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Anti-Corruption, Anti-Bribery, Compliance Provisions

1. INTRODUCTION

Premier Destination Services Inc., (“Premier”) is a global corporation comprising a network of entities affiliated with or controlled by Premier, a company registered in the State of Florida, United States of America. Premier has strict anti-bribery, anti-corruption, compliance, privacy and data protection policies (the “Policies”) that apply to all Premier services worldwide.

For ease of reference, these Policies apply to Premier’s dealings with counterparties in both the public and commercial sectors. In addition, these Policies set out the basis on which any Personal Data (as defined below) Premier collects from you, or that you provide to Premier, will be processed. Premier expects business partners and others within the Premier supply chain (the “Suppliers”) to comply not only with Premier’s Policies, but also with applicable bribery, corruption, compliance and data protection laws (the “Laws”) from May 2018 the European Union’s General Data Protection Regulation (“GDPR”).

All of the above information is in order to maintain the highest ethical standards of business conduct which apply to all dealings with, on behalf of, or involving Premier.

2. STATEMENT OF POLICIES

Premier does not tolerate any form of bribery or corruption and it is a requirement that Premier staff, consultants, contactors and/or agents, as well as Suppliers comply with both the letter and the spirit of these Policies and all applicable Laws.

Premier will not, directly or indirectly, engage in bribery and/or corruption in any form and has a zero tolerance approach to breach, whether it involves private individuals or public officials. Premier will never accept, solicit, agree to receive, promise, offer or give a bribe, facilitation payment, kickback or other improper payment.

3. BRIBERY

For purposes of these Policies, “bribery” means receiving or offering a financial or other advantage, intended to induce someone (with either public or private responsibilities) to give improper assistance in breach of their duty, in bad faith and dishonesty. It also consists of improperly influencing someone with the underlying purpose of obtaining/retaining business, or an advantage in the course of business.

4. SCOPE OF POLICIES & PROHIBITIONS

Premier’s Policies apply to Premier staff, consultants, contactors and/or agents, as well as Suppliers performing work for or on behalf of Premier. All the aforementioned shall refrain from and have strictly prohibited to:

1. Engage in acts of corruption, offering or accepting bribes, including any financial payment or other form of benefit offered to any government official, for influencing any decision that it should take and that is contrary to any Laws.
2. Participate in any transactions (including financial transactions) using privileged information owned by Premier or allow the improper use of such information for their benefit. This provision includes disclosing confidential or privileged information that may be used for illicit purposes.
3. Take part in actions of corruption, both actively (offering and/or paying bribes) and/or passively (accepting the pressure resulting from extortion).
4. Provide any gratification (including economic benefit of any kind), to any public official or in customs in any jurisdiction, in order for them to omit and/or refrain any of their official acts and thereby ensure or accelerate any operation that relates to the area in which they operate.
5. Accept a gift or hospitality from a third party if they know or suspect that it is offered or provided with an expectation that a business advantage will be provided by Premier in return;
6. Threaten or retaliate against another member of Premier, including but not limited to staff, consultants, contactors and/or agents, Suppliers and/or other who have refused to commit a bribery offence.

Please take note the list above is not exhaustive and Premier will revise this as and when needed.

5. VIOLATION & FAILURE TO COMPLY WITH THESE POLICIES

Premier staff, consultants, contactors and/or agents, as well as Suppliers who contravene these Policies and/or Laws may expose Premier practices and themselves to significant criminal and/or civil sanctions.

A failure to act in accordance with the letter and spirit of any applicable Laws and Premier’s Policies may result in:

1. Penalties and responsibilities, which may be exercised under the laws of one or more than one jurisdiction;
2. Damage to Premier’s corporate image and reputation, including any comments or information that comes out in the media;
3. Termination of agreements with immediate effect.
4. Other penalties as deemed necessary by Premier or according to applicable Laws.

6. PROTECTION

Premier staff, consultants, contactors and/or agents, as well as Suppliers should tell their Premier contact any time they become aware that a payment is being requested and/or demanded and that they suspect is forbidden by these Policies. This includes threats, bribes and/or blackmailing. If the aforementioned suspect a colleague of having made a payment, that is not permitted, they should report it directly to their Premier contact in the strictest confidence.

Premier encourages openness and will support anyone who raises in good faith, genuine concerns under these Policies even if they turn out to be mistaken. Premier is committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith his/her suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.

7. RISK ASSESSMENT & PROCEDURES

Premier regularly carries out a risk assessment identifying and prioritizing anti-corruption risks. This includes an evaluation of the jurisdictions in which Premier operates as well as for the entities and Suppliers have dealings with, third parties and the degree of interaction with public and/or government officials.

8. EDUCATION & REINFORCEMENT

Premier staff, consultants, contactors and/or agents, as well as Suppliers are not expected to be experts in the Laws applicable to them. However, they should be aware of the circumstances when Bribery and corruption concerns may arise because of any of the Laws of their own and other jurisdictions and adjust their behavior accordingly.

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