Hotel Insider

1. Purpose

This policy defines the standards expected from HOTEL INSIDER LTD, its directors, officers, employees, contractors, consultants, representatives, and business partners when acting for or on behalf of the company. It covers anti-corruption compliance, business ethics, commissions, referral fees, gifts, hospitality, entertainment, conflicts of interest, accurate records, and interactions with customers, vendors, partners, and public officials.

2. Scope

This policy applies to all business activities of HOTEL INSIDER LTD and to all persons and third parties acting on behalf of the company. It applies regardless of location and is intended to support compliance with applicable laws and regulations, including those of the Republic of Cyprus, as well as applicable customer, supplier, and partner requirements.

3. Anti-Corruption and Anti-Bribery Commitment

HOTEL INSIDER LTD prohibits bribery, corruption, facilitation payments, kickbacks, improper inducements, and any other form of unethical or unlawful advantage.

No person acting for or on behalf of HOTEL INSIDER LTD may offer, promise, authorize, give, request, receive, or accept anything of value for the purpose of improperly influencing a business decision, obtaining or retaining business, securing an unfair advantage, or influencing the actions of a customer, supplier, business partner, regulator, public official, or government representative.

4. Business Ethics Standards

HOTEL INSIDER LTD expects all business to be conducted honestly, fairly, and professionally. Company representatives must act in a way that protects the company’s reputation and supports trust with customers, vendors, partners, and other stakeholders.

• Act with honesty, fairness, professionalism, and accountability.
• Comply with applicable laws, regulations, contracts, and partner requirements.
• Avoid conflicts of interest and disclose them when they arise.
• Use company assets and confidential information only for authorized business purposes.
• Maintain accurate and complete business, operational, and financial records.
• Avoid misleading, deceptive, unfair, or improper business practices.

5. Commissions, Referral Fees, and Third-Party Payments

HOTEL INSIDER LTD permits commissions, referral fees, reseller fees, consultant fees, and similar commercial payments only when they are lawful, reasonable, transparent, properly approved, accurately recorded, and connected to legitimate services actually provided.

Hidden commissions, improper referral payments, kickbacks, side payments, personal payments, or payments intended to improperly influence a decision are prohibited. Any third-party payment arrangement must have a legitimate business purpose and must be documented in accordance with company procedures.

6. Gifts, Hospitality, and Entertainment

Gifts, hospitality, meals, travel, entertainment, promotional items, or other benefits must be modest, reasonable, infrequent, transparent, lawful, and connected to a legitimate business purpose. They must never be offered or accepted to improperly influence a decision or create an obligation.

7. Public Officials and Government-Related Interactions

Extra care must be taken when interacting with public officials, government employees, regulators, state-owned enterprises, public-sector customers, or persons acting in an official capacity. HOTEL INSIDER LTD prohibits payments, gifts, hospitality, travel, entertainment, charitable contributions, sponsorships, or other benefits intended to influence official action or obtain an improper advantage.

8. Conflicts of Interest

Directors, employees, contractors, and representatives of HOTEL INSIDER LTD must avoid situations where personal, financial, family, or other interests could conflict with the company’s interests or with duties owed to customers, vendors, or partners. Any actual or potential conflict of interest must be disclosed promptly to company management.

9. Accurate Books and Records

HOTEL INSIDER LTD requires all transactions, expenses, commissions, reimbursements, gifts, hospitality, discounts, credits, and other business payments to be recorded accurately and transparently. False, misleading, incomplete, disguised, or off-book records are not permitted.

10. Third-Party Representatives and Business Partners

Agents, consultants, contractors, integration partners, suppliers, vendors, and other third parties working with or on behalf of HOTEL INSIDER LTD are expected to follow standards consistent with this policy. The company may decline, suspend, or terminate a business relationship where bribery, corruption, unethical conduct, or serious compliance concerns are identified.

11. Reporting Concerns

Any suspected violation of this policy, including concerns about bribery, corruption, improper gifts, improper commissions, conflicts of interest, inaccurate records, or unethical conduct, should be reported promptly to the company’s compliance contact.

12. No Retaliation

HOTEL INSIDER LTD does not tolerate retaliation against any person who raises a concern in good faith, requests guidance, or assists with a compliance review. Reports will be handled appropriately and confidentially where possible, subject to applicable law and the need to review or address the matter.

13. Review and Enforcement

HOTEL INSIDER LTD may review and update this policy periodically. Breaches of this policy may result in corrective action, termination of business relationships, disciplinary action, legal action, or other appropriate measures.