Policies

• Bombay Travel Service LLP is dedicated to using ethical business methods, in particular, to always adhering to the anti-bribery and anti-corruption legislation that are in effect in all the nations in which the Group conducts business (collectively, the Anti-Corruption Laws).
• The anti-bribery and corruption policy document (the Policy guiding)’s principles are applicable to all global business operations of the Group. The Group is of the opinion that long-term, prosperous business relationships are formed on honesty, fairness, and the quality of the Group’s services rather than on unethical business practises, in addition to the requirements of the law. To ensure adherence to both the Group’s ethical standards and expectations as well as compliance with anti-corruption laws, this Policy lays out specific guidelines for Group employees as well as outside parties involved in Group operations.
  
  

RESPONSIBILTY FOR COMPLIANCE WITH THIS POLICY:

This Policy applies to all Group Personnel and all of the Group’s Business Partners. For these purposes:

• Chairman means the Chairman of Bombay Travel Service LLP
• Group means Bombay Travel Service LLP and any branch, business or division operated by or under the control of the foregoing from time to time;
• Group Internal Audit means the internal audit department serving the Group;
• Group Personnel includes all employees, officers, and directors of the Group and any of them;
• Business Partners includes all third parties who are specifically appointed to engage in business for or on behalf of the Group.
• MD means the Managing Director of Bombay Travel Service LLP or the president, as applicable;
• D-IA means Director Internal Audit.

 

PROHIBITION AGAINST BRIBES AND IMPROPER PAYMENTS

• Making or accepting bribes in the course of conducting Group business is forbidden, as is providing or receiving any financial or other advantage to or from any party with the intent to persuade or reward the inappropriate performance of an action. Although bribes can take many different forms, they typically have a corrupt motive. Usually, there will be a quid pro quo where both parties gain something. Any promise, offer, or permission of something of value, as well as the offering or acceptance of any kickback money, reward, or other benefit, whether direct or indirect, constitute bribery.
• Bribery is the offer, promise, provision, demand, or acceptance of a benefit in exchange for a behaviour that is forbidden or unethical. Corruption is the abuse of public position or power for personal benefit or the abuse of private power in the context of non-governmental enterprises.
• Bribery and corruption are intended to sway someone’s execution of their task and persuade them to act dishonestly. If any Group Personnel violates paragraph 3.1, disciplinary action, including termination, may be taken against that person. Bribes and other illegal payments cannot be made through the employment of middlemen.
• The policy’s ban on accepting bribes or engaging in other unethical payment practises has no exceptions. The fact that Group Personnel, for instance, may be conducting business in a nation where they believe corruption is pervasive, is part of the culture or way of doing business, where the legal requirements governing bribery are murky, or in a transaction where a Group employee has been approached for a bribe, will not be used as an excuse for engaging in improper payment activity. Evidence of improper behaviour by the Group’s competitors will also not be considered. Even if this results in lost sales, no Group Personnel or Business Partner will incur negative effects for refusing to engage in inappropriate payment activities.

EXTORTION AND REQUEST TO CARRY OUT IMPROPER PAYMENT ACTIVITY

• Extortion and any other requests for erroneous payments made under duress shall be rigorously resisted by the Group. Payments that are necessary in extraordinary circumstances to protect a person’s health or safety must be justified by local senior management and will be subject to audit. All such payments must be disclosed to D-IA for additional review.
• Group Personnel should never take part in illegal payment practises simply because a management or fellow employee told them to. If such a circumstance ever occurs, the person involved must notify D-IA in line with the applicable procedures.

GUIDELINES ON SPECIFIED ACTIVITIES

The following “Guidelines” explain how the Policy applies to certain types of activities:

FACILITATING PAYMENTS

• The member of the Group in question may, under certain conditions, be entitled to pay a public servant without breaking the relevant anti-corruption laws. For what are known as “facilitating payments,” which are payments made to government personnel in order to hasten or ensure the fulfilment of a routine government operation, some anti-corruption laws provide a limited exception (Facilitating Payments).
• For instance, under this exception, it might be acceptable to make a Facilitating Payment in order to obtain permits, licences, or other documents that would allow the Group member in question to conduct business in a particular nation, to process official documents like work orders and visas, to offer police protection, to schedule inspections, to pick up and deliver mail, to provide phone service, to provide power and water, or to load and unload cargo. Except in certain limited circumstances where a Facilitating Payment is legal and inevitable, it is Group policy not to make or permit any sort of Facilitating Payments. The Chairman or one of the MDs must approve each Facilitating Payment. Furthermore, each and every Facilitating Payment will be honestly and accurately recorded and accounted for.

GIFTS

• Anyone with whom the Group transacts business may not give or receive gifts from you if doing so would go beyond the usual courtesies connected with recognised standard business practise. This rule is in place to make sure that neither the giving nor receiving of a gift imposes any obligations on the parties involved or gives rise to claims of favouritism, discrimination, or other wrongdoing on the part of third parties.
• Giving or receiving cash as a gift is strictly forbidden.
• You must speak with your supervisor and/or the head of your company unit right away if you are asked to give gifts that are excessive for social customs or that might appear improper. When accepting a present would violate local laws, be seen as intended to influence a business decision, or appear to put the recipients of the gift in a conflict of interest, it is best to decline the offer.

BUSINESS ENTERTAINMENT & HOSPITALITY

• Meals, invites to parties, events, or other social gatherings in connection with topics relating to the Group’s business are all considered forms of hospitality. As long as they stay within permissible boundaries, these activities are permitted.
• It is acknowledged that reasonable and appropriate hospitality is a recognised and significant component of conducting business. Reasonable and proportionate hospitality aims to enhance the Group’s reputation, better market its services, or develop friendly ties. Hospitality must be designed to persuade someone to carry out a task inappropriately in order for it to qualify as a bribe.

An individual’s judgement must be used to determine whether a specific type of business entertainment or hospitality is acceptable. When making this decision, consider the following:

• Is it to develop a connection or is there another goal in mind?
• Use the “newspaper test” to determine whether a newspaper would be likely to report on the company hospitality or entertainment and, if so, what the public’s reaction would be. For instance, if publicised, an all-expenses paid international golfing weekend before a tender review would almost surely create a negative impression.
• Would you feel confident defending the amusement or hospitality to Group management?
• If you have trouble responding to one of these questions, there may be a risk involved that could perhaps harm the Group’s business and reputation.
• The following situations are typically acceptable: modest/occasional dinners with a party with whom the Group conducts business; infrequent attendance at athletic, theatrical, and other cultural events; or infrequent participation in social gatherings.
• The following situations are not acceptable: hospitality or entertainment that is provided as part of a “quid pro quo”; and improper entertainment.
• The kind of relationship you have with the host or guest, the cost of living and style of living in the area, and the types of appropriate business entertainment or hospitality there will all influence the kind and expense of acceptable business entertainment or hospitality. Consult your supervisor or the head of your business unit if you are unsure about what is appropriate in a certain circumstance.
• It is important to use extra caution when entertaining government representatives.
• Expenses for business entertainment or hospitality must be accurately reported in the books and records of the Group member.

SPONSORED TRAVEL

• In the right situations, the Group may reimburse customers, potential customers, and others for reasonable and legitimate travel costs that are directly related to: advertising or demonstrating the Group’s services; carrying out a contract with the Customer; or undertaking a fact-finding mission to comprehend relevant foreign markets and regulatory environments.
• These costs must be reasonable for the firm and only cover what is required to achieve that goal.
• Sponsored travel expenditures need advance written consent.

POLITICAL CONTRIBUTIONS

• You cannot donate to any political party or publicly funded international organisation without the Chairman or one of the MDs’ prior written consent.

BUSINESS PARTNERS

• No Business Partner may be retained unless they are evaluated, chosen, and retained in accordance with the procedures and guidelines established for doing so. As a minimum, basic contract clauses relating to compliance with anti-corruption laws and this Policy shall be included in all written agreements with Business Partners.
• Business Partners may only be paid by wire transfer or check; cash payments are never accepted. All payments will be made in accordance with invoices, receipts, or other records that specifically detail the services provided. This standard contract language will be included in all agreements with Business Partners.
• Business Partners can only be hired after performing the necessary amount of due diligence. Ownership, background checks, examinations of letters of recommendation, examinations of credentials, examinations of financial statements, contacts with local Chambers of Commerce, independent confirmation of the candidate’s history of employment in government, and assessment of the candidate’s additional connections to government officials, including family ties, are a few examples of what may be included in this due diligence.
• The concerned business manager will be in charge of making sure that all “red flags” have been looked at and eliminated.

DOING BUSINESS WITH GOVERNMENT

• Group when interacting with any government official, staff members must use extra caution. When interacting with a government official, actions that could be appropriate or legal when working with private sector partners may be wrong or criminal. Any Group Personnel who has concerns about whether interactions with government representatives are appropriate should get in touch with D-IA right away.

COMPLIANCE

• All Group Personnel are accountable for comprehending and observing this Policy.

IMPLEMENTATION

• The execution of this Policy and making sure that staff members are aware of it are the responsibilities of local management. Anyone working for the Group who has a query about the Policy should direct it to his local management. Through the internal auditing process, Group Internal Audit will keep an eye on how this Policy is being applied.

RECORD KEEPING

• All expenditures of the member’s finances must be completely and fairly reflected in all of the Group members’ books and records. The creation of false or deceptive records is prohibited. All of the Group members’ books and records must comply with these standards.
• No payment on behalf of any Group member may be allowed without sufficient supporting paperwork or made with the understanding that all or a portion of the payment would be utilised for reasons other than those stated in the supporting documentation.
• No “off the books” accounts or other hidden or unrecorded funds belonging to any Group member may be set up for any use. No payments may be sent, either directly or indirectly, to unidentified or unknown receivers or to anybody else with whom the Group employee in charge of upholding the relationship cannot vouch for their reliability.

BREACHES & REPORTING

• Group Personnel who violate this policy may face disciplinary action, including termination, and/or may be reported to local or state law enforcement agencies. The person who violated the Anti-Corruption Laws could also face harsh civil or criminal sanctions, such as hefty fines and possibly lengthy jail sentences. Breach of this policy for Business Partners will result in the end of their partnership with the Group.
• All those covered by this Policy are obligated to notify D-IA as soon as they become aware of any violations.