Corruption and Bribery
The laws of virtually all countries in which Travelport companies operate, as well as extra-territorial laws, such as the U.S. Foreign Corrupt Practices Act and various United Kingdom (UK) anti-bribery-related legislation, prohibit bribes to governments and other officials (such as political candidates, political parties and their officials, employees of government-owned business, United Nations officials and individuals, etc.), and bribes to commercial parties. A violation can be a serious criminal offense for companies and/or individuals, resulting in fines and penalties for companies, and fines, penalties, and imprisonment for individuals. Accordingly, employees must ensure that payments made by or on behalf of Travelport are made only for legitimate business purposes.
Under no circumstance is it acceptable for an employee to pay, offer give, solicit, or receive anything of value, to or from, a government official for any improper purpose, and without the prior written approval of the Office of the Chief Compliance & Ethics Officer or the business unit General Counsel. Further, no payments or offers of anything of value may be made to any commercial counterparties (including their employees or officers), where intended to, or where they may have the effect of, inducing the recipient to perform a function improperly.
In addition, no offer, payment, promise, or gift of anything of value may be made to a government official in exchange for a commitment to expedite or perform a routine governmental action, unless (1) it is necessary to secure governmental services (e.g. police protection, medical evacuation) in response to a medical or safety emergency, or (2) the person reasonably believes that he or she is in imminent jeopardy of serious harm and no other prudent alternatives are available.
Please refer to the applicable Travelport Code Guidance Supplement for more information.