CODE OF CONDUCT IN BUSINESS RELATIONSHIPS

Introduction

At Goodwood Park Hotel (“Hotel”), our values and principles define who we are and how we do business. We strongly believe that acting responsibly, ethically, lawfully and in the best interests of the Hotel at all times is the right thing to do.

This Code of Conduct in Business Relationships (“Code”) provides an ethical framework, general principles and overall guidance for business conduct required of all members of the board of directors and employees (“Employees”) of Goodwood Park Hotel and our subsidiaries and associated companies (“The Company”), including but not limited to, third party service providers, agents, consultants, business partners, vendors and contractors performing work for the Hotel or on its behalf (collectively referred to as “GPHPL Personnel”). It is designed to ensure clarity and consistency in how Employees conduct themselves both within the Company and in their dealings outside of the Company.

The provisions of the Code is not meant to cover every possible situation and may be amended, modified or supplemented without prior notice at the Company’s discretion. All Employees and GPHPL Personnel must strictly adhere to the Code and abide by the applicable laws and regulations in their everyday work. Failing to comply will lead to disciplinary action up to and including immediate termination of employment or business relationship, arrest and prosecution for any criminal acts.

Code of Ethics

Employees’ Responsibility

a) Employees shall at all times:

  • Be familiar with and comply with the Company’sinternal policies and processes;
  • Abide by applicable laws, rules and regulations;
  • Be accountable and adhere to the Code prescribed by the Company.

b)  Employees shall ensure that procurement contracts are awarded and administered free from improper influence.

c) Circumstances might arise that could call the Employee’s impartiality into question. When any such conflict of interest arises, the Employee shall promptly consult and involve the Compliance Manager in evaluating the potential conflict of interest.

d) Partners or family members shall not receive personal benefits as a result of an Employee’s position at the Company.

e) Employee should not hold other appointments outside the Company without prior approval of the General Manager, and if required, the approval of a Director.

f) Employees must disclose any outside activities, financial interest or relationship that may pose a real, potential or perceived Conflict of Interest to the Compliance Manager. Where Employees are not sure what to declare or whether or when a declaration needs to be made, they are strongly encouraged to be prudent and seek advice from the Compliance Manager.

g) Employees shall comply with Company guidelines regarding the acceptance of gifts and hospitality.

h) Real or perceived conflicts of interest in the procurement process should be avoided at first instance, and where unavoidable and inevitable, proper disclosure must be made.

i) Any concerns regarding compliance with the Company’s Code shall be raised and reported immediately to the Compliance Manager.

 Free Competition and Fair Dealing

a) All procurements are expected to be done in line with this Code. It is expected that the process of identifying potential/shortlisted vendors is documented and justified. The responsibility of justifying purchases with only one or less than the required number of vendors based on the Company’s procurement requirements lies with the individual/department requesting for the purchase.

b)  Circumstances that are prejudicial to the principles of open competition between vendors need to be highlighted to the appropriate parties for proper review. This process should include documented declarations on potential conflicts and should include any business interests in vendors through association (eg: relatives/friends, etc.).

c) Employees shall select suppliers and award business on the basis of fair competition.

d) Arrangements with or among suppliers that could potentially limit or distort competition shall be avoided.

e) Employees shall not require or encourage suppliers to undertake activities or incur costs when there is minimal probability of obtaining business within a reasonable period, unless the supplier is made aware of all the circumstances.

f) Employees must never lead a supplier or client to believe that they can inappropriately influence any procurement decisions at the Company.

g) The Company works with business partners and suppliers who uphold the virtues of integrity and fairness towards their stakeholders. They must also observe both the laws of the countries in which they operate or are incorporated.

 Anti-Money Laundering (AML) Compliance

The Company is committed to combating money laundering and complies with all applicable laws and regulations concerning AML efforts.

a) Employees should be responsible for applying appropriate level of due diligence when entering into client relationships and, where applicable, individual transactions.

b) No Employee, either alone or in collaboration with third parties, shall take measures that violate domestic or foreign regulations on money laundering.

Protection and Proper Use of Company’s Assets and Intellectual Property

a) Employees shall not misuse, waste or steal the Company’s assets (including but not limited to, inventory, equipment, funds, networks, computers, email, facilities, complimentary items, discount vouchers, trademarks, copyrights, literary/artistic works, business ideas, trade secrets, systems information and confidential data).

b) Employees must not give away, dispose or remove any of the Company’s assets/intellectual property from the Company’s premises without permission or use them for inappropriate purposes.

Reporting Violations

a) Employees are under a duty to promptly report any suspected or observed violations of the law, of this Code or of the Company’s policies to the Compliance Manager. External parties who want to report such concerns can email to: ccbr@goodwoodparkhotel.com. All feedback will be taken seriously and shall be properly investigated.

 All feedback/ reports will be treated with the utmost discretion and confidentiality.

 Effective Date: August 2018

Good wood park