Ethical Business Policy: Anti-Bribery, Anti-Corruption and Modern Slavery

1.1 This Policy establishes VMT's standards concerning ethical business conduct, bribery, corruption, fraud, conflicts of interest, modern slavery, forced labour, child labour and human trafficking.

1.2 This Policy applies to VMT's directors, employees, contractors, representatives, agents, guides, drivers, suppliers and business partners to the extent relevant to their relationship with VMT.

1.3 VMT expects persons acting on its behalf to comply with applicable law and to conduct business honestly.

1.4 VMT will take a proportionate, risk-based approach to implementation, taking account of the size, structure and activities of the business.

1.5 VMT's principal operations concern travel services in Morocco, while VMT is incorporated in the United Kingdom.

1.6 The Policy therefore considers relevant UK requirements together with applicable Moroccan law and relevant international standards.

2.1 VMT's anti-bribery framework is principally informed by:

a. Bribery Act 2010;

b. Criminal Finances Act 2017 where applicable;

c. Proceeds of Crime Act 2002 where applicable;

d. Modern Slavery Act 2015;

e. applicable employment and labour legislation;

f. applicable Moroccan law;

g. applicable anti-trafficking and forced-labour requirements;

h. other applicable laws governing VMT's activities.

2.2 The UK Bribery Act 2010 creates offences including offering, promising or giving a bribe, requesting or accepting a bribe, bribery of foreign public officials and failure by certain commercial organisations to prevent bribery.

2.3 The Modern Slavery Act 2015 consolidates UK offences concerning slavery, servitude, forced or compulsory labour and human trafficking.

2.4 VMT will not assume that compliance with UK law alone satisfies every legal requirement applicable to activities performed in Morocco or other jurisdictions.

2.5 Where mandatory local law imposes additional requirements, VMT will comply with those requirements.

3.1 VMT conducts business according to the following principles:

a. honesty;

b. integrity;

c. transparency;

d. lawful conduct;

e. fair dealing;

f. respect for human dignity;

g. responsible supplier relationships;

h. protection of customers and workers;

i. accurate business records;

j. responsible use of company resources.

3.2 VMT does not tolerate deliberate dishonest conduct undertaken for commercial advantage.

3.3 VMT expects business decisions to be based on legitimate commercial considerations.

4.1 VMT prohibits bribery.

4.2 No person acting for or on behalf of VMT may:

a. offer a bribe;

b. promise a bribe;

c. give a bribe;

d. request a bribe;

e. agree to receive a bribe;

f. accept a bribe;

g. arrange a bribe through another person;

h. authorise another person to make an improper payment.

4.3 A bribe might involve money or another financial or non-financial advantage.

4.4 The fact that a payment is described as a “commission”, “fee”, “tip”, “facilitation”, “marketing expense” or another commercial term does not determine whether the payment is lawful.

4.5 VMT will assess the substance and purpose of a payment.

5.1 VMT prohibits improper payments or advantages offered to foreign public officials.

5.2 Particular caution applies when dealing with:

a. government officials;

b. customs officials;

c. immigration officials;

d. police officers;

e. municipal officials;

f. regulators;

g. employees of state-owned or state-controlled organisations;

h. political officials;

i. persons acting in an official capacity.

5.3 Payments must not be made to influence an official decision improperly.

5.4 VMT personnel must not use intermediaries to achieve an outcome which VMT could not lawfully achieve directly.

6.1 VMT prohibits facilitation payments where they constitute improper payments under applicable law.

6.2 A facilitation payment generally involves an unofficial payment made to encourage or secure routine governmental action.

6.3 Calling a payment a “small fee” does not make the payment lawful.

6.4 VMT personnel should refuse requests for unofficial payments where reasonably safe to do so.

6.5 Where a person faces an immediate threat to personal safety, VMT does not require conduct which places that person at unreasonable risk.

6.6 Any payment made under duress should be reported to VMT as soon as reasonably possible.

6.7 VMT will record and assess such incidents.

7.1 Genuine business hospitality is not automatically prohibited.

7.2 Gifts or hospitality must:

a. have a legitimate business purpose;

b. be reasonable and proportionate;

c. comply with applicable law;

d. not influence or appear intended to influence a business decision improperly;

e. not create an obligation to provide preferential treatment.

7.3 Particular caution applies during:

a. tender processes;

b. supplier selection;

c. contract negotiations;

d. regulatory proceedings;

e. government interactions;

f. disputes.

7.4 Cash gifts are prohibited where they create a bribery or improper-payment risk.

7.5 Gifts or hospitality offered to public officials require particular scrutiny.

8.1 Ordinary customer gratuities and customary tips do not automatically constitute bribery.

8.2 VMT personnel must not request personal payments in exchange for services they are already contractually required to provide.

8.3 Customers must not be pressured to provide gifts or additional payments.

8.4 Suppliers must not offer VMT personnel personal benefits in exchange for preferential treatment.

9.1 A conflict of interest might arise where a person's personal interests interfere, or appear to interfere, with VMT's interests.

9.2 Potential conflicts should be disclosed promptly.

9.3 Examples include:

a. ownership of a supplier;

b. undisclosed financial interests;

c. family relationships with suppliers;

d. personal financial benefits;

e. outside business activities;

f. preferential treatment of connected persons.

9.4 A conflict does not automatically constitute misconduct.

9.5 VMT will assess the circumstances and determine appropriate safeguards.

10.1 VMT prohibits fraud.

10.2 Fraud might include:

a. false invoices;

b. fabricated expenses;

c. false booking information;

d. manipulation of financial records;

e. fraudulent refunds;

f. misuse of company funds;

g. false supplier claims;

h. identity fraud;

i. deliberate concealment of material information;

j. other dishonest conduct intended to obtain an advantage or cause a loss.

10.3 VMT may investigate suspected fraud.

11.1 VMT will maintain accurate and appropriate business records.

11.2 Records should accurately reflect:

a. payments;

b. expenses;

c. commissions;

d. supplier charges;

e. refunds;

f. gifts and hospitality where required;

g. contractual transactions.

11.3 No person may create false or misleading accounting records to conceal an improper payment.

11.4 Off-book accounts and undisclosed funds must not be created for improper purposes.

12.1 VMT does not knowingly participate in money laundering.

12.2 VMT will take reasonable measures appropriate to its business to identify suspicious financial activity.

12.3 VMT might consider indicators including:

a. unusual payment arrangements;

b. unexplained third-party payments;

c. requests for refunds to unrelated accounts;

d. suspicious overpayments;

e. inconsistent customer information;

f. transactions lacking a legitimate commercial explanation;

g. requests to circumvent ordinary payment procedures.

12.4 VMT might request additional information where reasonably necessary.

12.5 VMT might refuse or suspend a transaction where required by law or where a significant fraud or financial-crime risk exists.

13.1 VMT will take reasonable steps to comply with applicable sanctions requirements relevant to its business.

13.2 VMT might screen relevant parties or transactions where proportionate and appropriate.

13.3 VMT might refuse or suspend transactions where required by applicable sanctions law.

14.1 VMT opposes modern slavery in all forms.

14.2 Modern slavery includes conduct falling within applicable legal definitions of:

a. slavery;

b. servitude;

c. forced or compulsory labour;

d. human trafficking;

e. exploitation involving coercion.

14.3 VMT expects suppliers and business partners to take reasonable steps to prevent slavery and trafficking in their operations and supply chains.

15.1 VMT prohibits forced or compulsory labour.

15.2 Workers should not be required to work through:

a. threats;

b. coercion;

c. unlawful restriction of movement;

d. confiscation of identity documents for exploitative purposes;

e. unlawful debt bondage;

f. threats of violence;

g. other unlawful coercive practices.

15.3 VMT expects suppliers to comply with applicable labour laws.

16.1 VMT does not support unlawful child labour.

16.2 VMT expects suppliers to comply with applicable minimum-age and child-protection requirements.

16.3 Work involving young persons must comply with applicable law concerning age, working conditions, hours and safety.

16.4 VMT will consider heightened risks where tourism activities involve children.

17.1 VMT opposes human trafficking and exploitation.

17.2 VMT will take concerns seriously where there are indications that a person involved in a VMT service might be subject to trafficking or exploitation.

17.3 Relevant concerns might include:

a. restricted freedom of movement;

b. threats or intimidation;

c. unexplained control over identity documents;

d. apparent coercion;

e. severe exploitation;

f. unexplained control of wages;

g. suspicious recruitment arrangements.

18.1 VMT expects recruitment to be lawful and fair.

18.2 VMT will not knowingly use recruitment arrangements involving forced labour or trafficking.

18.3 Workers should receive clear information concerning:

a. their role;

b. expected duties;

c. remuneration;

d. relevant working conditions.

18.4 Recruitment fees imposed unlawfully on workers are inconsistent with VMT's ethical expectations.

18.5 VMT expects suppliers to take reasonable steps to prevent recruitment-related exploitation.

19.1 VMT does not support unlawful confiscation of workers' passports or identity documents.

19.2 Where temporary document handling is legally necessary, appropriate safeguards should apply.

19.3 Suppliers should not use document retention to control or exploit workers.

20.1 VMT expects suppliers to:

a. comply with applicable law;

b. prohibit bribery;

c. prevent forced labour;

d. prevent human trafficking;

e. avoid unlawful child labour;

f. maintain appropriate worker safety;

g. respect worker dignity;

h. maintain accurate records;

i. report serious concerns;

j. cooperate with reasonable investigations.

20.2 Relevant requirements might be included in supplier contracts.

20.3 VMT might assess supplier compliance according to risk.

21.1 VMT recognises that tourism supply chains might involve particular risks.

21.2 Such risks might arise in:

a. accommodation;

b. transport;

c. construction;

d. cleaning;

e. agriculture-related experiences;

f. activity operations;

g. informal labour;

h. recruitment;

i. subcontracting.

21.3 VMT will take reasonable steps proportionate to the risk and size of the business.

22.1 VMT might conduct proportionate supplier checks.

22.2 Checks might include:

a. business identity;

b. licences;

c. insurance information where applicable;

d. safety arrangements;

e. reputation;

f. contractual terms;

g. relevant legal compliance;

h. safeguarding considerations.

22.3 VMT will prioritise higher-risk relationships for greater scrutiny.

23.1 VMT might use agents, representatives or intermediaries.

23.2 VMT expects such persons to comply with applicable anti-bribery requirements.

23.3 VMT will not knowingly use an intermediary to conceal an improper payment.

23.4 Remuneration should be commercially reasonable and properly documented.

24.1 Legitimate commissions are not prohibited.

24.2 Commissions should:

a. have a legitimate commercial basis;

b. be documented;

c. be proportionate;

d. be properly recorded;

e. not constitute an improper inducement.

24.3 Hidden payments designed to influence decisions improperly are prohibited.

25.1 VMT will not make political contributions for the purpose of obtaining improper business advantage.

25.2 Any political activity involving VMT resources must comply with applicable law.

25.3 Personal political activity by an individual is not automatically attributable to VMT.

26.1 Charitable donations must have a legitimate purpose.

26.2 Donations must not disguise:

a. bribery;

b. political payments;

c. supplier inducements;

d. payments to obtain preferential treatment.

26.3 VMT might conduct reasonable checks where a donation presents an elevated risk.

27.1 Sponsorship must have a legitimate business or community purpose.

27.2 Sponsorship must not be used to obtain improper influence.

27.3 Sponsorship arrangements should be documented where appropriate.

28.1 Anyone may report a concern involving:

a. bribery;

b. corruption;

c. fraud;

d. money laundering;

e. modern slavery;

f. forced labour;

g. child exploitation;

h. human trafficking;

i. serious supplier misconduct.

28.2 Reports should be sent to:

hello@visitmorocco.tours

28.3 Reports should contain factual information where possible.

28.4 A person does not need proof of wrongdoing before raising a genuine concern.

28.5 Deliberately false allegations are not appropriate.

29.1 Where a person faces an immediate threat to life or safety, emergency assistance should be sought first.

29.2 VMT should be notified as soon as reasonably safe.

29.3 VMT might contact relevant authorities where legally required or reasonably necessary.

30.1 VMT may investigate credible reports.

30.2 Investigations might involve:

a. reviewing records;

b. interviewing relevant persons;

c. reviewing supplier information;

d. examining payment records;

e. examining communications;

f. reviewing contracts;

g. obtaining professional advice.

30.3 VMT will seek to conduct investigations fairly and proportionately.

30.4 VMT will protect confidentiality where reasonably possible.

30.5 Confidentiality cannot be guaranteed where disclosure is legally required.

31.1 VMT will cooperate with competent authorities where legally required.

31.2 VMT might report suspected serious criminal conduct to appropriate authorities.

31.3 VMT will consider legal obligations concerning disclosure and confidentiality before making disclosures.

32.1 VMT does not support retaliation against a person who raises a genuine concern in good faith.

32.2 Retaliation might include:

a. threats;

b. harassment;

c. dismissal or termination in circumstances prohibited by law;

d. unfair treatment;

e. intimidation.

32.3 This protection does not prevent lawful action concerning unrelated misconduct.

33.1 Where applicable law provides whistleblower protection, VMT will respect those protections.

33.2 Persons raising concerns should use appropriate reporting channels.

33.3 VMT will not require a person to conceal unlawful conduct.

34.1 VMT will handle reports appropriately.

34.2 Information will be shared only with persons who have a legitimate reason to receive it, subject to legal requirements.

34.3 VMT might disclose information to:

a. professional advisers;

b. insurers;

c. auditors;

d. regulators;

e. law enforcement;

f. courts;

g. other competent authorities.

35.1 Personal data collected during an investigation will be processed under VMT's Data Protection, Privacy, Cookies, Retention and Data Rights Policy.

35.2 VMT will process investigation information according to applicable data-protection law.

36.1 VMT will maintain appropriate records concerning this Policy.

36.2 Records might include:

a. relevant training;

b. supplier checks;

c. reported concerns;

d. investigations;

e. gifts and hospitality where required;

f. payments;

g. contracts;

h. corrective action.

36.3 Records will be retained according to VMT's Data Retention Policy.

37.1 VMT will provide appropriate information or training concerning this Policy according to the risks associated with a person's role.

37.2 Higher-risk personnel might receive additional guidance concerning:

a. public officials;

b. supplier relationships;

c. payments;

d. gifts;

e. fraud;

f. modern slavery indicators.

37.3 Training requirements will be proportionate to VMT's size and risk profile.

38.1 Breaches of this Policy might result in:

a. investigation;

b. corrective action;

c. withdrawal of authority;

d. termination of a supplier relationship;

e. disciplinary action where applicable;

f. recovery of losses;

g. reporting to authorities where required;

h. termination of a contract where legally permitted.

39.1 VMT might suspend or terminate a supplier relationship following serious ethical misconduct.

39.2 VMT will consider:

a. severity;

b. evidence;

c. risk to customers;

d. risk to workers;

e. legal requirements;

f. corrective action;

g. recurrence.

40.1 VMT expects customers to respect this Policy when interacting with VMT personnel and suppliers.

40.2 Customers must not:

a. offer bribes;

b. request improper preferential treatment;

c. pressure staff into unlawful conduct;

d. knowingly participate in fraudulent transactions.

40.3 VMT might refuse an unlawful request.

41.1 VMT works with businesses and individuals operating in Morocco and might work with international agents, customers and suppliers.

41.2 VMT expects international partners to comply with applicable anti-bribery, anti-trafficking and labour laws.

41.3 Where legal requirements differ between jurisdictions, VMT will apply the stricter standard where appropriate and lawful.

41.4 VMT will not treat local custom as a justification for bribery, forced labour or exploitation.

42.1 Cultural or commercial custom does not automatically make an improper payment lawful.

42.2 VMT recognises that customary hospitality, tipping and legitimate commercial commissions exist within the tourism industry.

42.3 The key consideration is whether the benefit is legitimate, proportionate, transparent and lawful.

43.1 VMT will apply controls proportionate to its business.

43.2 Factors considered might include:

a. country risk;

b. supplier type;

c. public-sector involvement;

d. transaction value;

e. payment method;

f. use of intermediaries;

g. labour conditions;

h. vulnerability of workers;

i. customer safety;

j. previous concerns.

44.1 No commercial target, booking, commission or business opportunity justifies unlawful conduct.

44.2 VMT will not knowingly sacrifice legal compliance to obtain or retain business.

45.1 VMT will comply with applicable Modern Slavery Act 2015 transparency requirements where those requirements apply to VMT.

45.2 The statutory obligation to publish a modern slavery statement applies to organisations carrying on business or part of a business in the UK with a total annual turnover of £36 million or more.

45.3 Where VMT does not meet that statutory threshold, VMT will not represent that it is legally required to publish a statement under section 54 solely because it is a UK company.

45.4 VMT might nevertheless publish voluntary information concerning its approach where appropriate.

This distinction matters. VMT should not claim a statutory obligation which does not apply to the company.

46.1 VMT expects relevant suppliers to communicate serious modern-slavery concerns.

46.2 VMT might request additional information from higher-risk suppliers.

46.3 VMT might include modern-slavery requirements in supplier agreements.

47.1 VMT seeks to operate responsibly within the communities where it provides tourism services.

47.2 Ethical business includes respect for:

a. workers;

b. local communities;

c. customers;

d. cultural heritage;

e. applicable environmental requirements.

47.3 VMT's broader responsible-tourism requirements are addressed in its Environmental and Responsible Tourism Policy.

48.1 VMT will review this Policy periodically.

48.2 Reviews might consider:

a. changes to UK law;

b. changes to Moroccan law;

c. regulatory guidance;

d. supplier risks;

e. reported incidents;

f. changes in VMT's business;

g. international legal developments.

49.1 This Policy is governed principally by the laws applicable to VMT's UK operations, subject to mandatory laws applying to specific conduct or activities.

49.2 Nothing in this Policy removes mandatory legal obligations in Morocco or another jurisdiction.

50.1 Ethical, anti-bribery, corruption and modern-slavery concerns:

hello@visitmorocco.tours

50.2 Postal address:

VISIT MOROCCO TOURS LTD

82a James Carter Road

Mildenhall

Bury St. Edmunds

England

IP28 7DE

51.1 This Policy takes effect on 12 August 2026.

51.2 VMT will update this Policy where necessary to reflect material legal or operational changes.