The Red Carnation Hotel collection subscribes to an ethos of honest, ethical and transparent business practices and it expects the same from its employees. This is a condition of employment. The company has therefore established a policy to recognise this commitment and to protect the financial interests of the company, which in turn protects the livelihood of its staff and their families.

The Red Carnation Hotel collection will regularly and consistently perform spot checks and internal audits on its business practices and systems in order to detect fraud and/or theft. Managers have the authority and are obligated to perform regular checks on the procedures and systems in any area where the company may be exposed, such as, petty cash, banking, use of company credit cards, use of company technology, etc.

The Red Carnation Hotel collection will take appropriate action in each and every instance of neglect, gross neglect, fraud, theft or similar. The Policy applies to all employees, temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of the company within the UK and overseas. Exceptions can only be made with the agreement of the Managing Director or Vice President People and Culture.

Procedure

1. The action could be, but is not limited to:

• A full investigation will be held using all means available at the company’s disposal;
• Any allegation will be investigated and disciplinary action will be taken if appropriate. The employee will be given the opportunity to refute the allegation(s) / prove their innocence / offer mitigating factors;
• A charge of Fraud / Theft / Misappropriation of Funds will be lodged with the Police and this action will be regardless of the outcome of the internal investigation;
• The Red Carnation Hotel collection will support a criminal conviction and imprisonment of the guilty party / parties whether all persons involved are employed by The Red Carnation Hotel collection or not;

2. Should any employee be aware of fraud / theft or any other irregular/ unlawful impropriety being perpetrated by another employee, and even though the observing employee may not be part of the fraudulent activity, it is expected that the observing employee informs the company of their knowledge and/or suspicions immediately.

3. Should investigations show that an employee(s) was aware of fraudulent activity and did not report it, this/these employee(s) will be charged as an accessory(ies) to the crime and the same action(s) as above will be applied to such persons.

To facilitate the confidential reporting of any suspected fraudulent activity, the company has established a Fraud Tip Off Line: Any suspected fraud or impropriety can be reported to:

Liz McGivern – Vice President People and Culture

lmcgivern@rchmail.com or 0207 963 0783.