Anti bribery and corruption policy

The Metropole Hotel is committed to the highest standards of ethical conduct and integrity in its business activities. It recognizes that any involvement in bribery will also reflect adversely on its image and reputation.

Any form of bribery (direct or indirect) by, or of, its employees, Board Members, Agents, Consultants or any person or body acting on its behalf will not be tolerated.
The purpose of this policy is to set out for Board Members and employees of the Metropole the aim of limiting the Metropole exposure to bribery by:

SETTING OUT A CLEAR ANTI-BRIBERY POLICY
Training all employees and Board Members so that they can recognize and avoid the use of bribery by themselves and others;
Encouraging its employees to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately;
Rigorously investigating instances of alleged bribery and assisting police and other appropriate authorities in a resultant prosecution;
Taking firm and vigorous action against any individual(s) involved in bribery.

THE METROPOLE PROHIBITS
The offering, the giving, the promising, the solicitation or the acceptance of any bribe, whether cash or other inducement.
To or From any person or company, wherever they are situated and whether they are a public official, body, private person or company.
In order to gain any commercial, contractual or regulatory advantage for the Metropole in a way that is unethical.
Or in order to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.

BREACHING THE POLICY
A breach of the Metropole’s anti-bribery policy by employees will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct and immediate dismissal.
A breach of the Metropole’s anti-bribery policy by Board Members will be dealt with in suspension and removal from the Board.
Employees and other individuals acting for the Metropole should note that bribery is a criminal offence that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for the Metropole.

EMPLOYEE AND BOARD RESPONSIBILITY
The success of this policy depends on all employees and Board Members and those acting for the Metropole where bribery is suspected reporting in accordance with the Metropole Public Interest Disclosure (Whistle Blowing Procedure) set out in the Staff Handbook and Irregularity Procedure.

RELATED POLICIES AND PROCEDURES
Irregularity Procedures
Probity Policy
Confidentiality Policy
Staff Handbook
Board Members Misconduct Procedure
Hospitality Policy

REVIEW AND MONITORING
The Managing Director is responsible for the implementation of the policy.
The policy will be reviewed annually. Reviews will be initiated by the Managing Director. Where changes in employment legislation or regulatory requirements occur that directly affect this policy, these will be reflected with immediate effect and communicated by HR team.
The Boards are responsible for monitoring implementation of the policy and all incidents will be reported to the Audit Committee under the arrangements for reporting irregularities. The Metropole Board is responsible for approving the annual review.

Modern Slavery Act 2015

This transparency statement by Metropole Hotel (Llandrindod Wells) Ltd acknowledges the provisions of the Modern Slavery Act 2015. Metropole Hotel is committed to operating with integrity and accountability. That commitment applies both within the organisation and in our relationships with suppliers. We adopt a zero-tolerance approach to slavery and human trafficking. We are committed to taking all reasonably practicable steps to ensure that slavery and human trafficking is not present either in our operations or supply chains. Metropole Hotel recognises that slavery and human trafficking are not issues which are confined to the overseas hospitality sector. In particular we recognise and are assessing the risks that arise from the use of foreign and migrant labour, and from supply chains both in the UK and overseas.

 

JUSTIN BAIRD-MURRAY
Managing Director
2nd April 2019