These Terms of Use apply to the use of TripStax Hotels (the “Site(s)”) and contain your rights, obligations and restrictions when using and accessing such Sites.
The Sites are operated by TripStax Hotels Oy, a company registered in Finland, with its registered office at Linnoitustie 4B, FI-02600 Espoo, Finland (“TripStax Hotels”), irrespective of where you reside.
Use of Site
PLEASE READ THE TERMS OF USE CAREFULLY BEFORE USING OR ACCESSING THE SITE. By accessing or using the Site, you acknowledge that you have read, understand, and agree to be bound by these Terms of Use, and the applicable law. These Terms of Use contain your rights, obligations and restrictions when using the Site. If you do not agree to these Terms of Use, please do not use, or access the Site.
Our privacy statement is incorporated into these Terms of Use by this reference, further describes the collection and use of information on the Site and in the provision of TripStax Hotels services and the use of cookies. To read more about how TripStax Hotels deals with your information and the use of cookies, please have a look at TripStax Hotels’s privacy statement, available here.
You may use the Site, and the information, writings, images and/or other works that can be seen, heard, or otherwise experienced on the Site (singly or collectively, the “TripStax Hotels Content”) solely for non-commercial, personal purposes and/or to learn about TripStax Hotels’s products and services. No right, title or interest in any TripStax Hotels Content is transferred to you, whether because of downloading such TripStax Hotels Content or otherwise.
TripStax Hotels may update and change the Site and the TripStax Hotels Content from time to and will try to give you reasonable notice of any major changes. TripStax Hotels reserves the right to modify these Terms of Use at any time without prior notice. Use of the Site following any such modification constitutes your agreement to follow and be bound by these Terms of Use as modified.
Restrictions on use
You agree to use the Site only for lawful purposes. You agree not to take any action that might compromise the security of the Site, render the Site inaccessible to others or otherwise cause damage to the Site or the TripStax Hotels Content or interfere with the rights of third parties. You agree not to change or delete any ownership notices from any materials downloaded, printed, or otherwise obtained via the Site; not to modify, copy, translate, broadcast, perform, display, distribute, frame, reproduce, republish, download, display, post, transmit or sell any TripStax Hotels Content available through the Site. You may not mirror or frame the home page or any other pages of this Site on any other web site or web page and are prohibited from using any of the marks or logos appearing throughout the Site without permission from the trademark owner, except as permitted by applicable law.
Intellectual Property
TripStax Hotels is the owner or the licensee of all intellectual property rights in our Site, and in the TripStax Hotels Content published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.
You may print off one copy, and may download extracts, of any page(s) from the Site for your personal use and you may draw the attention of others within your organisation to content posted on our Site.
All TripStax Hotels Content on the Site is a collective work under the United Kingdom and other copyright laws and is the proprietary property of TripStax Hotels. Nothing in these Terms of Use shall be interpreted as granting any license of intellectual property rights to you.
Links to Third-Party Web Sites
Links on the Site to third party web sites or information are provided solely as a convenience. By using these links, you will leave the Site. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by TripStax Hotels of the third party, the third-party web site, or the information contained therein. TripStax Hotels is not responsible for the availability, content, or policies of any such web sites and access such third-party websites is solely at your own risk.
Disclaimer of Warranties
Although care has been taken to ensure the accuracy of the information on the Sites, TripStax Hotels assumes no responsibility therefor. The Sites and the TripStax Hotels Content are provided ‘as is’ and ‘as available’ and without any warranties of any kind.
TripStax Hotels does not represent or warrant that the Sites will always be available, be uninterrupted or error-free, that any defects will be corrected, or that the Site or the server that makes the Site available is free of viruses or anything else harmful.
To the fullest extent permitted by law, TripStax Hotels disclaims all warranties, express or implied, statutory, or otherwise, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, title and non-infringement, as to the operation of the Site, use of the Site and the TripStax Hotels Content. TripStax Hotels may suspend or withdraw or restrict the availability of all or any part of the Site for business and operational reasons and will try to give you reasonable notice of any suspension or withdrawal.
Limitation of Liability
TripStax Hotels do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents, or subcontractors and for fraud or fraudulent misrepresentation.
TripStax Hotels exclude all implied conditions, warranties, representations, or other terms that may apply to the Site or any TripStax Hotels Content on it.
IN NO EVENT WILL TRIPSTAX HOTELS NOR ITS AFFILIATES, SUPPLIERS AND/OR LICENSORS BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY DAMAGES WHATSOEVER, INCLUDING, BUT NOT LIMITED TO ANY DIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY OR OTHER INDIRECT DAMAGES, WHETHER IN CONTRACT, TORT (INCLUDING NEGLIGENCE), BREACH OF STATUTORY DUTY OR OTHERWISE ARISING UNDER OR IN CONNECTION WITH: (I) THE USE OF OR INABILITY TO USE THE SITE, OR THE TRIPSTAX HOTELS CONTENT, (II) ANY TRANSACTION CONDUCTED THROUGH OR FACILITATED BY THE SITE OR AS A RESULT OF YOUR ACCESSING OR USE OF THE SITE; (III) ANY CLAIM ATTRIBUTABLE TO ERRORS, OMISSIONS, OR OTHER INACCURACIES IN THE SITE, AND/OR THE TRIPSTAX HOTELS CONTENT, (IV) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA, OR (V) ANY OTHER MATTER RELATING TO THE SITE, OR THE TRIPSTAX HOTELS CONTENT, EVEN IF TRIPSTAX HOTELS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
IF YOU ARE DISSATISFIED WITH THE SITE, THE TRIPSTAX HOTELS CONTENT, OR WITH THE TERMS OF USE, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE SITE.
TRIPSTAX HOTELS AGGREGATE LIABILITY FOR ANY ONE OR MORE CLAIMS ARE LIMITED TO THE GREATEST EXTENT PERMITTED BY LAW BUT IN NO EVENT SHALL EXCEED €50.00 AS THE CASE MAY BE. APPLICABLE LAW MAY NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY OR INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION OR EXCLUSION MAY NOT APPLY.
NOTWITHSTANDING THE ABOVE, NOTHING IN THESE TERMS OF USE EXCLUDES OR LIMITS ‘TRIPSTAX HOTELS’ LIABILITY FOR DEATH OR PERSONAL INJURY ARISING FROM NEGLIGENCE, OR FRAUD OR FRAUDULENT MISREPRESENTATION, OR ANY OTHER LIABILITY THAT CANNOT BE EXCLUDED OR LIMITED BY APPLICABLE LAW.
Indemnification
You understand and agree that you are personally responsible for your behaviour on the Site. You agree to indemnify, defend and hold harmless TripStax Hotels, its parent companies, subsidiaries, affiliated companies, joint ventures, business partners, licensors, employees, agents, and any third-party information providers from and against all claims, losses, liabilities, expenses, damages and costs (including, but not limited to, direct, incidental, consequential, exemplary and indirect damages), and reasonable attorneys’ fees, resulting from or arising out of use, misuse of the Site, the TripStax Hotels Content, violation by you of these Terms of Use, any law or the rights of any third party.
General Provisions
Entire Agreement/No Waiver. These Terms of Use constitute the entire agreement of the parties with respect to the subject matter hereof. No waiver by TripStax Hotels of any breach or default hereunder shall be deemed to be a waiver of any preceding or subsequent breach or default.
Correction of Errors and Inaccuracies. The Site, in particular the TripStax Hotels Content may contain typographical errors or other errors or inaccuracies and may not be complete or current. TripStax Hotels therefore reserves the right to correct any errors, inaccuracies, or omissions and to change or update the TripStax Hotels Content at any time without prior notice. TripStax Hotels does not, however, guarantee that any errors, inaccuracies, or omissions will be corrected.
Severability. If any part of this Agreement is determined by a court of competent jurisdiction to be invalid or unenforceable, it will not impact any other provision of this Agreement, all of which will remain in full force and effect.
Notices. Any notices to be sent to TripStax Hotels in connection with these Terms should be sent to Legal@Tripstax.com.
Choice of Law/ Choice of Forum. The Terms of Use, their subject matter, and their formation (and any non-contractual disputes or claims) are governed by Finnish law. We both agree to the exclusive jurisdiction of the courts of Finland.
Version: November 2023
INFORMATION ABOUT HOW WE USE COOKIES
TripStax Hotels websites uses various cookies and by using our websites and other online services, such as our mobile app, you agree that we can store and access cookies, IP addresses and use other methods to collect website usage data and improve your online experience.
WHAT ARE ‘COOKIES’?
A cookie is a small file of letters and numbers that we put on your computer if you
agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and allows us to improve our site. This can include information about your use of the website, the browser and device type you are accessing it from and where you are in the world (see ‘How do we collect and use geo-location information?’). Cookies are small files that are placed on your computer by websites that you visit or certain emails you open. They are widely used to make websites function properly, as well as to provide business and marketing information to the owners of the site.
Essential cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, and to use online forms.
Analytical cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Marketing cookies: These are used to recognise you when you return to our website. This enables us to personalise content for you and remember your preferences. These cookies also record your visit to our website, the pages you have visited and the links you have followed. This information helps to make our website, advertising and communications sent more relevant to your interests;
THIRD PARTY COOKIES
TripStax Hotels use third party cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads both on our website and around the world wide web. These sites include Facebook, LinkedIn, Twitter, Google, and Bing.
Google Analytics
The TripStax Hotels website use Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics uses cookies to help us understand how the websites are used. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google. TripStax Hotels use this information for the purpose of evaluating use of the websites, compiling reports on website activity and providing other services relating to website activity and internet usage. Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
To opt out of being tracked by Google Analytics across all websites, please visit;
http://tools.google.com/dlpage/gaoptout.
Social Media Cookies
TripStax Hotels uses a range of social media platforms. We have no control over the use of cookies on these third-party sites. Please follow these links for more information on the privacy policies of the individual social media sites where we are active:
You may refuse the use of cookies by selecting the appropriate settings in your browser. However, if you do this you may lose some useful functionality within the TripStax Hotels websites. Please note also, that if you delete your cookies:
We will no longer know that you have opted out of online behavioral advertising, so the banners from our third-party advertisers will reappear when you visit other selected websites
We will no longer automatically recognise that you have agreed to our Privacy Policy, cookies policy and website terms and conditions and will ask for confirmation of this along with your language and country preferences.
Corporate Social Responsibility Policy
This Policy applies to all companies, Board members, officers, and staff within the TripStax Technologies Ltd group of companies, hereafter referred to as the Company.
Introduction
The Company takes its responsibility as a corporate citizen very seriously and is noticeably clear about what Corporate Social Responsibility (or CSR) means to its employees, clients, suppliers and all its other stakeholders. It also recognises that its business can have a detrimental impact on the wider world in a variety of diverse ways.
Therefore, in order to maintain a sustainable balance between economic growth, profitability, and care for the environment and community it affects, the Board of the Company believes that the Company’s activities must be conducted responsibly, fairly, openly, and always with the aim of minimizing its adverse impact on the environment and community in which it operates.
Accordingly, the Company has developed this CSR policy to communicate how it will manage these responsibilities, and the Board expects all staff to be aware of the contribution that is required from each one of them in order to achieve this, and how they should actively participate in its implementation.
The Board therefore believes that it is the responsibility of everyone employed by the Company, regardless of role or level of responsibility, to ensure compliance with this Policy, and to promote it.
Signed, Jack Ramsey
Chief Executive Officer
November 2023
Duty of care
Being part of a global industry that promotes the use of many forms of transport, the Company recognizes it has a role to play in assisting customers to be more aware of the effect of their travel on the environment. The Company has already incorporated various technologies as part of its proprietary products to enable clients to assess the impact of their company’s travel pattern on the environment by the mileage they have travelled, the method of their travel, and the CO2 this generates.
In order to ensure that the Company is well informed about the business activities and practices of its suppliers, and to correctly align its suppliers with the requirements of its clients, the Company will also regularly conduct a supplier risk review when considering purchasing solutions. Therefore, in addition to reviewing their products and services, this review will seek to take into account the track record of its existing and potential suppliers in reducing their impact on the environment and the communities that their commercial activities affect. For the same reason, it will also seek to prioritise the use of services from local suppliers wherever possible.
The Company will also work closely with local colleges that provide travel industry training courses to seek to ensure that they are relevant to the travel industry’s current and future requirements, so as to enable students to find long-term employment in the industry.
Further, when vacancies arise, the Company will first seek to employ locally based employees to fill these positions, and only recruit from further afield in the absence of any suitable local candidates.
People and Equality
The Company commits to always recruit and employ staff on the principles of equal opportunity, diversity and respect for human rights and in accordance with the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work Recruitment.
Employment will always be in strict accordance with the employment legislation of each jurisdiction in which the Company operates, and as set out in its Equal Opportunities, and Ethics and Conduct Policies.
The Company will also put in place consistent employment procedures and policies across all locations to ensure that these principles are universally applied to all staff to the greatest extent permitted by their local employment legislation. However, for the avoidance of doubt the provisions of this policy do not form part of any individual contract of employment.
The Company strives to ensure that the principles of equality of opportunity are embedded in the culture and structure of the organisation. The policy of promoting equal opportunities in employment is therefore reflected in all the HR policies and procedures developed by the Company. These span the following areas of the employee lifecycle:
a) Recruitment
b) Induction
c) Training and Development
d) Employment and wellbeing
e) Employee movement and career breaks
f) Performance review
g) Reward and Recognition
h) Disciplinary
i) Grievance
j) Termination of employment
The Company therefore confirms that all employees will:
Be recruited and employed according to written recruitment procedures that are regularly reviewed and audited, and which shall contain:
o Recruitment validation procedures that;
ensure that sufficient evidence is obtained to ensure that no persons under the age of 18 or the local minimum age of employment are unknowingly employed;
ensure that evidence is obtained to ensure that all employees are eligible to work in the local jurisdiction in which they are applying for a position, and that their identity and background checks are suitably verified;
risk assessments and work procedures for students and other staff under the age of 18 or the local minimum age of employment who are temporarily with the Company for work experience;
procedures that ensure that the Company’s Equal Opportunities Policy is always complied with.
Be provided with:
a clear written role description.
a contract of employment (which shall contain the legal terms of their employment and their full remuneration details);
access to Group employment policies, including:
Equal Opportunities Policy
Recruitment Policy
Harassment Policy
Grievance policy
an employee handbook containing additional local employment policies, investigation procedures and any variations of Group employment policies required in order to comply with local legislation.
the local Health and Safety procedures, which shall always comply with local legislation, but which shall also meet Group requirements.
Be paid at least the local minimum wage.
Not be required to work at night, work excessive hours, or perform duties of a hazardous nature if they are under the age of 18.
Be free to leave their employment with the Company at any time, and without financial penalty or deduction if such deductions have not been communicated and agreed with the employee in advance of their departure.
Be free to take with them any original personal identify, training, medical or other documents held by the Company during their employment when they leave.
Not be recruited through recruitment or other agencies that demand a fee from the employee, such that the only fee receivable by such agencies shall be that which is paid by the Company.
Only perform nighttime duties in accordance with the relevant local legislation and their contracts.
Be employed under terms and conditions that include a limit on the number of hours they can work, unless they agree otherwise, and provide them with their statutory rest breaks.
• When the company requires it, be offered overtime without being compelled to perform it.
Be free to join or create trade union or equivalent body.
Be employed in offices that are safe to work in and comply with:
Local Health and safety Legislation and Fire Regulations, such that they shall contain:
Protective equipment that is provided free of charge.
Firefighting aids and prevention equipment that is regularly checked;
Emergency medical supplies provisions to the local statutory standard;
Clear and visible fire/emergency instructions;
Health and Safety Risk identification and management systems and procedures.
Discrimination
Discrimination can take many forms and the Company has a zero-tolerance approach to discriminatory behaviour. All employees should be familiar with the behaviours that are considered as discrimination.
Protected characteristics detailed below a defined by the UK Equality Act 2010 and outline the attributes of a person that must not be discriminated against in business.
The Company will at all times observe and respect its legal obligations that govern the employment of all personnel in all countries in which it operates.
The Company recognises that certain groups and individuals in society are disadvantaged because of discrimination they have experienced. The Company requires that no customer or prospective customer, supplier or prospective supplier, employee, temporary worker or job applicant receives less favourable treatment on the basis of:
a) Age
b) Disability
c) Gender (including gender reassignment)
d) Marriage and civil partnership
e) Race (including color or nationality)
f) Religion or belief
g) Sexual orientation.
h) Full or part time or temporary working
i) Pregnancy and maternity
The Company recognises that there may be other areas where people experience discrimination and will work towards an anti-discriminatory environment, based on open discussions with employees, customers, suppliers and others on perceptions of discrimination.
Responsibility
The Company expects that you will apply the principles of non-discrimination and equality of opportunity whenever and wherever you interact with other employees or officers of the Company, clients, suppliers, and business partners of the Company, and the Company will apply the relevant disciplinary procedures to any staff that fail to do this.
The Environment
The Company believes that good corporate management should consider all environmental impact matters, and is committed to upholding this principle, primarily by reducing the waste the Company produces.
This principle is therefore a consideration in all our decisions and policies, and reflected in the activities, products and services we offer. The Company encourages these and other forms of environmental responsibility at all levels of our organisation, which we aim to achieve through a programme of employee awareness and environmental training courses.
The Boards’ approach to its environmental responsibilities is set out in its Environmental Policy
Ethics
The Company believes that sustainable growth should be based on, and driven by, two fundamental principles; those of expertise and integrity.
The Company has therefore published an Ethics and Conduct Policy, which is designed to communicate the importance that it attaches to ensuring that the highest standards of integrity are consistently applied to all aspects of its activities.
The Ethics and Conduct policy also supports the Company’s Vision, Mission and Value statements, and means that in order for the Company to be successful, all staff must understand and accept that it is everyone’s responsibility to act at all times with honesty, fairness, and in full compliance with the law.
The Ethics and Conduct Policy confirms the company’s commitment to a zero-tolerance on slavery and human trafficking, either within the company, or its network partners and suppliers.
Measurement & Monitoring
The Company will assess compliance with this and other policies and procedures as part of its Integrated Management System (IMS), which will provide a structure, process and timetable for regular internal audits.
Management Review
As part of the Company’s Corporate Governance framework, the results of the internal audits are regularly reported to management for review and action.
An annual Management Review is also conducted to assess both compliance with, and performance against, this Policy and the targets that have been set around it.
The Management Review Team will then determine and arrange for the implementation of any action plans that are required, and also set the new targets for the forthcoming year.
Communication
As is the case with all of the Company’s policies, this CSR Policy will be available to all staff through the Company’s Share Point site.
All other relevant compliance training material will also be accessible by staff in this way. All staff will be able to confirm that they have read and understood this material within Entropy in order for their personal development and compliance training records to be kept up to date.
The Company will also arrange regular on-site and virtual training sessions to encourage discussion of the training subject matter. External stakeholders, customers, suppliers and third parties will have access to the Company’s policies via the Company website.
Anti-Facilitation of Tax Evasion Policy
This Policy applies to all companies, individuals or other entities who perform services for or on behalf of TripStax and its subsidiary companies.
Introduction
It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to facilitation of tax evasion, whether under UK law or under the law of a foreign country.
We are committed to acting professionally, fairly and with integrity in all of our business dealings and relationships wherever we operate. We have implemented and will enforce effective systems to counter tax evasion facilitation.
We will uphold all laws relevant to countering tax evasion in all jurisdictions in which we operate, including the Criminal Finances Act 2017.
Signed,Jack Ramsey
Chief Executive Officer
November 2023
About this Policy
The purpose of this policy is to:
(a) Set out our responsibilities, and those working for us, in observation and upholding our position on preventing the criminal facilitation of tax evasion; and
(b) Provide information and guidance to those working for us on how to recognise and avoid tax evasion.
If we fail to prevent our employees, workers, agents or service providers facilitating tax evasion, we can face criminal sanctions including an unlimited fine, as well as exclusion from tendering for public contracts and damage to our reputation. We, therefore, take our legal responsibilities seriously.
In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers and government and public bodies including their advisers, representatives and officials, politicians and political parties.
This policy may be amended at any time.
Who must comply with this policy?
This policy applies to all persons working for us or any third party working for or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, contractors, external consultants, third party representatives and business partners, subcontractors, sponsors, or any other person associated with us, wherever located.
Who is responsible for the policy?
The TripStax Technologies Ltd board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and all those under our control comply with it.
The Group Chief Financial Officer has primary and day to day responsibility for implementing this policy, monitoring 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.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.
Account Managers at all levels are responsible for ensuring those customers and partners they manage accounts for understand and comply with this policy.
What is tax evasion facilitation?
For the purposes of this policy:
(a) 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 there must be deliberate action, or omission with dishonest intent;
(b) Foreign tax evasion facilitation means evading tax in a foreign country, provided such conduct is an offence in that country and would be a criminal offence if committed in the UK. As with tax evasion, the element of fraud means there must be deliberate action, or omission with dishonest intent; and
(c) Tax evasion facilitation means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax (whether UK tax or tax in a foreign country) by another person, or aiding, abetting, counselling or procuring the commission of that offence. Tax evasion facilitation is a criminal offence, where it is done deliberately and dishonestly.
Under the Criminal Finances Act 2017, a separate criminal offence is automatically committed by a corporate entity or partnership where the tax evasion is facilitated 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 accidentally, ignorantly, or negligently facilitates the tax evasion, 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 or tac planning. Tax evasion involves deliberate and dishonest conduct. Tax avoidance is not legal and involves taking steps, within the law, to minimise tax payable (or maximise tax reliefs)
In this policy, all references to tax include national insurance contributions (and their equivalents in any non-UK jurisdiction).
What You Must Not Do
It is not acceptable for you (or someone on your behalf) to:
(a) Engage in any form of facilitating tax evasion or foreign tax evasion;
(b) Aid, abet, counsel or procure the commission of a tax evasion offence or foreign tax evasion offence by another person;
(c) Fail to promptly report any request or demand from any third party to facilitate the fraudulent evasion of tax (whether UK tax or tax in a foreign country), or any suspected fraudulent evasion of tax (whether UK tax or tax in a foreign country) by another person, in accordance with this policy.
(d) Engage in any other activity that might lead to a breach of this policy; or
(e) Threaten or retaliate against another individual who has refused to commit a tax evasion offence or foreign tax evasion offence or who has raised concerns under this policy.
Your Responsibilities
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of tax evasion and foreign tax evasion is the responsibilities of those working for us or under our control. You are required to avoid any activity that might lead to or suggest a breach of this policy.
ust notify your manager as soon as possible if you 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 payment is not subject to VAT.
How to Raise a Concern
You are encouraged to raise concerns about any issue or suspicion of tax evasion or foreign tax evasion at the earliest possible stage to the Chief Executive Officer, Jack Ramsey by email: jack.ramsey@tripstax.com.
If you become aware of any fraudulent evasion of tax (whether UK tax or tax in a foreign country) by another person in the course of your work, or 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 of tax has occurred or may occur, whether in respect to UK tax or tax in a foreign country, you must notify the responsible person / team as identified above a soon as possible.If
you are unsure about whether a particular act constitutes tax evasion or foreign tax evasion, raise it with your manager as soon as possible. You should note that the corporate offence is only committed where you deliberately and dishonestly take action to facilitate the tax evasion or foreign tax evasion. If you do not take any such action, then the offence will not be made out. However, a deliberate failure to report suspected tax evasion or foreign tax evasion, or “turning a blind eye” to suspicious activity could amount to criminal facilitation or tax evasion.
Protection
Individuals who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises a genuine concern in good faith under this policy, even if they turn out to be mistaken.
We are committed to ensuring no one suffers any detrimental treatment as a result of:
(a) Refusing to take part in, be concerned in, or facilitate tax evasion or foreign tax evasion by another person;
(b) Refusing to aid, abet, counsel or procure the commission of a tax evasion or foreign tax evasion by another person.
(c) Reporting in good faith their suspicion that an actual or potential tax evasion offence or foreign tax evasion 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 you believe that you have suffered any such treatment, you should inform the CEO immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
Training & Communication
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.
Our zero-tolerance approach to tax evasion and foreign tax evasion must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate after that.
Breaches of this Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Modern Slavery Act Transparency Statement 2023
Statement
The UK Modern Slavery Act 2015 requires Businesses to disclose their efforts to address the issues of Slavery and Human Trafficking in their supply chains. The disclosures are intended to provide clients with the ability to make informed decisions about the services they buy and companies they support.
TripStax and its subsidiaries (the Company) believes that sustainable growth should be based on, and driven by, two fundamental principles: those of expertise and integrity. These principles are clearly outlined in the Company’s Ethics & Conduct Policy. The Company firmly believes that working closely in partnership with our clients, stakeholders and supply chain enables us to establish Ethical trading which avoids Slavery and Human Trafficking.
The Company is committed to zero-tolerance in human rights violations related to our own operations, our partner network and that of our supply chain. As such all members of staff are required to undertake mandatory Ethics training on the Company’s training platform.
The Company is committed to acting ethically and with integrity in all our business relationships, and as far as is reasonably possible to ensure slavery and human trafficking is not taking place anywhere within our supply chains. The supply chain includes companies who provide travel, hotel, car hire, and other travel related services on a Global basis and fulfil travel requirements that we deliver to our clients.
This statement has been approved by our Board of Directors, who will review and update it as necessary on an annual basis. This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes the Company’s Slavery and Human Trafficking Statement for the financial year ending 2022.
Signed,Jack Ramsey
Chief Executive Officer
November 2023
TRIPSTAX TECHNOLOGIES LTD SUPPLIER CODE OF CONDUCT
About this Code
Corporate integrity, responsible sourcing, and the safety and wellbeing of workers across the global supply chain are of paramount importance to TripStax Technologies Ltd and its subsidiaries (the Company). These core principles are reflected in this Supplier Code of Conduct (Code), which establishes the minimum standards that must be met by any business or entity that supplies products or services to the Company.
In this Code: Supplier: means a company, partnership or individual that provides goods or services to one or more members of the Company.
Associates: means the Supplier’s suppliers, vendors, agents and subcontractors who are involved in the Company’s supply chain.
Who Must Comply with This Code?
The Supplier must comply with this Code and must ensure that its workers are aware of this Code and comply with it. The Supplier must include in its agreements with Associates provisions that require Associates to comply with the applicable provisions of this Code. 1.
Standards of Compliance
In carrying out its obligations under its agreement(s) with the Company, the Supplier must comply with the standards set out in this Code and all applicable laws and regulations where it operates.
If there is a conflict between any applicable laws or regulations, the agreement between the parties, and this Code, the Supplier shall meet the most stringent standard.
Updating this Code
The Company has the right to modify this Code from time to time and will ensure that the most up-to-date version of the Code will be published on its corporate website.
Workforce Issues
Slavery, Human Trafficking and Forced Labour. The Supplier shall comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force in any part of its supply chain. This includes, but is not limited to, not supporting or engaging or requiring any forced labour, the use of child labour, bonded labour, indentured labour, or prison labour.
Human Rights. The Supplier shall comply with all internationally recognised human rights understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work from time to time in force in any part of its supply chain.
Equal Opportunities. the Company is an equal opportunity employer. The Supplier shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement, or any employment practice on the basis of race, colour, national origin, gender, gender identity, sexual orientation, religion, age, marital or pregnancy status, disability, or any other characteristic other than the worker’s ability to perform the job subject to any accommodations required or permitted by law.
Freedom of Association and Collective Bargaining. The Supplier shall respect, and shall not interfere with, the right of workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining.
Working Environment. The Supplier shall: (a) provide a safe, healthy, and sanitary working environment and comply with all applicable health and safety laws and any other relevant laws where it operates; and (b) not support or engage in or require any hazardous labour to be performed by any person under the age of 18. Hazardous labour involves any work, that by its nature or the circumstances in which the work is undertaken, involves the substantial risk of harm to the safety or health of the worker if adequate protections are not taken. (c) ensure that working hours comply with national laws, collective agreements, and individual labour agreements of their workers.
Wages and remuneration. The Supplier must compensate all workers with wages, including overtime premiums, and benefits that at a minimum meet the higher of: (a) the minimum wage and benefits established by applicable law; (b) collective agreements; (c) industry standards; and (d) an amount sufficient to cover basic living requirements.
Information Security and Data Protection
Without prejudice to the agreement(s) between the Company and the Supplier, the Supplier shall have in place appropriate measures to: (a) protect the integrity and confidentiality of information (including information belonging to or supplied by the Company) held on its systems (which include physical and online or electronic systems); and (b) ensure that there is no unauthorised access of the information by third parties, including its Associates.
The Supplier shall comply with all data protection laws and requirements when processing any personal data on the Company’s behalf.
Environmental Responsibility
The Supplier shall ensure that: (a) its operations comply with all applicable environmental laws, including laws and international treaties relating to (but not limited to) climate change, waste disposal, emissions, discharges and hazardous and toxic material handling; (b) the goods it manufactures (including the inputs and components that it incorporates into its goods) comply with all environmental laws and treaties; and (c) it will only use (packaging) materials that comply with all applicable environmental laws and treaties and shall use recyclable materials to the greatest extent possible.
The Supplier shall have in place a suitable environmental management system, process or policy for managing its environmental risks. As a minimum, these should include and address the following: (a) an assessment of the environmental impact of all historical, current and likely future operations; (b) steps to continuously improve environmental impact by reducing pollution, emissions and waste through the revision of existing practices, processes, systems and technologies and the adoption of new ones, and to comprehensively measure environmental performance; and (c) raising awareness and training employees in environmental matters.
Bribery and Corruption
The Supplier must maintain the highest ethical standards and shall comply with all applicable laws, statutes, codes, and regulations relating to the prevention of bribery and corruption. To that end, the Supplier shall not accept, offer, promise, pay, permit or authorise: (a) bribes, facilitation payments, kickbacks or illegal political contributions; (b) money, goods, services, gifts entertainment, employment, contracts or other things of value, in order to obtain or retain an advantage; and (c) any other unlawful or improper payments or benefits.
Unfair Business Practices
The Supplier shall comply with all applicable competition laws including but not limited to those relating to teaming and information sharing with competitors, price fixing, and rigging bids.
Sourcing and Managing of Associates
When assessing the Supplier’s performance against the requirements set out in this paragraph, the Company shall consider the risk profile of the transaction, the Supplier’s ability to comply with the requirements and the consequences where the Supplier fails to meet those requirements.
The Supplier shall carry out appropriate due diligence of its prospective Associates that will form part of the Company’s upstream supply chain. As a minimum, the due diligence should include the following: (a) investigations into prospective suppliers’ stance, public statements, compliance with applicable laws and other actions on human rights, treatment of workers, bribery, ethical behaviour and the environment; and (b) risk assessments for countries from which materials, components, or finished goods are sourced.
When dealing with Associates, the Supplier shall: (a) ensure that all agreements with Associates include provisions that require the Associates to comply with applicable provisions of this Code; (b) ensure that it has measures to monitor that those Associates are complying with those compliance related provisions; and (c) pay its Associates promptly, compliant to locally applicable standards.
Training
The Supplier shall implement a system or process for training for its employees and Associate to ensure that they are aware of the requirements of this Code.
Supplier shall keep a record of all training offered and completed by its employees and Associates and shall make a copy of such record available to the Company on request.
Self-Monitoring, Proof of Compliance and Audit
The Supplier shall monitor its compliance with the Code and shall report any violations (actual or suspected) of this Code as soon as possible to legal@tripstax.com.
The Supplier shall provide any certifications that are required to demonstrate compliance with all applicable laws and frameworks within 14 workdays of a written request from the Company.
The Supplier shall not retaliate or take disciplinary action against any Supplier employee or Associate that has, in good faith, reported violations of this Code or questionable conduct, or who has sought advice regarding this Code.
The Supplier shall upon request provide written confirmation to the Company that: (a) it has appropriate systems in place to ensure its and its Associates compliance with this Code; and (b) it is able to comply with this Code for the duration of its relationship with the Company.
In addition to the written confirmation above, the Company may conduct audits to verify the Supplier’s compliance with this Code. The Company has no obligation to conduct such audits.
The Supplier will provide to the Company by request a copy of its own Code of Conduct (or equivalent).
Breach, Remediation and Termination
Where the Company becomes aware of any violation (actual or prospective) by the Supplier or its Associates of the Code, the Company may require the Supplier to produce a remediation plan that will lead to compliance with the Code and present it to the Company within 28 workdays of being requested to do so.
If the Supplier fails to produce the remediation plan within this timeframe or fails to implement it within a reasonable time, the Company may immediately upon notice terminate the applicable agreement(s) or commercial relationship with the Supplier (including any purchase orders and contracts between them).
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