Trinity Tours expects all of its activities to be conducted lawfully and consistent with the highest ethical standards, with each employee (part time, contractual, temporary or full time) acting with personal integrity as well as coming forward and raising concerns should they become aware of any questionable activity involving the organisation generally. In essence, each of Trinity Tours employee (part time, contractual, temporary or full time) is responsible for:
• Acting with integrity, Conduct which is of the highest ethical standards – intellectual, financial & moral and reflects the highest levels of courtesy and consideration to others. Such conduct shall be fair and transparent and be perceived to be so by third parties
• Conduct which builds and maintains teamwork, with mutual trust as the basis of all working relationship. Ensuring constructive two way communication, accepting constructive criticism , debate as well as dissent while fearlessly acting with total conviction. Transparently conduct in a manner which ensures that people are our key and most valuable asset. Thorough respect for every employee who is to be treated with highest level of dignity. Conduct oneself in a manner which is leading from the front regarding performance achievement as well as individual development. Conduct in a manner which ensures empowered decision making at all levels.
• Conduct in a manner which shall ensure, at all times, the integrity of data or information furnished by him / her to the company. He / she shall be entirely responsible in ensuring that the confidentiality of all data of the organisation, it’s stakeholders, customers, guests, partners is retained securely and in no circumstance transferred to any outside person / party or outside storage medium in the course of normal operations without express guidelines from or, the approval of the management in writing.
• Act in such manner transparently which puts the customer first, the Company second and the self last. Utmost care for customer through anticipation of need, attention to minutest detail. Ensure excellence in service, aesthetics and style. Act in manner which takes uncompromising respect for privacy of guests along with warmth and genuine concern.
• Act and conduct with uncompromising attitude which at all times ensures the safety, security, health and environment of guests, employees and the assets of the company.
• Understanding and complying with the detailed Code of Conduct of Trinity Tours and applicable provisions of law.
• Notifying the organisation if a violation of Policy, code of conduct or the law has occurred
Fully and honestly cooperating in the investigation of an alleged violation of any organisational Policy, code of conduct or law, should it occur.
Your constant commitment to living by the Trinity Tours Values and meticulously following the Business Conduct Guidelines distinguishes Trinity Tours and each Trinity Tours Team Member . Trinity Tours brand, goodwill , integrity and reputation are directly in the hands of each Trinity Tours Team Member.
Commitment to Integrity and Business Ethic
Trinity Tours reputation as well as goodwill for integrity and business ethics should always be upheld in each transaction completely and never be taken for granted. To maintain that reputation, it is important for you to always follow these Business Conduct Guidelines as well as exercise good judgment in your decisions and actions.
As Trinity Tours employees, we may face ethical and legal questions; some may be difficult ones. We should always decide these questions in ways that are consistent with Trinity Tours Values:
• Commitment to uphold under all circumstances faith trust and trust of our customers and guests immensely and will uphold that in under
circumstances.
• Exceed the expectations of our customers and guests each time , every time with the best in services and products.
• Our uncompromising attitude for our guests safety, security and privacy guides us constantly in every aspect of service
• Committed dedication to every client’s success
• Innovation that matters—for our organisation as well as for the world
• Our organisation’s assets are our people and thus we are committed to the growth, development and welfare of our team members.
• Having empowered people at all levels, upon whom we trust as well as rely to realise our organisation’s vision.
• Trust and personal responsibility in all relationships.
Our Values in themselves may not provide obvious answers in all cases, but they should serve as the basis for the choices we make as well as decisions we take. Our Values also serve as the basis for the Business Conduct Guidelines, which provide greater guidance on the questions you may face.
Using the Business Conduct Guidelines
In all instances, each of us must obey the law and act ethically. The Business Conduct Guidelines provide general guidance for resolving a variety of legal and ethical questions for us. Employees are also expected to comply with other applicable Trinity Tours policies, directives and guidelines, some of which may or may not be referenced here. For example, employees who work in specialized areas such as procurement, Direct Service to Customers, environmental, Government relations, Accounts / Finance/ Tax , must also comply with additional functional guidelines.
It is important to bear in mind at all times that there are no simple shortcuts or automatic answers for the choices we have to make in business today. No single set of guidelines or policies can provide the absolute last word to address all circumstances. Therefore, we expect all employees of Trinity Tours to use sound judgment in all of their conduct and ask for help when needed.
Importance of Compliance
If you have any questions about interpreting or applying the Business Conduct Guidelines—or any other Trinity Tours policies, directives, or guidelines—it is your responsibility to consult your manager, Trinity Tours Counsel, or Trust and Compliance.
A violation of any Trinity Tours guideline can result in disciplinary action, including dismissal.
Furthermore, Trinity Tours policy is to comply with all laws and regulations that apply to its business. As you conduct Trinity Tours business, you may encounter a variety of laws and legal issues, including those in the areas described herein. If you have questions on specific laws or regulations, contact and seek guidance of Trinity Tours Counsel. Penalties for failure to comply with laws are severe and can result in fines, lawsuits, loss of business privileges and, in some cases, imprisonment of individuals.
Raising Concerns and Reporting Violations
If you know of, or have good reason to suspect, an unlawful or unethical situation or believe you are a victim of
prohibited workplace conduct, immediately report the matter through any of Trinity Tours
Communication Channels:
Your manager is usually the best place to start
Trinity Tours Concerns & Appeals programs include “Open Door” to higher management and
“Confidentially Speaking,” which lets you raise your concern anonymously, if you so choose.
Furthermore, these programs allow you to submit your concerns online, by email, regular mail or phone.
Non-Retaliation Policy
Trinity Tours will promptly review your report of unlawful or unethical conduct, and will not tolerate threats or acts of retaliation against you for making that report.
As part of Trinity Tours Integrated Enterprise, your workplace may include working from a Trinity Tours location, associated concern location , partner locations , third party locations , Wherever you are , you will interact with other Trinity Tours Team members and come in contact with sensitive information, intellectual property, and other valuable assets.
Whether communicating in person , over phone , online or by any other means or media including through a third party or representative Business Conduct Guidelines apply.
Work Environment
Trinity Tours strives to maintain a healthy, safe and productive work environment which is free from discrimination and harassment, whether based on race, color, religion, gender, gender identity or expression, sexual orientation, national origin, genetics, disability, age, or any other factors that are unrelated to Trinity Tours legitimate business interests.
Trinity Tours will not tolerate sexual advances, actions or comments, racial or religious slurs or jokes, or any other comments or conduct that, in the judgment of Trinity Tours management, creates, encourages or permits an offensive or intimidating work environment.
Further Trinity Tours will not tolerate sexual advances, actions or comments, racial or religious slurs or jokes, or any other comments or conduct that, in the judgment of Trinity Tours management, creates, encourages or permits an offensive or intimidating behavior towards it’s clientele, partner organization Team members, associated organization Team Member or any public in general.
Other prohibited conduct, because of its adverse impact on the work environment, includes:
Furthermore, if Trinity Tours management finds that your conduct on or off the job adversely affects your performance, that of other employees, or Trinity Tours legitimate business interests, you will be subject to disciplinary action, including dismissal.
Trinity Tours Information and Property
Trinity Tours has extensive assets of great value. These assets include valuable proprietary information,intellectual property and confidential information, as well as physical property and systems belonging to Trinity Tours or it’s clients or it’s partner as well as associated concerns. Protecting all of our assets mentioned above is critical. Their loss, theft, misuse or unauthorized disclosure can jeopardize Trinity Tours future.
You are personally responsible for protecting assets in general belonging to Trinity Tours as well as other organisations mentioned above , as well as those entrusted to you. This includes those assets that you have been authorized to provide to other Trinity Tours employees, contract personnel, clients or others. To do this, you should know and understand Trinity Tours security controls, processes and practices. You should be alert to situations that could lead to the loss, misuse, theft, or unauthorized disclosure of our assets. Furthermore, you should report those situations to your manager or to Trinity Tours management as soon as they come to your attention.
Further Trinity Tours will not tolerate disclosure without Trinity Tours management authorization of information, data , facts of any nature pertaining to any of it’s clients or client organization/s , partner organization/s, associated organization/s to any third party unless required for providing / completion of services . Information shared should be with authorization of client expressely for the purpose required or to other Trinity Team member or other associated as well as partner organization and on need to know basis only or for any legal compliance purpose.
Trinity Tours follows a strict code of privacy towards of any kind of information pertaining to it’s clients and client organisations. And privacy of such is the utmost responsibility of all Trinity Tours Team members be they be permanent , full time , part time , contractual in nature.
Proprietary and Confidential Information
As a Trinity Tours employee, you will have access to information that Trinity Tours considers proprietary. Most Trinity Tours proprietary information is confidential, p ertaining to clients and often subject to copyright, non disc losure agreements , patent or other intellectual property or legal rights. It is also the result of the hard work of Trinity Tours employees and investments made by Trinity Tours . Trinity Tours competitive advantage from this information would be lost if such information was improperly disclosed, even if the disclosure is inadvertent. To help maintain the value of this important information, it is critical that you follow all Trinity Tours safeguards for protecting that information and that you only disclose or distribute that information as authorized by Trinity Tours.
Trinity Tours proprietary information is any information that Trinity Tours owns, including for example:
Information about current and future products, services or research Business plans or projections
Earnings and other financial data
Personnel information including executive and
organizational changes
Software in object or source code form
Information of any nature of it’s clients
Information of/ related to associated/ partner concerns / vendor /
supplier organizations of trinity Tours or of their employees.
Inadvertent Disclosure
You should be careful to avoid inadvertent disclosure. Never discuss proprietary information that Trinity Tours considers confidential or which Trinity Tours has not made public with, or in earshot of, any unauthorized person. Activities where inadvertent disclosure could occur include a conversation (in person or by telephone) in any public area, in a blog or within a social network. Also, you should not discuss such information with family members or friends. They might innocently or otherwise pass the information on to someone else.
External Inquiries, Contacts, and Opportunities
Trinity Tours business activities are monitored by journalists, consultants, securities analysts and others. In ddition, as an employee of Trinity Tours , you may be recognized by these individuals or groups as having valuable expertise and be asked to provide your own insights to them, with or without compensation. You should not contact these individuals or groups or respond to their inquiries, whether online (including social media), telephonically, or otherwise, without authorization from Trinity Tours Management.
Similarly, if you receive a request for information related to Trinity Tours business from an attorney, an investigator, law enforcement, or other government official or agency, refer the requester to Trinity Tours Counsel and Management . Immediately notify Trinity Tours Counsel and Management of any such requests.
Intellectual Property
Trinity Tours Intellectual Property
As a Trinity Tours employee you will have access to and may develop Trinity Tours intellectual property. When you joined Trinity Tours as an employee be it full time or on contractual basis it is an agreement in which you assumed specific obligations relating to intellectual property. For example, you assign to Trinity Tours all of your rights in certain intellectual property you develop. That intellectual property includes such things as ideas, inventions, software, templates, publications and other materials relating to Trinity Tours current or anticipated offerings, business, research or development. Subject to the laws of each country, this applies no matter where or when—at work or after hours—you create such intellectual property. You must disclose that intellectual property to Trinity Tours and protect it like any other Trinity Tours proprietary information. In addition, you should also seek advice and direction from Trinity Tours management before you file for a patent other than through Trinity Tours , and provide Trinity Tours with copies of any patents you have applied for or obtained.
Third Party Software
You should exercise caution in obtaining third party software from others, including commercial and open source software. Software includes computer programs, databases and related documentation, and can be in any stage of development. Software may be on tangible media (e.g. CDs, portable devices and publications), or it may be downloadable or accessible for use online. The license for the software sets out the rights and obligations that must be complied with, such as how and where the software may be used, whether it may be modified or distributed and, possibly, what rights Trinity Tours is obligated to grant to others. The terms and conditions of the license agreement must be strictly followed. You must follow
applicable business unit and Office procedures of first obtaining management approval in written before you load software even if temporarily from any source onto any computer or device provided by Trinity Tours or used primarily for Trinity Tours business purposes. You must also follow those procedures before you distribute, access or receive software from inside or outside of Trinity Tours , or otherwise accept a license agreement.
Open Source Software
Do not confuse open source software with software that is in the public domain. Open source software licenses often impose obligations that could result in a conflict of interest with Trinity Tours and the inappropriate transfer of Trinity Tours intellectual property rights. If you want to be involved with or use open source software you must first obtain management approval and comply with Trinity Tours procedures in the same.
Trademarks
Trinity Tours and many other companies have trademarks—words, names, symbols or designs—that are used to identify and distinguish the company and its products. It is important that you properly use Trinity Tours and other companies’ trademarks.
For guidance on proper usage and acknowledgement of Trinity Tours and certain third party trademarks, refer to Trinity Tours management. In addition, you should not use a word, name, symbol or design as a trademark without without first going through the Naming Approval Process or seek guidance from Trinity Tours management.
External Standards Organizations
Before you participate in any external standards activity, you must get approval from management, with guidance from Intellectual Property and Standards. In addition to the obligations that you and Trinity Tours may have to the standards organization, you also need to understand your responsibilities to protect Trinity Tours intellectual property; to submit to Trinity Tours any intellectual property you create; to avoid conflicts of interest; and to comply with antitrust and other laws.
Use of Trinity Tours Assets and Premises
Protection of Trinity Tours assets, workplace environment and business interests, including compliance with legal requirements, are critical to Trinity Tours operations and marketplace integrity. All of Trinity Tours assets—proprietary information, such as Trinty Tours intellectual property and confidential information, as well as physical property and systems—should only be used to conduct Trinity Tours business or for purposes authorized by Trinity Tours management. This obligation applies whether or not you developed the information yourself, and it applies by law in virtually all countries where Trinity Tours does business.
Trinity Tours physical property and systems include equipment, facilities, information and communication systems, corporate charge cards and supplies. Trinity Tours property and systems, including Trinity Tours connections to the Internet, should also only be used for appropriate purposes. Incidental personal use of such property and systems—meaning use that is limited in duration, does not violate company policies, and does not interfere with doing your job—may be permitted by management. However, it is never permissible to use Trinity Tours systems for visiting Internet sites that feature sexual content or gambling, that advocate intolerance of others, or that are inconsistent with Trinity Tours Values and business interests. It is also inappropriate to use them in a manner that interferes with your productivity or the productivity of others.
Trinity Tours Right to Access and Use
You should understand Trinity Tours has the right to inspect your use of Trinity Tours assets, including your communications using Trinity Tours assets. You should understand that Trinity Tours does not consider any such uses of its assets to be private. Therefore, you should not place or keep any personal items, messages or information that you consider private anywhere in the Trinity Tours workplace, such as, telephone, office, or email systems, electronic files, laptops, smartphones and other personal communication devices, lockers, desks, or offices. If you choose to do so, you should understand that Trinity Tours may at any time, monitor, recover through technical or other means, and review employee communications including emails from personal email accounts, records, files, and other items Trinity Tours finds through or in its systems, assets and any other Trinity Tours areas or Trinity Tours provided facilities, for any purpose. In addition, in order to protect its employees, assets, and business interests, Trinity Tours may share outside of Trinity Tours anything it finds, such as with its outside legal or other advisors, or with law enforcement. Additionally, in order to protect its employees, assets and business interests, Trinity Tours may ask to search an employee’s personal property, including briefcases and bags, located on or being removed from Trinity Tours locations. If you use personal electronic devices for Trinity Tours -related work, then those devices may also be examined by Trinity Tours . You are expected to cooperate with all such requests. Employees, however, should not access another employee’s work space, including email and electronic files, without prior approval from management. For additional information on access to company property and employee personal property, refer to Trinity Tours management.
Leaving Trinity Tours
If you leave Trinity Tours for any reason, including retirement, you must return all Trinity Tours assets, such as documents and media which contain Trinity Tours proprietary information, and you may not disclose or use that information. Also, Trinity Tours ownership of intellectual property which you created as a Trinity Tours employee continues after you leave Trinity Tours. There have been cases in which Trinity Tours proprietary information or other assets have been wrongfully taken or misused. Trinity Tours has and will continue to take every necessary step, including legal measures, to protect its assets, other employees and customers.
Trinity Tours Handling of Your Personal Information
To the extent permitted by law, Trinity Tours and Trinity Tours authorized companies and individuals collect and maintain personal information which relates to your employment, such as compensation, medical and benefit information. As a globally integrated enterprise, Trinity Tours business processes, management structures and technical systems cross country borders. Therefore, you acknowledge that, to run its business, Trinity Tours and its authorized companies may transfer personal information about you as an employee to any of the countries where we do business. While not all countries have data protection laws, Trinity Tours has very stringent policies that are intended to protect information wherever it is stored or processed.
Access to your personal information is restricted to people with a need to know Personal information is normally released to outside parties only with employee approval, except that Trinity Tours and authorized companies and individuals may also release personal information to verify employment, to satisfy the legitimate requirements of a company or other entity which is considering acquiring some of Trinity Tours business operations, or for appropriate investigatory, business or legal reasons Likewise, in your work you may have access to personal information of others. You must ensure that you use and disclose that information only as permitted by Trinity Tours policies or practices.
Making Commitments and Obtaining Approvals
Trinity Tours approval processes are designed to help Trinity Tours protect its assets and maintain appropriate controls to run its business effectively, whether you are dealing with clients, Trinity Tours Business Partners, suppliers, or other third parties. Within these processes, authority for pricing, contract terms and conditions and other actions mayhave been delegated to certain functions and to line management. Making business commitments outside of Trinity Tours processes, delegation limits or without appropriate approvals, through side deals or otherwise, is not acceptable. Modifications of pricing, contract or service terms, must be approved by the appropriate level of management or authorized function. Do not make any oral or written commitments that create a new agreement or that modify an existing Trinity Tours agreement with a third party without approval, consistent with delegation levels. All commitments must be reported to Trinity Tours Accounting to help ensure the accuracy of Trinity Tours books and records.
Reporting, Recording and Retaining Information
Every employee records or reports information of some kind and submits it to the company and others with whom we interact. In doing so, you must ensure that all information is recorded and reported accurately, completely and honestly.
Never make misrepresentations or dishonest statements to anyone. If you believe that someone may have misunderstood you, promptly correct the misunderstanding. Reporting inaccurate or incomplete information, or reporting information in a way that is intended to mislead or misinform those who receive it, is strictly prohibited and could lead to serious consequences. The following are some examples of dishonest reporting:
Financial Controls and Reporting
As law abiding responsible company , Trinity Tours must follow strict accounting principles and standards, to report financial information accurately and completely, and to have appropriate internal controls and processes to ensure that accounting and financial reporting complies with law.
The rules for accounting and financial reporting require the proper recording of, and accounting for, revenues, costs, expenses, assets and liabilities. If you have responsibility for or involvement in these areas, you must understand and follow these rules.
Retaining Records
Employees must comply with the guidelines of the records Management Plan in their retention and disposal of Trinity Tours documents. The plan applies to information in any media, including both hard copy and electronic records such as email. It requires that information defined as “essential” be retained in a recoverable format for the duration of its assigned retention period. Information that is not essential or whose retention period has expired should be disposed of as soon as possible, unless it is subject to a document retention order issued by Trinity Tours management or Counsel.
Where such an order exists, you must strictly follow the retention requirements specified in the order until you receive a notice from Trinity Tours senior management or Counsel that the order is no longer in force.
Further, these rules also prohibit anyone from assisting others to account improperly or make false or misleading financial reports. Do not assist anyone to record or report any information inaccurately or in a way that could be misleading. You should also never provide advice to anyone outside of Trinity Tours , including clients, suppliers and Trinity Tours Business Partners, about how they should be recording or reporting their own revenues, costs, expenses, and other assets and liabilities.
Leaving Trinity Tours
If you leave Trinity Tours for any reason, including retirement, you must return all Trinity Tours assets, such as documents and media which contain Trinity Tours proprietary information, and you may not disclose or use that information. Also, Trinity Tours ownership of intellectual property which you created as a Trinity Tours employee continues after you leave Trinity Tours. There have been cases in which Trinity Tours proprietary information or other assets have been wrongfully taken or misused. Trinity Tours has and will continue to take every necessary step , including legal measures, to protect its assets, other employees and customers.
Trinity Tours Handling of Your Personal Information
To the extent permitted by law, Trinity Tours and Trinity Tours authorized companies and individuals collect and maintain personal information which relates to your employment, such as compensation, medical and benefit information. As a globally integrated enterprise, Trinity Tours business processes, management structures and technical systems cross country borders. Therefore, you acknowledge that, to run its business, Trinity Tours and its authorized companies may transfer personal information about you as an employee to any of the countries where we do business. While not all countries have data protection laws, Trinity Tours has very stringent policies that are intended to protect information wherever it is stored or processed.
Access to your personal information is restricted to people with a need to know Personal information is normally released to outside parties only with employee approval, except that Trinity Tours and authorized companies and individuals may also release personal information to verify employment, to satisfy the legitimate requirements of a company or other entity which is considering acquiring some of Trinity Tours business operations, or for appropriate investigatory, business or legal reasons Likewise, in your work you may have access to personal information of others. You must ensure that you use and disclose that information only as permitted by Trinity Tours policies or practices.
Making Commitments and Obtaining Approvals
Trinity Tours approval processes are designed to help Trinity Tours protect its assets and maintain appropriate controls to run its business effectively, whether you are dealing with clients, Trinity Tours Business Partners, suppliers, or other third parties. Within these processes, authority for pricing, contract terms and conditions and other actions may have been delegated to certain functions and to line management. Making business commitments outside of Trinity Tours processes, delegation limits or without appropriate approvals, through side deals or otherwise, is not acceptable.
Modifications of pricing, contract or service terms, must be approved by the appropriate level of management or authorized function. Do not make any oral or written commitments that create a new agreement or that modify an existing Trinity Tours agreement with a third party without approval, consistent with delegation levels. All commitments must be reported to Trinity Tours Accounting to help ensure the accuracy of Trinity Tours books and records.
Reporting, Recording and Retaining Information
Every employee records or reports information of some kind and submits it to the company and others with whom we interact. In doing so, you must ensure that all information is recorded and reported accurately, completely and honestly. Never make misrepresentations or dishonest statements to anyone. If you believe that someone may have misunderstood you, promptly correct the misunderstanding. Reporting inaccurate or incomplete information, or reporting information in a way that is intended to mislead or misinform those who receive it, is strictly prohibited and could lead to serious consequences. The following are some examples of dishonest reporting:
Financial Controls and Reporting
As law abiding responsible company , Trinity Tours must follow strict accounting principles and standards, to report financial information accurately and completely, and to have appropriate internal controls and processes to ensure that accounting and financial reporting complies with law.
The rules for accounting and financial reporting require the proper recording of, and accounting for, revenues, costs, expenses, assets and liabilities. If you have responsibility for or involvement in these areas, you must understand and follow these rules.
Retaining Records
Employees must comply with the guidelines of the records Management Plan in their retention and disposal of Trinity Tours documents. The plan applies to information in any media, including both hard copy and electronic records such as email. It requires that information defined as “essential” be retained in a recoverable format for the duration of its assigned retention period. Information that is not essential or whose retention period has expired should be disposed of as soon as possible, unless it is subject to a document retention order issued by Trinity Tours management or Counsel.
Where such an order exists, you must strictly follow the retention requirements specified in the order until you receive a notice from Trinity Tours senior management or Counsel that the order is no longer in force.
Further, these rules also prohibit anyone from assisting others to account improperly or make false or misleading financial reports. Do not assist anyone to record or report any information inaccurately or in a way that could be misleading. You should also never provide advice to anyone outside of Trinity Tours , including clients, suppliers and Trinity Tours Business Partners, about how they should be recording or reporting their own revenues, costs, expenses, and other assets and liabilities.
It is essential that you must be ethical and lawful in all of your business dealings, whether you are selling, buying or representing Trinity Tours in any other capacity. Your communications and dealings with Trinity Tour Business Partners, suppliers, competitors, clients or others can directly impact Trinity Tours reputation , goodwill and our compliance with applicable laws.
Working with Organizations Outside of Trinity Tours
Other organizations have multiple relationships with Trinity Tours. A Trinity Yours Business Partner may be both a client and a competitor. Another organization may be an Trinity Tours supplier and client at the same time. A few organizations may even be suppliers, competitors, Business Partners and clients. No matter what the context, you need to understand each relationship involved in your dealings, and act in accordance with our guidelines.
Working with Suppliers
In deciding among competing suppliers, we weigh the facts impartially to determine the best supplier. You should do so whether you are in a procurement job or any other part of the business—and regardless of whether it is a large or small purchase. You must not exert or attempt to exert influence to obtain special treatment for a particular supplier.
Even appearing to do so can undermine the integrity of our established procedures. Seeking reciprocity is contrary to Trinity Tours policy and may also be unlawful. You should not tell a prospective supplier that your decision to buy its goods or services is conditioned on the supplier’s agreement to buy Trinity Tours products or services.
This does not mean that an Trinity Tours client cannot be an Trinity Tours supplier or that Trinity Tours can never consider its other relationships with the supplier when it is evaluating the supplier. It simply means that Trinity Tours decision to buy goods and services from a supplier must be made independently and apart from that supplier’s decision to buy Trinity Tours products and services.Working with Resellers and Other Complementary Third Parties
Working with Resellers and Other Complementary Third Parties
Trinity Tours has relationships with complementary third parties, such as Trinity Tours Business Partners, Independent professionals to help Trinity Tours market and provide Trinity Tours solutions and products . If you work with these third parties, you must follow the applicable sales, marketing and services guidelines for dealing with them. In addition to their complementary offerings, some of these third parties market products or services that compete with Trinity Tours . When such a situation arises, you must exercise caution and follow established guidelines for dealing with competitors.
Working with Competitors
In the marketplace it is often clear when you are directly competing with another company. However, a company with which you are dealing in another context—such as a client, a supplier, or even a Trinity Tours Business Partner—may also be a competitor. Such situations require extra care. For example, it is likely that you and competitors will, from time to time, meet, talk and attend the same industry or association meetings. Many of these contacts are acceptable as long as established procedures are followed. Acceptable contacts include sales to other companies in our industry and purchases from them; approved participation in joint bids; and attendance at business shows, road shows , standards organizations and trade associations. However, these contacts require caution.
Discussion or collaboration on prohibited subjects with competitors can be illegal. In all contacts with competitors, avoid discussion or collaboration on pricing policies, contract terms, costs, inventories, marketing and product plans, market surveys and studies, production plans and capabilities, and any other proprietary or confidential information. You must also avoid any discussion or agreement on dividing clients or territories.
If a competitor raises a prohibited subject, even lightly or with apparent innocence, you should object, stop the conversation immediately and inform the competitor that you will not discuss these matters. If necessary, you should leave the meeting and immediately report the incident to Trinity Tours management.
Competing Fairly
Trinity Tours will compete vigorously for business. However, you must compete ethically and in compliance with our policies and the law, no matter how competitive the environment.
Statements About Competitors
Trinity Tours sells products and services on their merits. Avoid false and misleading statements about competitors, their products,and their services. Be sure all comparisons to competitors are substantiated, and that they are complete, accurate and not misleading whenever they are made. Certain countries prohibit comparative advertising.
Selling Against Competitive Orders
If a competitor already has a firm order (a legally enforceable contract) from a client for the competitor’s product or service, care should be taken when marketing competing Trinity Tours Solutions, products or services to that client. Letters of intent, free trials, conditional agreements and similar arrangements are usually not considered firm orders. It is often difficult to determine when a firm order exists. When a situation is unclear, seek advice from Trinity Tours management.
Acquiring and Using Information
Information About Others
In the normal course of business, it is not unusual to acquire information about other organizations, including competitors. Doing so is not unethical in itself. In fact, Trinity Tours quite properly gathers this kind of information from legitimate sources for such purposes as:
There are, however, limits to how that information should be acquired and used, especially information about competitors. No company should use improper means to acquire another’s trade secrets or other confidential information. Improper solicitation or receipt of confidential data from any source, including an Trinity Tours client, a competitor’s employees or any other party, is wrong.
Trinity Tours will not tolerate any form of questionable intelligence- gathering. Accordingly, you must not engage in or facilitate any improper or illegal practices designed to collect potentially confidential or sensitive information from competitors or others, such as:
Trinity Tours will not tolerate any form of questionable intelligence- gathering. Accordingly, you must not engage in or facilitate any improper or illegal practices designed to collect potentially confidential or sensitive information from competitors or others, such as:
Information about other organizations and individuals should be treated with sensitivity and discretion. When working with information, you should use that information in the proper context and make it available only to other Trinity Tours employees with a legitimate need to know. In presenting such information,you should disclose the identity of the organization or the individuals only if necessary. If specific identifying information is not necessary, you should present the information in aggregated form or by some other means.
Personal Information About Individuals
As part of your work, you may have access to personal information, such as information about consumers or employees of clients, suppliers, Trinity Tours Business Partners and others. You may only use such information to the extent necessary to fulfill your assigned job responsibilities and in accordance with instructions issued by management or applicable Trinity Tours policies, directives, and guidelines. You may not use or alter the personal information inappropriately or disclose it to anyone who does not have a legitimate need for such information.
If possible, information should be made anonymous before disclosure to avoid disclosing personal information of individuals. If you suspect that personal information has been lost or stolen, you must report it immediately to Trinity Tours management.
Proprietary and Confidential Information Owned by Others
Our business often requires the use, exchange or disclosure of information that others may own and which they may consider to be their trade secrets or intellectual property.
If you receive another party’s proprietary information, even inadvertently, you must proceed with caution to prevent any accusation that Trinity Tours misappropriated or misused the information. For example, you should avoid receiving or using confidential information owned by others unless (a) you are clearly authorized to do so, and (b) an authorized confidentiality agreement is in place between Trinity Tours and the other party or parties. The terms, restrictions and other conditions that apply to using confidential information can vary widely so it is important that you understand and comply with the applicable obligations.
Gifts, Amenities and Bribes
The following are general guidelines on receiving and giving gifts and business amenities. Types and values of gifts and amenities can vary widely—ranging from advertising novelties of nominal value, which you may give or accept, to bribes, which you unquestionably may not. Additional guidance and approval requirements are provided in Trinity Tours Corporate Instruction on Business amenities and gifts. Under these guidelines, senior executive management may approve receiving or giving higher value gifts and business amenities provided the gifts and business amenities are not prohibited by law or known client, business partner or supplier practices.
Receiving Gifts, Amenities and Referral Fees
Neither you nor any member of your family may, directly or through others, solicit or accept from anyone money, a gift, or any amenity that could influence or could reasonably give the appearance of influencing Trinity Tours business relationship with that person or organization. If you or your family members receive a gift (including money), even if the gift was unsolicited, you must notify your manager and take appropriate measures, which may include returning or disposing of what you received.
Unless you have been informed otherwise, you may accept the following:
Similarly, when authorized by Trinity Tours you may refer clients and others to third parties but you may not accept any fee, commission or anything in compensation for this referral.
Giving Gifts, Amenities and Other Value
You may not, directly or through others, offer or give any money, gift, amenity or other thing of value to an executive, official, employee or representative of any client, supplier, Trinity Tours Business Partner or any other organization, if doing so could influence or could reasonably give the appearance.
Other Public Sector Matters
Selling in the Public Sector
Public sector procurement laws are designed to ensure that products and services are procured at fair and reasonable prices. These laws vary widely and can be complex.
You should be sensitive to the following when working with the public sector:
You should follow these guidelines when dealing with the public sector. Immediately report any actual or possible violation of these guidelines or a public sector procurement law or regulation to management.
Lobbying
Any contact with government personnel for the purpose of influencing legislation or rule making, including such activity in connection with marketing or procurement matters, may be considered lobbying. In addition, under some laws, lobbying includes normal marketing and sales activities unrelated to legislation or rule making. You are responsible for knowing and adhering to all relevant lobbying and associated gift laws, including all reporting requirements.
You must obtain prior approval from Tri n I t y Tours management to lobby or authorize anyone else (for example, a consultant, agent, or Trinity Tours Business Partner) to lobby on Trinity Tours behalf—including when lobbying is limited to normal marketing and sales activities.
Campaign Visits on Trinity Tours Property
Political campaigning is not allowed on Trinity Tours property. From time to time, Trinity Tours may encourage public officials to make non-partisan visits to Trinity Tours locations, to better understand our offerings and our views on public policy issues. However, non-partisan visits by public officials within 60 days of an election in which they are participating are generally not allowed, unless authorized by Government regulations pertaining to such and authorized by Trinity Tours Counsel.
The Environment
Trinity Tours is committed to worldwide environmental protection. As Trinity Tours employees, we each have a role to play in protecting the environment. If you become aware of any violation of environmental law or any action that could cause or may appear to conceal such a violation you should immediately report the matter to management or Trinity Tours Counsel.
A conflict of interest occurs when you advance a personal interest at the expense of Trinity Tours interests. Some conflicts of interest can be avoided through careful foresight and planning. Others are unavoidable. In some cases, the mere potential for or perception of a conflict can be problematic. It is up to you to avoid situations in which your loyalty may become divided.
Some common conflicts are addressed below.
Assisting a Competitor
An obvious conflict of interest is providing assistance to an organization that markets products and services in competition with Trinity Tours current or potential product or service offerings.
You may not, without Trinity Tours consent, work for such an organization in any capacity, such as an employee, a consultant or as a member of its board of directors.
Competing against Trinity Tours
Also prohibited are individual pursuits that could conflict with Trinity Tours current or future business interests. Outside the office, many Trinity Tours may want to engage employees engage in activities that generally relate to travel & tourism , technology, business advice or other products or services Trinity Tours offers its clients. Often, such activities are in sufficient conflict with Trinity Tours current or future business interests that they are prohibited. Because Trinity Tours is rapidly expanding into new lines of business and areas of interest, the company will constantly redraw lines of acceptable activity. It is therefore your responsibility to consult, in advance and on a periodic basis, with your management to determine whether your planned activity will compete with any of Trinity Tours actual or potential businesses.
Supplying to Trinity Tours
Unless approved in advance by senior management and Trinity Tours Counsel, you may not be a supplier to Trinity Tours , represent a supplier to Trinity Tours , work for a supplier to Trinity Tours or be a member of its board of directors while you are an employee of Trinity Tours . In addition, you may not accept money or benefits of any kind for any advice or services you may provide to a supplier in connection with its business with Trinity Tours.
Personal Financial Interests
You may not have a financial interest in any organization if that interest would create or give the appearance of a conflict of interest with Trinity Tours . Such organizations include suppliers, clients, competitors, Trinity Tours Business Partners, alliance companies and others with which Trinity Tours does business. In all cases, a financial interest is improper if your job, the amount of your investment, or the particular organization in which you invested could— when viewed objectively by another person—influence your actions as a Trinity Tours employee.
If you have any involvement—direct or indirect—in deciding whether Trinity Tours does business with an organization, you should not obtain or maintain a financial interest in that organization. Additionally, you must not accept or buy stock options or other securities in any situation where there is a question that the offer was motivated in whole or in part by your Trinity Tours employment, or if the investment otherwise violates Trinity Tours policies, directives, and guidelines.
Investments in closely-held organizations—typically, closely held corporations, partnerships, and sole proprietorship—raise unique, though no less compelling, concerns. Employees may not make any investment in a closely held organization that is a competitor, supplier, Trinity Tours Business Partner, distributor or organization that re-markets Trinity Tours products. Any exceptions must be specifically approved by management with the advice of Trinity Tours Counsel.
You must not attempt to evade these investment restrictions by acting indirectly through anyone else.
Family and Close Relations Working in the Industry
Close ties to others working in the industry—spouses, immediate relatives, close friends and the like—present special security, regulatory and confidentiality concerns. You may find yourself in a situation where someone you are close to—such as a member of your family, spouse or domestic partner—is a competitor or supplier of Trinity Tours , or is employed by one. While everyone is entitled to choose and pursue a career, such situations call for extra sensitivity to security, confidentiality and conflicts of interest. The closeness of the relationship might lead you to inadvertently compromise Trinity Tours interests.
If you have any questions about your situation, you should review it with your manager. Frequently, any risk to Trinity Tours interests can be minimized through periodic reminders regarding security protocol, and careful attention to avoiding inadvertent disclosure of Trinity Tours confidential information.
However, in some instances, a change in the job responsibilities of one of the people involved may be necessary.
Personal Use of Trinity Tours Time
Whether or not your personal activity presents a conflict of interest, you may not conduct non-Trinity Tours work or solicit such business on Trinity Tours premises or while working on Trinity Tours time, including time you are given with pay to handle personal matters.
Employment, Activities other than Trinity Tours
Whether or not it presents a conflict of interest, you may not enter into any form of activity be it on on commercial remunerative nature or otherwise like employment be it full time or part time , consultancy , business activity of any nature, professional activity of commercial nature, membership of any organisation’s board , committee etc . Any exceptions must be specifically approved by management with the advice of Trinity Tours Counsel.
This is to be strictly followed irrespective of the fact whether your employement at Trinity Tours is a full time one or a part time one. Further keeping in view the business situation and other necessary scenario affecting Trinity Tours the approval or permission given earlier may be reviewed at any time and changed.
Hobbies, interest of personal nature which are non commercial can be freely pursued as long as they are not affecting your work at Trinity Tours or that of your other colleagues at Trinity Tours.
Inside Information Disclosure
In the course of your employment with Trinity Tours , you may become aware of information about Trinity Tours or other companies that has not been made public. The use or disclosure of such nonpublic or “inside” information about Trinity Tours or another company for your financial or other benefit is not only unethical, but it also may be a violation of law. Violation of such laws may result in civil and criminal penalties, including fines and jail sentences. Trinity Tours will not tolerate the improper use of inside information. These prohibitions also apply anywhere in the world where we do business.
Avoid improper use and disclosure of inside information. For example:
If you know that Trinity Tours is considering an alliance or is about to announce a new product or make a purchasing decision that could affect the price of the securities of an Trinity Tours client or supplier or other company, you should not buy or sell the securities of that company until after the information becomes public You should not buy or sell the securities of a client or alliance company based on any inside information you have about that company you should not disclose inside information about Trinity Tours or any other company to Trinity Tours employees who do not have a business need to know or to anyone outside of Trinity Tours .As with investments, you should not evade these guidelines by acting through anyone else or by giving inside information to others for their use, even if you will not financially benefit from it. If you have any doubt about what you can or cannot do in this area, you should consult with Trinity Tours management.
Public Service and Political Activity
Trinity Tours encourages all employees to pursue personal interests, including active participation in their communities. While the vast majority of such interests pose no particular concerns for your Trinity Tours position, some do. Certain off-the-job activities can affect your Trinity Tours position, or can otherwise reflect negatively on Trinity Tours . In cases where there is doubt, you must decide whether you can avoid harm through careful management of your conduct, or whether harm is unavoidable, and therefore the activity must be avoided.
Public Service
Participation in public and governmental service may pose conflict of interest concerns. In all events, you should make it clear that you are an Trinity Tours employee to avoid any perception that you concealed your association with Trinity Tours . Similarly, should you decide to abstain, you should state clearly that you are doing so to avoid an actual or potential conflict of interest.
Political Office, Contributions and Endorsements
Trinity Tours will not make contributions, payments or otherwise give any endorsement or support which would be considered a contribution, directly or indirectly, to political parties or candidates, including through intermediary organizations, such as political action committees, campaign funds, or trade or industry associations. For example, trinity Tours will not purchase tickets, pay fees, or reimburse expenses for any event where any portion of the funds will be used for election campaigns.
In many countries, political contributions by corporations are illegal, though Trinity Tours will not make such contributions even where they are legal. You must not make any political contribution as a representative of Trinity Tours . You may not request reimbursement from Trinity Tours , nor will Trinity Tours reimburse you, for any personal contributions you make.
Further, your work time or use of Trinity Tours assets is the equivalent of such a contribution. Therefore, you will not be paid by Trinity Tours for any time spent running for public office, serving as an elected official or campaigning for a political candidate, unless required by law. You can, however, take reasonable time off without pay for such activities if your Trinity Tours duties permit and it is approved by your manager. You also may use vacation tim for political activity. You must consult with Trinity Tours management and Trinity Tours Counsel before accepting a political appointment to any government entity or running for government office at the local, state, or federal level.
Speaking Publicly and Social Media
Speaking Publicly and Social Media when you speak out on public issues or in a public forum, you do so as an individual, and you should not give the appearance of speaking or acting on behalf of Trinity Tours . This is particularly important with the rise of social networking media. You must always be aware that such services are increasingly being monitored by clients, colleagues and regulators alike. Guidelines.
Acting with integrity and according to our Values is often a question of good judgment and basic questions like these will often help you to eliminate any doubt about a decision or proposed action:
• Is it honest?
• Does it conform to the Business Conduct Guidelines?
• Do I really feel comfortable with this decision?
• What if this appeared in the news?
What if everyone were to behave like this?