1. Introduction and basic principles
Objective :
The purpose of the code of ethics is to make Anima transparent Travel , clearly defines the operating principles and clearly demonstrates to our partners and passengers the values we represent. With the help of the guidelines, we strengthen trust and develop a unified set of values.
Default values :
The Anima Travel's core values include integrity, transparency, responsibility and sustainability. We are committed to supporting the environment, fostering collaboration with local communities and prioritizing long-term sustainability in all our activities. We are committed to fair business conduct and ethical decisions.
Scope :
The Code of Ethics applies to everyone who works at Anima . Travel , including employees, managers, partners and customers. The guidelines expect everyone involved to behave ethically and uphold our core values.
2. Ethical behavior in business
Business integrity : Fair competition, anti-corruption, gift-giving rules.
Compliance with contracts : Respect for legal regulations and contractual obligations.
Data protection and confidentiality : Protecting the data of customers, partners and employees.
The Anima It is Travel's policy to conduct all of its business activities in a fair and ethical manner. We have a zero tolerance policy towards bribery and corruption and are committed to acting professionally, fairly and honestly in all our business dealings and relationships, wherever we operate, and to implementing and enforcing effective systems against bribery.
We comply with all laws related to combating bribery and corruption in all jurisdictions in which we operate.
The purpose of this policy is to:
a. to define the Anima Travel , and the responsibility of us and those who work with us to comply with and enforce our position on bribery and corruption; and
b. provide information and guidance to us and those who work with us on how to identify and address bribery and corruption issues.
Bribery and corruption are punishable as crimes against individuals, and if we are found to have engaged in corruption, we could face fines and reputational damage. That is why we take our legal obligations very seriously.
We have identified the following as potential risks to our business:
- Corporate hospitality and gifts: Corporate hospitality, such as entertaining customers or suppliers, and the giving or receiving of gifts may constitute bribery, especially in dealings with foreign public officials.
- Facilitation payments: These are payments requested by officials (or others) simply to secure or expedite the performance of their usual duties (e.g. issuing permits, allowing goods to cross borders, etc.). In some jurisdictions, these are commonplace , but such payments, no matter how small, are unacceptable.
- We frequently come into contact with public officials, sometimes in high-risk jurisdictions.
- We litigate in a variety of jurisdictions, some of which are considered high risk, and in countries where corruption is considered high.
Who does the policy apply to?
This policy is everything, Anima It applies to all individuals working for Travel at all levels, including senior managers, officers, directors, employees (permanent, fixed-term or temporary), board members, auditors, consultants, contractors, interns, seconded staff, home workers, casual and agency workers, volunteers, trainees, agents, sponsors or any other person associated with us, regardless of where they are located (collectively referred to in this Policy as employees).
What is bribery?
Bribery is an offer, promise or giving of an inducement or reward to obtain a commercial, contractual, regulatory or personal advantage. The offences fall into four categories:
Offering a bribe: offering, promising or giving a reward in order to induce a person to improperly perform a relevant task or activity.
For example: you offer a potential TO tickets to the Travel Congress, but only if he persuades his company to do business with us on favorable terms.
This would be a criminal offence as you are making the offer to gain a commercial and contractual advantage. We could also be committing a criminal offence as we made the offer to gain business for ourselves. It could also be a criminal offence if the potential TO accepts your offer.
Accepting a bribe: accepting, agreeing to accept, or requesting a reward in exchange for improper performance of a relevant function or activity.
For example, the TO promises to give you free accommodation on your next family vacation, but makes it clear that in return, it expects you to give it a favorable audit score.
It is a crime for TO to make such an offer. If you accept the offer, it is also a crime, as you gain personal advantage by doing so.
If you accept the offer, it will be considered a crime, as you will gain personal advantage by doing so.
Bribery of a (foreign) public official: this is a specific crime that involves attempting to influence a foreign public official with the intent to obtain or retain business in a situation where the public official is not permitted or required by law to influence.
For example, you arrange for Travelife to secretly make a payment to a foreign official to expedite an administrative process, such as customs clearance of our goods for the Travel Agreement.
The crime of bribing a foreign public official is committed from the moment the offer is made. This is because the offer was made to gain a business advantage for us. It can also be established that we have committed a crime.
Failure to prevent bribery: this - a "corporate crime" - occurs when an organization fails to prevent individuals acting on its behalf from engaging in bribery.
The crime of failing to prevent bribery may be committed as a result of the actions of persons working on behalf of the organization, such as employees, consultants, auditors or agents, if those persons were involved in accepting or soliciting a bribe that resulted in the organization obtaining or retaining business.
Gifts and hospitality
This policy does not prohibit customary and appropriate hospitality (giving and receiving) to or from third parties.
The giving (or receiving) of gifts is not prohibited if the following conditions are met:
a. the gift is not made with the intention of obtaining or retaining a business or business advantage from a third party, or of rewarding the granting or retention of a business or business advantage, or of influencing a third party in exchange for an express or implied favour or advantage;
b. complies with local legislation;
c. is done in our name, not in your name;
d. does not include cash or a cash equivalent (such as a gift certificate or voucher);
e. appropriate in the circumstances. For example, in the United Kingdom it is customary to give small gifts at Christmas;
f. taking into account the reason for the gift, the gift is of an appropriate type and value and is given at an appropriate time; and
g. is given openly, not secretly; and
h. the Anima No gifts may be offered or accepted to government officials or representatives, or politicians or political parties, without prior approval from a senior Travel manager.
We recognise that market practices for giving business gifts vary from country to country and region to region, and what is normal and acceptable in one region may not be in another. The test to be applied is whether the gift or hospitality is reasonable and appropriate in all the circumstances. The intention behind the gift should always be considered.
What is not acceptable?
It is not acceptable if you (or someone on your behalf):
a. Giving, promising or offering payment, gift or hospitality with the expectation or hope of receiving a business advantage or in return for a business advantage already given.
b. Giving, promising, or offering a payment, gift, or hospitality to a government official, agent, or representative to “facilitate” or expedite a routine procedure.
c. Accept any payment from a third party that you know or suspect is being offered with the expectation that it will provide them with a business advantage.
d. Accept a gift or hospitality from a third party if you know or suspect that it is being offered or provided with the expectation that we will receive a business advantage in return.
e. Threaten or retaliate against another employee who has refused to commit bribery or who has raised concerns under this policy.
f. To engage in any activity that may lead to a violation of this policy.
Aid and abetment
We do not provide facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to a government official to secure or expedite routine government action. They are not customary in some countries, but are common in some other jurisdictions.
If you are asked to make a payment on our behalf, always consider what the payment is for and whether the amount requested is proportionate to the goods or services provided. Always ask for a receipt detailing the reason for the payment. If you have any suspicions, concerns or questions about a payment, these should be raised with a Travelife senior manager.
Bribes are generally payments made in exchange for a business favor or advantage. All employees must avoid any activity that could lead to or suggest that our company is making or accepting a favor or bribe.
Donations
ethical under local laws and practices . No donation should be offered or made without the prior approval of the senior manager.
Your responsibilities
You must ensure that you read, understand and comply with this policy.
Preventing, detecting and reporting bribery and other forms of corruption is the responsibility of everyone who works for us or is under our control. All employees are required to avoid any activity that could lead to or appear to violate this policy.
You must notify your manager as soon as possible if you believe or suspect that an incident that violates this policy has occurred or may occur in the future. For example, if a company, supplier or potential supplier offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business. Additional “red flags” that may indicate bribery or corruption are provided at the end of this policy.
Register
We must maintain financial records and implement appropriate internal controls that demonstrate the business rationale for payments to third parties.
You must report and maintain a written record of all hospitality or gifts accepted or offered, which will be reviewed by management.
You must ensure that all claims for reimbursement of hospitality, gifts or expenses to third parties are submitted in accordance with our reimbursement policy and specifically record the reason for the expense.
All accounts, invoices, notes and other documents and records relating to dealings with third parties, such as customers, suppliers and business contacts, must be prepared and maintained with strict accuracy and completeness.
Accounts that facilitate or conceal irregular payments should not be kept “ off- book ” .
How to raise concerns
We encourage you to raise concerns or suspicions of misconduct at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other questions, these should be raised with a Travelife senior manager.
What to do if you have been a victim of bribery or corruption?
Travelife as soon as possible. Senior Manager if a third party offers a bribe, if you are asked to pay a bribe, if you suspect that this may happen in the future, or if you believe that you have been the victim of other illegal activity.
Protection
Employees who refuse to accept or offer bribes, or those who raise concerns or report misconduct by others, sometimes worry about the potential consequences. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they are proven to be wrong.
We are committed to ensuring that no one is treated adversely for refusing to engage in bribery or corruption, or for reporting in good faith that they suspect actual or potential bribery or other corruption offences have occurred or may occur in the future. Adverse treatment includes dismissal, disciplinary action, threats or other adverse treatment related to raising a concern.
If you believe you have been subjected to such treatment, please notify your compliance manager immediately.
Training and communication
Our zero tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the beginning of our business relationship with them and as necessary thereafter.
Potential risk scenarios: “red flags”
Below is a list of potential “red flags” that may arise during your work with us that may raise concerns under various anti-bribery and corruption laws. The list is not exhaustive and is for illustrative purposes only.
If you encounter any of these red flags while working with us, you must report them immediately to your Travelife Senior Manager:
a. if you become aware that a third party is engaging in improper business practices or is accused of engaging in improper business practices;
b. if you become aware that a third party has a reputation for paying bribes or demanding bribes or for having a “special relationship” with foreign government officials;
c. a third party insists on receiving a commission or fee before committing to enter into a contract with us or performing a governmental task or process for us;
d. a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement or refuses to provide an invoice or receipt for the amount paid;
e. a third party requests payment to a country or geographic location that is different from the third party's place of residence or place of business;
f. a third party charges an unexpected additional fee or commission to “facilitate” a service;
g. the third party demands lavish entertainment or gifts before initiating or continuing contractual negotiations or providing services;
h. a third party requests that the payment “disregard” any potential legal violations;
(i) a third party requests that you provide a job or other benefit to a friend or relative;
j. you receive an invoice from a third party that appears to be non-standard or customized;
k. a third party insists on the use of cover letters or refuses to record the terms of the agreement in writing;
l. You notice that a commission or fee has been charged that appears to be large in relation to the service allegedly provided;
m. a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that we do not typically use or that we are not familiar with;
n. a third party offers you an unusually generous gift or lavish hospitality.
Bribery
Employees do not offer, promise or give, request, agree to or accept any undue financial or other advantage to public officials or employees of business partners.
Consumer rights
Employees will respect consumers' privacy at all times and take reasonable measures to ensure the security of personal information they collect, store, process or distribute.
Fair competition
Employees shall refrain from entering into or implementing anti-competitive agreements between competitors, including agreements to:
- fixing prices;
- manipulated offers ( collusive tenders);
- setting production restrictions or quotas; or
the division or partitioning of markets by allocating customers, suppliers, territories, or lines of trade
3. Internal relations and workplace behavior
Equality and respect : Non-discrimination, equal opportunities, respectful treatment.
Preventing harassment and abuse : Rejecting any form of harassment and abuse.
Workplace Safety : Maintaining a healthy and safe work environment.
Equality and respect
Anima Travel is committed to providing an equal opportunity and non-discrimination environment. We treat all our employees and partners with respect and do not tolerate discrimination based on race, gender, religion, age, disability or any other personal characteristic.
Preventing Harassment and Abuse
We strongly oppose any form of harassment, abuse or exploitation. We expect everyone in the workplace to contribute to a supportive and positive atmosphere in which everyone feels safe.
Workplace Safety
A healthy and safe working environment is of paramount importance to us. We ensure that the tools and conditions necessary for working comply with regulations and provide the opportunity to immediately report safety issues and potential risks.
4. Environmental protection and sustainability
Sustainable operations : Striving for environmental protection and sustainable development.
Waste management : Efficient use of natural resources and promotion of recycling.
By traveling with our colleagues to domestic and distant landscapes, reading a lot, and talking, we get more and more inspiration, our journeys are born from these experiences and discovered messages. We love history, art, and the cultural history of different eras, we are fascinated by the beauty, colors, and flavors of the created world, and we seek the way to other cultures. On our walks in Budapest, on our country wanderings, and on our European trips, we relax, recharge, and learn. Arriving on other continents of the world, the inner journey, reflecting on other cultures, and meeting locals can be even more special. Our programs are born as workshops, and we compose something new every week.
The Anima Sustainable development and environmental protection are of paramount importance to Travel . In our operations, home We prefer the office system, so waste production and environmental impact are minimal. When organizing programs, we prioritize environmentally friendly solutions, such as train and bicycle trips, as well as ecotourism opportunities. The attitude of our employees is also in line with these principles and they actively contribute to the implementation of sustainability.
5. External relations
Customer relations : Providing correct information, handling complaints and ensuring customer satisfaction.
Relationship with partners : Transparency and mutual respect in business relationships.
Social responsibility : Community support, helping local communities.
Contact with customers
The Anima Travel pays special attention to always providing its customers with correct and accurate information. When planning and organizing trips, transparency is a basic principle that ensures that passengers receive all important information in a timely manner. We take complaints seriously in all cases, and our goal is to handle them quickly, fairly and with our customers' satisfaction in mind. If necessary, we also try to restore trust with compensation. It is no coincidence that we have many regular passengers who return to us regularly, as we have proven to them that we operate as a reliable and customer-oriented organization.
Relationships with partners
Transparency and mutual respect are the foundation of our business relationships. When working with our partners, we always strive for open communication and clear agreements, which result in the development of long-term, fruitful relationships. We recognize the work of our partners and treat them with respect, as without their contribution we could not achieve our common successes. Our commitment to transparent operations also means security and predictability for our business partners.
Passenger education and social responsibility
It is an important goal of ours to educate our passengers to adopt a sustainable approach, which is why we regularly organize educational programs and eco-conscious trips. Our programs often include social elements, such as supporting local communities or donation opportunities, thereby strengthening the role of social responsibility in tourism. We also organize an annual tree planting campaign, during which our passengers and employees work together to protect the environment, thereby contributing to the alleviation of global environmental problems.
6. Reporting and accountability mechanisms
Reporting system : Method for reporting violations of ethical rules (e.g. confidential hotline, email).
Protective measures : Protection of whistleblowers from retaliation.
Liability : Consequences of violating ethical rules.
Dealing with internal problems
In case of problems related to work or internal relations, you can confidently turn to [colleague XY], who will always help you find a solution discreetly and impartially.
Safeguards
It is of utmost importance to us that whistleblowers are protected from any discrimination or retaliation. We guarantee that whistleblower rights are respected so that everyone can feel safe when reporting ethical issues.
Accountability
Violations of ethical rules can have serious consequences. We thoroughly investigate each case and take appropriate action depending on the severity of the situation. These actions may include a warning, further training, or, if necessary, termination of employment. We aim to ensure that the organization operates in accordance with ethical expectations at all levels.
7. Final provisions
Update and maintenance : Regular review of the code.
The Anima Travel is committed to keeping its Code of Ethics up-to-date and relevant. We therefore regularly review its content to reflect changes in legislation, market trends and the development of the organisation. Maintaining the Code ensures that our values and operating principles are always of the highest standard and meet the expectations of our customers, partners and colleagues. We take into account experience and feedback when updating it, so that the document continues to provide practical guidance for our daily activities.