It is Travelife’s policy to conduct all of our business in an honest and ethical manner. We take a zero- tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

The purpose of this policy is: –

To set out the responsibilities of Travelife and of those working for and with us, in observing and upholding our position on bribery and corruption; and

To provide information and guidance to those working for and with us on how to recognise and deal with bribery and corruption issues.

Bribery and corruption are punishable for individuals by up to ten years’ imprisonment and if we are found to have taken part in corruption, we could face an unlimited fine and damage to our reputation. We therefore take our legal responsibilities very seriously.

We have identified that the following may be particular risks for our business:

The refusal or termination of Travelife subscription may jeopardise a company’s ability to trade and may therefore act as an incentive for bribes to be offered.

Corporate hospitality and gifts: There is a risk that corporate hospitality, such as customer or supplier entertainment, and the giving or receiving of gifts might be seen as bribery, especially in dealings with foreign public officials.

Facilitation payments: These are payments demanded by officials (or others) simply to secure or expedite the performance of their normal duties (for example, granting a licence, allowing goods to cross a border, and so on). These are commonplace in some jurisdictions, but the making of such payments, regardless of how small, will be an offence under the Act.

We have frequent interactions with public officials, sometimes in high-risk jurisdictions.

We make awards in various jurisdictions, some of which may be considered high risk and in countries where corruption is perceived to be high.

This policy applies to all individuals working at all levels for Travelife, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), committee members, auditors, consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors or any other person associated with us, wherever located (collectively referred to as workers in this policy).

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

For the purpose of the UK Bribery Act 2010, offences can fall under four categories; offering a bribe, receiving a bribe, bribing a foreign official and failure to prevent bribery by a corporate organisation.  Each of these categories are described in more detail below.

Offering a Bribe

The offering, promising or giving of a reward to induce a person to perform a relevant function or activity improperly.

For example, you offer a potential supplier tickets to the Travel Convention, but only if they get their company to agree to do business with us on favourable terms.  This would be an offence as you are making the offer to gain a commercial and contractual advantage. We may also be found to have committed an offence because the offer has been made to obtain business for us. It may also be an offence for the potential supplier to accept your offer.

Receiving a Bribe

The accepting of, agreeing to accept or requesting of a reward in return for performing a relevant function or activity improperly.

For example, Supplier promises to give you free accommodation on your next family holiday, but makes it clear that in return they expect you to give them a favourable audit score.  It is an offence for a Supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage.

Bribing a Foreign Official

This is a specific offence involving trying to influence a foreign public official, with the intention of obtaining or retaining business, in a situation where the public official was not permitted or required by law to be influenced.

For example, you arrange for Travelife to make a secret payment to a foreign official to speed up an administrative process such as clearing our goods through customs for the Travel Convention.  The offence of bribing a foreign public official has been committed as soon as the offer is made. This is because it is made to gain a business advantage for us. We may also be found to have committed an offence.

Failure to Prevent Bribery by a Corporate Organisation

This – the ‘Corporate offence’ – occurs when an organisation fails to stop people who are operating on its behalf from being involved in bribery.  This offence of failing to prevent the act of bribery could occur as a result of the activities of a range of people working on behalf of the organisation – an employee, consultant, auditor or agent, for example – if those individuals were involved in accepting or receiving a bribe which resulted in the organisations gaining or retaining business.

This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties provided the following requirements are all met:

1. It is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
2. It complies with local law; it is given in our name, not in your name.
3. It does not include cash or a cash equivalent (such as gift certificates or vouchers).
4. It is appropriate in the circumstances. For example, in the UK it is customary for small gifts to be given at Christmas time.
5. Taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time.
6. It is given openly, not secretly.
7. Gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of a Travelife Senior Manager.

We appreciate that the market practice of giving business gifts varies between countries and regions, and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

What is not acceptable?

It is not acceptable for you (or someone on your behalf) to:

• Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given.
• Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure.
• Accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them.
• Accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return.
• Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy.
• Engage in any activity that might lead to a breach of this policy.

Facilitation Payments and Kickbacks

We do not make facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. They are not commonly paid in the UK, but are common in some other jurisdictions.

If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt that details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with a Travelife Senior Manager.

Kickbacks are typically payments made in return for a business favour or advantage. All workers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

Donations

We do not make contributions to political parties, unless obligatory when attending party conferences or events. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of a Travelife Senior Manager.

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify a Travelife Senior Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a company, Supplier or potential Supplier offers you something to gain a business advantage with us or indicates to you that a gift or payment is required to secure their business. Further “red flags” that may indicate bribery or corruption are set out at the end of this policy.

We must keep financial records and have appropriate internal controls in place that will evidence the business reason for making payments to third parties.

You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.

You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.