• We believe that openness and transparency promote informed decisions, understanding, and trust. We give everyone - whether an employee, a guest, or a business partner - the opportunity to speak up if they experience something that does not seem right, to come forward with confidence against unethical behaviour without concern for any negative consequences.
• We aim to provide a workplace, business and hotel environment that is free from any form of abusive or threatening behaviour.
• The Company offers protection against all forms of retaliation, so that no one in the company will be discriminated for voicing their concerns.
• To protect the interests of our guests, business partners, and employees, the company proactively manages risks associated with third parties by conducting appropriate due diligence, rather than relying solely on good faith.

o To avoid bribery, our employees may accept business gifts only on a limited basis, depending on the circumstances and following the specific rules applicable to them.

o Our Company will consider a customary business gift (regardless of who gives it to whom) to be acceptable if the giving or receiving of the gift meets the following requirements:

• • it is in line with local legal regulations.
  • it is given on behalf of the business partner.
  • it is appropriate to the circumstances, of the right type and value, and given at the right time, considering the reason for the gift.
  • it is not given with the intent to influence, in exchange for an implied favour or benefit, to obtain or retain business or business advantage.
  • it is non-cash or another cash substitute (e.g. vouchers or gift vouchers), excluding normal tips given to our employees directly involved in catering.

o Facilitation payments are small payments (in cash or in-kind) made to public officials for routine tasks that they are otherwise required to perform (e.g. to obtain permits, issue postal items or speed up the connection of utilities). Employees of our Company do not give or accept any Facilitation payments or kickbacks.

o Legitimate administrative fees paid to an organisation (other than an individual) and legitimate payments made for expedited procedures, as well as payments for which an invoice can be issued on request, are not considered facilitation payments.

o Our Company will not make any donations, whether in cash, kind or by any other means, to support any political parties or candidates as this may be perceived as an attempt to gain an improper business advantage.

o Our Company encourages the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.

o Our Company will take all steps to ensure that charitable contributions are legal and ethical under local laws and practices and that donations are not used to facilitate or cover up acts of bribery. Donations may only be offered/transferred through the compliance officer of our company with prior approval of the compliance officer of CP Holdings Limited.

o Making false statements or providing false data, abuse of position, and withholding information are considered high-risk, common behaviours that are classified as risks of unlawful conduct. Financial reporting, procurement, and sales are high-risk areas for our Company, and we have implemented special customer due diligence procedures for these areas. To ensure transparency in its operations, the Company operates a preventive framework designed to eliminate unlawful conduct through the coordinated application of multiple safeguards. This framework is built around our employees, our processes, and our governance mechanisms to effectively mitigate risks.

o The most important elements of prevention include risk assessments, internal audits, segregation of duties, a system of approval authorities, due diligence, training, and ongoing oversight of implementation by the Board of Directors, which is linked to accountability.

Regarding employment conditions, the Company is committed to the following principles, which it equally requires from its business partners:

IV.3. Employees in private life should

Tax: for the purposes of this Policy, all mandatory monetary payments required by the state or other public authority on the basis of law, which must be made by individuals and organizations without receiving direct, individual compensation for this.

Tax evasion: tax evasion refers to behaviour where a person, in relation to an obligation to make payments into the public budget or to funds originating from the public budget:

• deceives another person, keeps them in error, makes a false statement, or conceals a material fact in connection with an obligation to pay into the public budget;
• unlawfully claims or takes advantage of a tax benefit, allowance, or relief connected with an obligation to pay into the public budget; or
• uses funds originating from the public budget for purposes other than those for which they were approved.

Tax evasion means the offence of cheating the public revenue or fraudulently evading UK tax and is a criminal offence. The offence requires an element of fraud, which means that there must be a deliberate action or omission with dishonest intent.

Foreign tax evasion: foreign tax evasion means evading tax in a country other than that of the Company, provided that the conduct is an offence in that country and would be a criminal offence if committed in the UK or any other relevant country. As with tax evasion, the element of fraud here as well, in line with Hungarian legal terminology, means there must be deliberate action or omission with dishonest intent.

hereafter as, tax evasion and foreign tax evasion together as Tax evasion

Tax avoidance: in a broader sense, it refers to the use of arrangements that may formally comply with the law but are primarily intended to reduce the tax burden and often run counter to the legislature’s intent. In some cases, the authorities may classify these as abusive.

Facilitating tax evasion or tax avoidance: this means that a person knowingly participates in fraudulent tax evasion or tax avoidance committed by another person (whether involving a UK tax, or a tax of any other country), or takes steps, provides assistance, encourages, advises, or assists in the commission of this offense. Facilitating tax evasion or tax avoidance is a criminal offense if done intentionally and dishonestly.

Third party: any individual or organization with whom one of our employees comes into contact in the course of their work at the Company; this includes actual and potential customers, clients, suppliers, distributors, business partners, agents, consultants, as well as government and public bodies—including their advisors, representatives, and officials, as well as politicians and political parties.

If our company fails to prevent its employees or third parties from facilitating tax evasion or tax avoidance, it may face sanctions—including unlimited fines —and in light of this, we consider it important that our Parent Company, in line with the relevant policies of CP Holdings Ltd.:

what to do if they encounter tax evasion, tax avoidance or its facilitation

The policy applies to all persons working for the Company or any Companies where we have influence on our behalf in any capacity including employees of all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners, sponsors, or any other person associated with us wherever they are located. 

The CP Group has identified that the following are particular risks to the business:

• Work status of contractors in a form that can easily qualify as a disguised employment relationship or assignment or other legal relationship,
• Tax status of third parties / suppliers, particularly, but not exclusively registration in a tax haven, if the identity of the beneficial owner cannot be known from public data base
• Compliance with construction industry scheme
• Labor not provided by companies with a special license
• Sub-contractors
• Non-cooperative countries where business is performed;
• Changes in invoice details – bank account, dates of services, company name 
• Cross border transactions

In addition to the above following is a list of possible red flags that may arise while you work for us, and which may raise concerns related to tax evasion or foreign tax avoidance.

If you encounter any of these red flags or if a business partner: 

• has filed or intends to file a false tax return, or has failed to file a tax return,
• has failed to disclose income or gains to the tax authorities,
• has set up or intends to set up a business structure to try to hide income, gains, or assets from the tax authorities,
• you become aware that an employee asks to be treated as a self-employed contractor, but without any material changes to their working conditions. 
• has deliberately failed to register for VAT (or the equivalent tax in any relevant non-UK jurisdiction) or failed to account for VAT.
• requests payment in cash not payment through an account held at a recognized bank and/or refuses to sign a formal commission or fee agreement or to provide an invoice or receipt for a payment made. 
• requests that the regulations concerning the reverse charge mechanism not be applied;
• requests that payment is made to a country or geographic location different from where the third party resides or conducts business,
• insists on the use of “side letters” (a separate agreement that hides the actual content of the contract (order) or refuses to put terms agreed in writing or asks for contracts or other documentation to be backdated, 
• asks us to change the description of services rendered by us on an invoice to another service,
• an invoice is received from a third party that appears to be non-standard or customised,
• an invoiced is received for a commission of fee payment that appears too large or too small, given the service stated to have been provided, 
• requests or requires the use of an agent, intermediary, consultant, distributor or suppler that is not typically used by or known to us. 

the incident must immediately be reported to the supervisor.

The Board of Directors of the Company have overall responsibility for ensuring this Policy complies with our legal and ethical obligations and that all those under our control comply with it. 

The CP Group Compliance Officer (Group Compliance Officer) has primary and day-to-day responsibility for implementing the policy issued by CP Holdings Ltd., while the Company Compliance Officer (Company Compliance Officer) for the monitoring of its use and effectiveness, dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in preventing the facilitation of tax evasion and tax avoidance. 

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and head of HR is responsible for ensuring adequate and regular training on it. 

Under the CFA 2017, a separate criminal offence is automatically committed by a legal or corporate entity or partnership where the tax evasion, tax avoidance or its facilitation is done by a person acting in the capacity of an ‘associated person’ to that body. For the offence to be made out the associated person must deliberately and dishonestly take action to facilitate the tax evasion by the taxpayer. If the associated person accidently ignorantly or negligently facilitates the tax evasion, or tax avoidance then the corporate offence will not have been committed. The Company does not have to have deliberately or dishonestly facilitated the tax evasion itself, the fact that the associated person has done so creates the liability for the Company. 

Tax evasion is not the same as tax avoidance (tax optimisation) or tax planning. Tax evasion involves deliberate and dishonest conduct. Tax avoidance is not illegal and involves taking steps within the law to minimise tax payable. 

What you must not do

It is not acceptable for any employee (or someone else acting on behalf of the employee) or any third party:  

• to engage in any form of facilitating tax evasion or tax avoidance. 
• to aid, abet, counsel or procure the commission of a tax evasion offence or offence by another person. 
• to fail to promptly report any request or demand from any third party to facilitate the fraudulent evasion or avoidance of tax (whether UK tax or tax in any other country) or any suspected fraudulent evasion or avoidance of tax (whether UK tax or tax in a foreign country) by another person in accordance with this policy. 
• to engage in any other activity that might lead to a breach of this policy; or 
• to threaten or retaliate against another individual who has refused to commit a tax evasion offence or who has raised concerns under this policy. 

Responsibilities of employees

All employees must ensure that they read, understand and comply with this policy. 

The prevention, detection and reporting of tax evasion and tax avoidance are the responsibility of all those working for Companies belonging to CP Holdings Ltd. or under its control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. 

The employees must notify their direct manager as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future. For example, if an employee or supplier asks to be paid into an offshore bank account, without good reason, or a supplier asks to be paid in cash, indicating that this will mean the payment is not subject to applicable tax. 

How to raise a concern

Employees are encouraged to raise concerns about any issue or suspicion of tax evasion or tax avoidance at the earliest possible stage including in relation to potential “Red flags”. 

If an employee becomes aware of any fraudulent evasion or avoidance of tax (whether UK tax or tax in any other country) by another person in the course of your work, or you are asked to assist another person in their fraudulent evasion of tax (whether directly or indirectly) or if you believe or suspect that any fraudulent evasion or avoidance of tax has occurred or may occur, whether in respect to UK or tax in a foreign country, you must notify your direct manager as soon as possible. 

If an employee is unsure whether a particular act constitutes tax evasion, or tax avoidance, or not raise it with your direct manager as soon as possible. You should note that the corporate offense is only committed where you deliberately and dishonestly take action to facilitate the tax evasion or tax avoidance. However, a deliberate failure to report suspected tax evasion or tax avoidance or “turning a blind eye” to suspicious activity, could amount to criminal facilitation of tax evasion or tax avoidance. 

Protection

Individuals who raise concerns or report another’s wrongdoing are sometimes worried about possible repercussions. The aim of CP Holdings Ltd. and the Company is to encourage openness and support anyone who raises genuine concerns in good faith under this policy even if they eventually turn out to be mistaken. 

CP Holdings Ltd. and the Company are committed to ensuring no one suffers any detrimental treatment as a result of: 

• refusing to take part in, be concerned in or facilitate tax evasion or tax avoidance by another person, 
• refusing to aid, abet, counsel or procure the commission of a tax evasion offence or a tax avoidance offence by another person; or 
• reporting in good faith their suspicion that an actual or potential tax evasion offence or tax avoidance offence has taken place or may take place in the future. 

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If an employee believes that he has suffered any such treatment, he should inform the compliance manager immediately. If the matter is not remedied, any you are an employee, you should raise it formally by filing a report through the whistleblowing channels in line with our Whistleblowing Policy.   

Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary; it may also form part of a training for relevant employees aimed at detecting and preventing financial crimes.

Our zero-tolerance approach to tax evasion and tax avoidance must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate after that, who by accepting our Code of Ethics also accept and acknowledge this Policy.  

Breaches of this Policy

We will initiate proceedings against any employee who violates the provisions of this Policy, and a finding of a breach of obligations or a serious breach of obligations may result in employment-related disciplinary measures. Furthermore, we will terminate our business relationship with any third party that violates the provisions of this Policy.

A These regulations apply to:

•   all business activities of the Company, that is, all business relationships, legal relationships, and transactions related to the operations, services, or collaborations of the Company, regardless of the form of the contract;

• legal entities that have a business or other cooperative relationship with the Company;
• any natural person who comes into direct or indirect contact with the Company, including:
• individuals providing services and sole proprietors,
• contributors and agents,
• employees of the Company, and
• within the framework of applicable laws - guests using the Company’s services.

In the course of its business activities, the Company pays particular attention to

•   the European Union,

•   the United Nations,

•   the United States of America,

•   the United Kingdom,

•   as well as compliance with sanctions and restrictive measures imposed by applicable domestic laws.

The Company requires that any person or company associated with it in any capacity:

•   not be subject to sanctions or embargoes;

•   not engage in any activity aimed at directly or indirectly circumventing sanctions;

•   comply with applicable laws and the principles of ethical business conduct in the course of their business operations or when utilizing the services provided by our Company, in accordance with the Code of Ethics of the Company.

• Sanctions: International, EU, Hungarian, or other regulatory measures that restrict business activities with certain countries, organizations, or individuals.
• Embargo: A foreign trade restriction that prohibits certain goods, services, or financial transactions.
• Business partner: Any legal entity or individual with whom the Company has a legal relationship or conducts a transaction.

The Company is entitled to:

• request additional information in the event of a risk;
• screen its business partners using publicly available databases and sanctions lists
• (e.g. Sanctions Map);
• refuse to establish or terminate a business relationship where justified,

 These measures serve the responsible and transparent operating principles set forth in the Company’s Code of Ethics.

The Company reserves the right to refuse or terminate the establishment of a legal relationship or the execution of a transaction that:

• conflicts with the fundamental principles of this Policy, or
• although permitted under applicable Hungarian or European Union laws and not subject to sanctions or embargoes, is contrary to the values set out in the Company’s Code of Ethics, or
• entails disproportionate legal, financial, or reputational risk.

Any violation of the fundamental principles set out in this Policy may result in the termination of the business relationship, the enforcement of claims for damages, and/or taking other legal actions.

If you have any questions, concerns, or would like further information, please contact our company using the contact details below:

E-mail: [email protected]

The Company regularly reviews this policy in light of changes in legislation and business risks, ensuring that it always complies with current sanctions and embargo regulations.