Anti-Bribery and Corruption-Statement of Values

 

1)   

In this statement of values, references to “VHS”, "we” or  “us” are to Vision Hotel Services Limited.

 

2)     

It is the policy of VHS to conduct all of our business in an honest and ethical manner, consistent at all times with our legal and professional obligations.  We take a zero-tolerance approach to bribery and corruption.  We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, as well as to implementing and enforcing effective systems to counter bribery.

 

3)    

We are committed to upholding all applicable laws to counter bribery and corruption.  The UK Bribery Act 2010 (the “Act”) applies to VHS and to those entities associated with it which have a UK connection. This statement of values has been formulated with particular reference to the Act.  Where necessary, additional procedures will be adopted in compliance with local legislation or identified risks.

 

4)     

We prohibit any practice involving bribery, regardless of local custom or expectation.

 

5)     

We recognise that transactions and good client relations are critical to our business.  This statement is not designed to stop either of those things.  However, there are ethical limits, which must be observed in the conduct of business and this statement addresses these.

 

6)      

VHS applies the standards described in this statement to everyone working for VHS, wherever they are located, including directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, agency staff, vacation students, volunteers, and interns (all “VHS Persons”). 

 

7)      

The Act applies not only to VHS Persons but also to all third parties associated with VHS who are referred to as  “associated third parties” in this statement.  Associated third parties include (but are not limited to) agents, consultants, contractors, suppliers, secondees, sponsors, experts, introducers, intermediaries, or any other person associated with us, wherever located.

 

8)    

We expect all VHS Persons to demonstrate honesty, integrity and fairness in all aspects of their business dealings and exercise appropriate standards of professionalism and ethical conduct in all their activities. We expect the same approach to doing business from all third parties associated with VHS.

 

9)    

VHS is absolutely committed to ensuring that all VHS Persons have a safe, reliable and confidential way of reporting suspicious activity relating to bribery or other criminal behaviour, either by another VHS Person or by a hospitality client or associated third party.  Any VHS Person can confidentially report any suspicion of bribery to Steve Mitchell.

 

10)     

 We:

(a) do not directly or indirectly offer, promise, give, accept or demand a bribe or other undue advantage (including excessive     gifts and hospitality) in order to obtain or retain business, or gain any improper advantage.

(b) do not offer, nor give in to demands to make illicit or illegal payments to agents, public officials (at whatever level) or the employees of business partners or anybody else that we do business with.

(c) engage and remunerate third parties only for legitimate services and adopt appropriate transparency in our approach.

(d) promote employee awareness of, and compliance with, VHS’s policies against bribery and corruption through appropriate dissemination of our own procedures (including disciplinary procedures) policies and training programmes.

(e) do not make illegal or inappropriate contributions to candidates for public office or to political parties or to other political organisations.

(f) raise awareness of the need to combat bribery and corruption with our business partners by publication of this Statement of Values and (where appropriate) relevant contractual provisions and support initiatives designed to reduce the risk of bribery and corruption.

 

11)   

 If you have any questions regarding this statement of values or our approach to bribery and corruption, please contact Steve Mitchell.

Steve.Mitchell@vision-am.com  Finance Director for Vision Asset Management