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Code Of Ethics

In TRAVEL ASSOCIATES LTD we believe that strong ethics and good business should go together naturally. We are committed to operating our company with integrity and in accordance with the highest ethical standards. Our reputation is built upon the trust and confidence of all our stakeholders, and is an integral part of our vision to make TRAVEL ASSOCIATES LTD one of the very best companies in Kenya.

The following Code of Ethics and Business Conduct (‘The Code’) sets out the principles and standards describing how we should work and behave, wherever we are in the world. It applies to all directors, officers and employees of TRAVEL ASSOCIATES LTD and should be read together with the company’s core values (our ‘Winning Ways’).

All employees have a responsibility to behave ethically and protect the reputation of the company. These principles lie at the heart of who we are, and nothing should ever compromise our commitment to honesty and integrity.

Responsibility for Compliance with the Code

All directors, officers and employees are responsible for abiding by the Code. This includes responsibility for the failure to exercise proper supervision and the responsibility to report a violation by subordinates. Disciplinary action may, when appropriate, include dismissal.

The standards set out in the Code are necessarily general .Where appropriate; guidance should always be sought from management. In addition, the Company Managing Director and his deputy are available on a confidential basis as independent sources of advice.

Health and Safety

We are all responsible for helping to maintain a safe and healthy working environment in line with local laws and regulations and in accordance with our internal standards.

Equal Opportunities

We recruit and promote individuals based solely on their suitability for the job without discriminating on the grounds of race, colour, ethnic or national origin, gender, sexual orientation, age, religion, marital status or disability unrelated to the role.

Harassment

We will not tolerate harassment of any employee by any person, for any reason.

The Environment

We are committed to preserving and protecting the environment and to economic growth and prosperity. These goals are not only consistent but mutually reinforcing. Protecting the environment is an investment in all our futures. We are also committed to constructive participation with all stakeholders in the ongoing process of sustainable growth.

Conflicts of Interest

We must always act in the best interests of TRAVEL ASSOCIATES LTD and avoid any personal preference or advantage. This includes situations where personal, family or financial interests conflict with those of TRAVEL ASSOCIATES LTD, or where an employee holds an interest in an organization seeking to do business with the TRAVELASSOCIATES LTD. If you encounter a potential conflict of interest you must disclose the details and stand back from any related decision-making process. In addition, you should avoid apparent conflicts of interest which occur where a reasonable observer might assume there is a conflict of interest and, therefore, a loss of objectivity in your dealings on behalf of the TRAVEL ASSOCIATES LTD

Relationships with Business Partners

It is in TRAVEL ASSOCIATES LTD best interests to establish mutually beneficial commercial relationships with our guests, suppliers and business partners. Offering or accepting gifts, entertainment or personal favors is only acceptable if their value is modest and the practice is consistent with local business culture. Employees should not accept gifts, entertainment or favors which might place him or her under any obligation or which would reasonably be viewed as influencing business transactions. Any gift or hospitality of more than token value must be reported to senior management who will determine whether it can be accepted.

Competition

TRAVEL ASSOCIATES LTD is committed to open, free and fair competition in all our markets.We will compete vigorously but honestly, observing all competition and local laws as stipulated by the Government.

Fraud

TRAVEL ASSOCIATES LTD will not tolerate fraud of any description. Our employees have an obligation to report any suspicious of fraud in accordance with the Disclosure Procedures detailed at the end of this Code.

Property, Assets and Resources

TRAVEL ASSOCIATES LTD resources are protected and not be used for personal gain. This includes tangible assets such as stocks, equipment and cash, in addition to intangible items such as intellectual property, computer systems and confidential information. Information held within the Group such as business plans, pricing, financial data and guest details remain the property of TRAVEL ASSOCIATES LTD and are not disclosed outside the Group without prior permission. The storage and use of guest data may be further subject to data a privacy regulation which is complied with.

Political Activity and Contributions

We are all free to take part personally in political activities in our own time. However, we must not create the impression that we represent the TRAVEL ASSOCIATES LTD in these matters. In dealing with regulatory and public policy issues that affect the TRAVEL ASSOCIATES LTD , we do not make party political donations but deal with the government of the day on matters which concern the business.

Records, Disclosure and Communications

As a private company, we are required to comply with the rules relating to laws of Kenya .In accordance with our disclosure obligations, financial communications and reports will be delivered in a manner that facilitates the highest degree of clarity of content and meaning so that readers and users will be able to quickly and accurately determine their significance and consequence. Matters relating to the activities and performance of the TRAVEL ASSOCIATES LTD must not be discussed with representatives of the other companies .Our Management will co-ordinate any announcements, statements or responses to questions from the media, particularly those which relate to hotel industry or commercially sensitive information.

Legal Compliance

We are committed to compliance with the laws and regulations of Kenya and jurisdictions in which we operate. In the unlikely event that a local law or regulation conflicts with the Code, you should continue to comply with the law but employees must report the circumstances of the conflict to the Management.

Disclosure Procedures

TRAVEL ASSOCIATES LTD provides a stepped approach for raising questions or concerns overinterpretation or violation of the Code. We do not permit retaliation against employees making good faith reports of suspected breaches of the Code.

Social Security Contributions and Taxes

All social security contributions including NSSF and NHIF are regularly and timely made. All taxes including PAYE and Corporate Tax are paid whenever due.