Anti Bribery and Corruption

This page outlines the company's position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. The company will not tolerate any form of bribery by, or of, its colleagues, agents or consultants or any person or body acting on its behalf.

Under the Bribery Act 2010, a bribe is a financial or other type of advantage that is offered or requested with the:

intention of inducing or rewarding improper performance of a function or activity; or
knowledge or belief that accepting such a reward would constitute the improper performance of such a function or activity.

A relevant function or activity includes public, state or business activities or any activity performance in the course of a person's employment, or on behalf of another organisation or individual, where the person performing that activity is expected to perform it in good faith, impartially, or in accordance with a position of trust.

The Company is committed to operating with honesty and integrity at all times, and does not support or condone bribery. In general, the Company Board of Directors does not believe that it is appropriate for colleagues to accept gifts from customers, suppliers or any other person or company with which the Company has (or might have) business connections. There will be zero tolerance to such actions being undertaken.

What is Prohibited?

The Company prohibits colleagues or associated persons from offering, promising, giving, soliciting or accepting any bribe. The bribe might be cash, a gift or other inducement to, or from, any person or company.

This prohibition also applies to indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors or sub-contractors, agents or sub-agents, sponsors or sub-sponsors, joint-venture partners, advisors, customers, suppliers or other third parties.

Records

Colleagues and, where applicable, associated persons, are required to take particular care to ensure that all company records are accurately maintained in relation to any contracts or business activities, including financial invoices and all payment transactions with clients, suppliers and public officials.

Due diligence should be undertaken by colleagues and associated persons prior to entering into any contract, arrangement or relationship with a potential supplier of services, agent, consultant or representative in accordance with the Company’s procurement and risk management procedures.

Colleagues and associated persons are required to keep accurate, detailed and up-to-date records of all corporate hospitality, entertainment or gifts accepted or offered.

Corporate Entertainment, Gifts, Hospitality and Promotional Expenditure

The Company permits corporate entertainment, gifts, hospitality and promotional expenditure that is undertaken:

for the purpose of establishing or maintaining good business relationships;
to improve the image and reputation of the company; or
to present the Company’s services effectively;

Provided that it is:

arranged in good faith; and
not offered, promised or accepted to secure an advantage for the Company or any of its colleagues or associated persons or to influence the impartiality of the recipient.

The Company will authorise only reasonable, appropriate and proportionate entertainment and promotional expenditure (see Expenses policy).

This principle applies to colleagues and associated persons, whether based in the UK or overseas, however, those with remits overseas will be given further training on the specific procedures that they are required to follow.

Procedure

Any gifts, rewards or entertainment received or offered from clients, public officials, suppliers or other business contacts should be reported immediately to your Line Manager. In certain circumstances, it may not be appropriate to retain such gifts or be provided with the entertainment and colleagues and associated persons may be asked to return the gifts to the sender or refuse the entertainment, for example where there could be a real or perceived conflict of interest. As a general rule, small tokens of appreciation, such as flowers or a bottle of wine, may be retained by colleagues.

If you or an associated person wishes to provide gifts to suppliers, clients or other business contacts, prior written approval from your Line Manager is required, together with details of the intended recipients, reasons for the gift and business objective. These will be authorised only in limited circumstances and will be subject to a cap per recipient.

Colleagues and, where applicable, associated persons must supply records and receipts, in accordance with the Company’s expenses policy.

Receipt of Gift (Disclosure)

The Company has to consider the motive of the sender of any gift when deciding how the matter should be handled. Whilst a small gift sent to a colleague as a genuine token of appreciation may be acceptable, a gift of substantial financial value that is intended to influence business decisions will not. Requiring colleagues to declare all gifts is a safeguard against the latter becoming a threat to the integrity of the business.

Should you receive a gift of any kind from an existing or potential business contact, you must disclose the fact of the gift, its nature and the identity of the sender to your line manager. If the gift is anything other than a small token of appreciation having no substantial financial value, you will be required to return the gift to the sender with a polite note thanking them and explaining that it is the Company’s policy that colleagues should not receive gifts.

If, in the opinion of your Line Manager, the gift might constitute a bribe or other inducement, you will be asked to pass the gift to the Director of Operations. They will return it to the sender with a suitable letter explaining the Company’s policy and asking that it be respected in the future. Alternatively, the gift may be used as a recognition reward during Celebrate Service / Employee Appreciation week or at the Company Hotels Annual Awards, or at a local hotel event as a raffle prize.

In cases where your Line Manager agrees that the gift was sent to you as a token of gratitude for work carried out to a particularly high standard or for an exceptional level of service given, you may, at your Line Manager’s discretion, be permitted to retain the gift. Thus small gifts that are genuinely given as a token of appreciation or gratitude will be acceptable, provided that you properly declare the gift in line with this policy and provided that you do not subsequently treat the person who sent the gift more favorably than other customers/suppliers, etc.

This policy does not apply to promotional gifts, i.e. items such as stationery or pens that bear the logo or company name of another company, provided that these have no significant value, however, since it is likely that such gifts will be received by only a limited number of colleagues, they should be shared amongst other colleagues, where appropriate.

Charitable and Political Donations

Reporting Suspected Bribery

The Company considers that charitable giving can form part of its wider commitment and responsibility to the community. The Company supports a number of charities that are selected in accordance with objective criteria. The Company may also support fundraising events involving colleagues.

If you suspect that an act of bribery has taken place in your area of work, you should report this by following the Company Whistleblowing Procedure.