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TravelPA (“the Company”) is committed to conducting all business with integrity, transparency, and fairness. Corruption, bribery, or any form of unethical inducement is strictly prohibited.

1. Purpose

The purpose of this policy is to ensure that all activities of TravelPA (“the Company”) and its affiliated brands are conducted with honesty, transparency, and accountability. The company maintains a zero-tolerance stance on bribery, corruption, and improper payments in any form.

 

2. Scope

This policy applies to:

  • All employees, directors, consultants, contractors, travel coordinators, and trustees.
  • All third parties representing or working with TravelPA, including schools, sponsors, agents, suppliers, and service providers.
  • All operations, whether in South Africa or abroad.

 

3. Core Principles

  • Integrity First: Every action must support the company’s ethical reputation and the trust of our clients, schools, and travel partners.

  • Zero Tolerance: Bribes, facilitation payments, kickbacks, or any form of improper inducement are strictly prohibited.

  • Transparency: All financial transactions must be accurately recorded and verifiable.

  • Accountability: Each person associated with the company is responsible for identifying and preventing potential corruption risks.

 

4. Definitions

  • Bribe: Offering, giving, receiving, or soliciting anything of value to influence a decision or secure an unfair advantage.

  • Facilitation Payment: Small, unofficial payments to speed up routine actions (e.g., customs clearance). These are not permitted.

  • Conflict of Interest: A situation where personal interests could influence professional judgment.

  • Honorarium: A voluntary payment made to an individual in recognition of services rendered (for example, a guest speaker, sports coach, or trip host) where a formal contract or employment agreement does not exist.

 

5. Honorarium Policy

To maintain transparency and fairness, TravelPA applies the following rules to all honoraria:

Approval:

  • Any honorarium—whether paid to staff, local coordinators, guides, or visiting professionals—must be pre-approved in writing by a Director or the Finance Manager.
  • Approval is required before any commitment or payment is made.

Documentation:

  • Each honorarium must be supported by a signed Honorarium Request or Payment Form, stating:
  • Recipient’s name and role
  • Description of service rendered
  • Amount and currency
  • Date of service
  • Authorising signature
  • The form must be filed in the company’s financial records.

Reasonableness:

  • The amount should be modest, proportionate, and consistent with the nature of the service.
  • Cash payments are discouraged. Prefer electronic transfer with clear proof of payment.

Tax and Legal Compliance:

  • Honoraria must comply with local tax laws; TravelPA will issue supporting documentation.

 

6. Gifts, Hospitality & Benefits

  • Modest hospitality (e.g., coffee, light meal, small token) is acceptable when it is customary, transparent, and not intended to influence a decision.

  • Cash or gift cards are not permitted.

 

7. Reporting & Whistle-Blowing

  • Any suspected incident of bribery, coercion, or unethical behavior must be reported immediately to the Managing Director or Compliance Officer.

  • Reports can be made confidentially or anonymously via ethics@travelpa.co.za.

  • Retaliation against a whistle-blower will not be tolerated.

 

8. Record-Keeping

  • All payments, reimbursements, and benefits must be fully documented in accounting records.

  • “Off-book” accounts or unofficial petty-cash funds are prohibited.

 

9. Disciplinary Action

Breaches of this policy may result in disciplinary action, up to and including termination of employment or partnership and referral to the relevant authorities.

 

10. Training & Review

  • All staff and partners must complete annual anti-corruption and ethics awareness training.

  • The policy is reviewed annually by management to ensure alignment with South African law, the UK Bribery Act, and other applicable regulations.

 

11. Our Commitment

 

TravelPA (“the Company”) believe that integrity is the foundation of sustainable partnerships. Every payment, honorarium and gift must reflect transparency, respect and the company’s commitment to ethical travel.

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