Anti Bribery Policy
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Purpose
The purpose of this policy is to establish controls to ensure compliance with all applicable
anti-bribery and corruption regulations and to ensure that International Hospitality Recruitment Ltd
conducts its business in a socially responsible manner.
Policy Statement
Bribery is defined as the offering, promising, giving, accepting, or soliciting of an
advantage as an inducement for action which is illegal or a breach of trust. It is our policy to conduct
all 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.
Who is covered by the policy?
This policy applies to all individuals working at all levels
and grades, including senior managers, officers, directors, employees, consultants, contractors,
trainees, volunteers, interns, agents, sponsors, or any other person associated with International
Hospitality Recruitment Ltd, or any of its subsidiaries or their employees, wherever located.
Covered activities
This policy covers:
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Bribes
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Gifts and hospitality
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Facilitation payments
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Political contributions
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Charitable contributions
Your responsibilities
You must 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 International Hospitality Recruitment Ltd.
You must notify your manager or the Company Secretary or the confidential helpline as soon as
possible if you believe or suspect that a conflict with or breach of this policy has occurred or may
occur in the future.
Training and communication
Training on this policy forms part of the induction process for all new employees.
All employees will receive regular, relevant training on how to implement and adhere to this policy.
Record-keeping
We must keep financial records and have appropriate internal controls in place.
You must declare and keep a written record of all hospitality or gifts accepted or offered, subject to
managerial review.
What to do if you are a victim of bribery or corruption
You must inform the Company Secretary or the confidential helpline as soon as possible if you are
offered a bribe by a third party or believe that you are a victim of another form of unlawful activity.
How to raise a concern
You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest
possible stage.
If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other
queries or concerns, these should be raised with your line manager, the Company Secretary, or
through the confidential helpline.
Protection
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's
wrongdoing, will be supported and protected.
Responsibility for the policy
The board of directors has overall responsibility for ensuring this policy complies with legal and
ethical obligations.
The Company Secretary has primary responsibility for implementing and monitoring this policy.
Monitoring and review
The Company Secretary will monitor the effectiveness and review the implementation of this policy
regularly.
Employees are invited to comment on this policy and suggest ways in which it might be improved.
This policy does not form part of any employee's contract of employment and may be amended at
any time.