 months shall be deemed to be a completed fiscal year.

“Covered Financial Restatement” means an accounting restatement required due to material noncompliance by the Company with any financial reporting requirements under the federal securities laws, including any required accounting restatement to correct an error in previously issued financial statements that is material to the previously issued financial statements or that would result in a material misstatement if the error were corrected in the current period or left uncorrected in the current period. The following shall not constitute a Covered Financial Restatement: (i) out-of-period adjustments; (ii) retrospective application of a change in accounting principle; (iii) retrospective revision to reportable segment information due to a change in the structure of the internal organization of the Company Group; (iv) retrospective reclassification due to a discontinued operation; (v) retrospective application of a change in reporting entity, such as from a reorganization of entities under common control; and (vi) retrospective revision for stock splits, reverse stock splits, stock dividends, or other change in capital structure.

“Excess Incentive Compensation” means (i) the amount of Incentive Compensation received by an Executive Officer on or after the date of becoming an Executive Officer (such person, a “Specified Officer”) from any member of the Company Group in excess of the amount that would have been received had it been determined based on the restated Financial Reporting Measure following a determination of a Covered Financial Restatement, and (ii) any other compensation that is computed based on, or otherwise attributable to, the amounts described in clause (i), in each case, as determined by the Compensation Committee to be the appropriate amount subject to recovery necessary to comply with the Recovery Rules. The amount of Excess Incentive Compensation shall be determined on a gross basis without regard to any taxes owed or paid by the Specified Officer on the receipt or settlement of the Incentive Compensation. For Incentive Compensation based on stock price or total shareholder return, where the amount of Excess Incentive Compensation is not subject to mathematical recalculation directly from the information in an accounting restatement, the amount shall be based on a reasonable estimate of the effect of the accounting restatement on the stock price or total shareholder return upon which the Incentive Compensation was received. This Recovery Policy applies to any Excess Incentive Compensation received by a person after such person ceases to be an Executive Officer.

“Executive Officer” means the Company’s president, principal financial officer, principal accounting officer, any vice-president of the Company in charge of a principal business unit, division or function and any other officer who performs a policy-making function, or any other person (including executive officers of a parent or subsidiary) who performs similar policy-making functions for the Company as identified by the Compensation Committee in accordance with the Recovery Rules.

“Financial Reporting Measures” means measures that are determined in accordance with the accounting principles used in preparing the Company Group’s financial statements, and any measures that are derived in whole or in part from such measures. Stock price and total shareholder return are also Financial Reporting Measures. A Financial Reporting Measure need not be presented within the financial statements or included in a filing with the Securities and Exchange Commission.

“Incentive Compensation” means any compensation that is granted, earned, or becomes vested, in whole or in part, upon the attainment of a Financial Reporting Measure and as identified by the Compensation Committee in accordance with the Recovery Rules. Incentive Compensation shall not include the following: (i) salaries; (ii) amounts received solely at the discretion of the Compensation Committee or the Board and that are not received from a pool that is determined by satisfying a Financial Reporting Measure performance goal; (iii) amounts received solely upon satisfying one or more subjective standards; (iv) amounts received solely upon satisfying one or more strategic measures or operational measures; and (v) amounts received solely based on service or the passage of time.

Incentive Compensation shall be considered to be “received” by a Specified Officer in the Company’s fiscal period during which the Financial Reporting Measure specified in the Incentive Compensation is achieved or attained, even if the payment, grant, or board or committee approval of attainment of the Incentive Compensation occurs after the end of that fiscal period.

“Triggering Date” means the earlier to occur of (i) the date the Board, a committee of the Board, or the officer or officers of the Company authorized to take such action if Board action is not required, concludes, or reasonably should have concluded, that the Company is required to prepare a Covered Financial Restatement or (ii) the date a court of competent jurisdiction, regulator, or other legally authorized body directs (in a final, non-appealable manner) the Company to prepare a Covered Financial Restatement.

This Recovery Policy Participation Agreement (this “Participation Agreement”) to the Financial Restatement Recovery Policy (the “Recovery Policy”) of Booking Holdings Inc. (the “Company”), is entered into between the Company and [NAME]. Capitalized terms used but not defined in this Participation Agreement shall have the meanings assigned to such terms in the Recovery Policy.

2.acknowledges and agrees that the undersigned shall comply with the Recovery Policy, including, without limitation, by returning Excess Incentive Compensation pursuant to, and in accordance with, the Recovery Policy and applicable law, and that the undersigned remains subject to the Recovery Policy during and after the undersigned’s employment or engagement with the Company Group;

4.acknowledges and agrees that in the event of any inconsistency between the Recovery Policy and the terms of any employment agreement to which the undersigned is a party, or the terms of any compensation plan, program, or agreement under which any Incentive Compensation has been granted, awarded, earned, or paid, the terms of the Recovery Policy shall govern; and