anti-corruption policy
commitment to inTegrity and ethical conduct
PREM Group is committed to upholding the highest standards of integrity and ethical behaviour in all our business dealings. We firmly believe that corruption, in any form, tarnishes the hospitality industry, erodes trust, and stands as a barrier to sustainable growth. As a responsible hospitality management company, we adopt a strict zero-tolerance policy towards corruption and bribery.
Definitions
Corruption can be defined as the abuse of entrusted power for private gain. This can manifest in various forms, including but not limited to bribery, fraud, embezzlement, and extortion.
Bribery refers to offering, giving, receiving, or soliciting something of value to influence the actions of an individual holding a public or private position.
POLICY OVERVIEW
Our anti-corruption policy is applicable to all employees, officers, directors, and third parties acting on our behalf, including contractors, suppliers, and partners. We expect everyone associated with PREM Group to adhere to this policy without exception. This is PREM Group’s first policy and is made for the financial year ending 2025.
KEY PRINCIPLES
Prohibition of Bribery and Corruption
We categorically prohibit any form of bribery, whether direct or indirect, including the offering, giving, receiving, or soliciting of anything of value to improperly influence the actions of another party.
Transparency and Accountability
All financial records and transactions must be accurately documented and transparent. We uphold stringent accounting and auditing procedures to prevent and detect corruption.
Gifts and Hospitality
At PREM Group, extending hospitality to our guests and clients is a fundamental part of our daily operations in the hospitality industry. Equally important to us is fostering strong relationships with our suppliers and customers, both at corporate and personal levels.
However, it is essential to differentiate between routine business hospitality and gifts that could be interpreted as attempts to gain undue influence. Any gifts or hospitality should be infrequent, reasonable, and modest, ensuring they do not improperly influence—or appear to improperly influence—business decisions.
Hospitality, in this context, encompasses invitations to social, cultural and sporting events, meals, and entertainment. It is permitted only if its purpose is to cultivate legitimate business relationships and is proportionate to the recipient and their organisation.
Gifts and hospitality must be moderate in value. No gift should be given if it could be seen as a reward, inducement, or a corrupt act. Cash or cash equivalents are strictly prohibited.
Every employee is responsible for ensuring any gifts or hospitality offered or accepted adhere to this policy. In cases of doubt, employees must consult the General Manager or Central Office Executive Team for approval.
We encourage all employees to be mindful of these guidelines as we continue to build meaningful and ethical business relationships.
Political Donations
The Group's policy prohibits making political donations. However, this does not prevent the Group or individual properties from engaging in business with political parties or affiliates for events and stays as part of their regular operations.
Donation Guidelines
At PREM Group, we believe in giving back to the community through charitable donations and sponsorship agreements. However, it's crucial that these contributions align with our commitment to ethical practices and aren't misconstrued as bribery.
For any significant or Group-wide charitable donations and sponsorships, approval from Central Office Executive Team is required.
Local properties are encouraged to support their communities by participating in local sponsorships, such as for sports organisations, and making charitable donations to local entities. It's important that these contributions are reasonable and modest in value. Every payment must be approved by both the General Manager and the Accountant.
Remember, when in doubt, always check with the General Manager or Central Office Executive Team to ensure compliance with anti-bribery regulations. Your diligence helps us maintain our integrity and community trust.
Third-Party Relationships
We expect our business partners, suppliers, and contractors to uphold similar anti-corruption standards. Due diligence will be conducted before entering into business relationships to ensure compliance.
Implementation and Enforcement
The CEO of PREM Group holds ultimate responsibility for this policy. The Central Office Executive Team and General Managers are tasked with implementing and enforcing it within their respective properties and business areas. Any violations will be rigorously investigated and could lead to disciplinary measures, including termination of employment or business relationships, as well as potential legal action.
Whistleblowing policy
We have implemented an internal whistleblowing policy, available in our properties and central office. The company encourages all its employees to report any concerns related to the direct activities, or the supply chains of the organisation. The organisation's whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.
FUTURE STEPS AND ONGOING COMMITMENT
The risks of bribery and corruption need our constant attention. Because of the growth of our operations, we must continue to minimise and manage the risks and develop better ways to increase the visibility of our actions in our operations. In order to monitor and assess our compliance, in 2026 we plan a number of steps:
A supplier code of conduct will be prepared and issued for all our suppliers. We expect our suppliers to commit to complying with this code of conduct.
We will carry out training on anti-corruption policies and practices which will be mandatory for all employees. We strive to create a culture of integrity and ethical behaviour through continuous education and awareness.
Conclusion
PREM Group is dedicated to maintaining an ethical workplace free from corruption. We believe that our success depends on our reputation for integrity, and we are committed to upholding this standard in all our business dealings.
Jim Murphy
Chief Executive Officer
PREM Group