Booking Terms
Please read the below and contact us if you have any questions.
We provide a platform through this Website for you to reserve apartments with Capital Residencies and our partner properties.
For our Partners, Nell Gwynn House we are acting solely as an intermediary between you and the Property Partner for the apartment you book. We have been authorised to act as its agent to take bookings for its apartments through this Website.
We transmit the details of your Booking Request to the Property Partner and send you a Confirmation of your Contract for and on behalf of the Property Partner. Our sole obligation to you is to provide a booking service for and on behalf of our Property Partners in accordance with these Terms.
When a Confirmation is issued, you will be entering into a legally binding contract for the provision of the Serviced Apartment directly with the applicable Property Partner.
By making a Booking Request through the Website you confirm that you have read and agree to these Terms and the Terms of Stay displayed on this Website on the date of your Booking Request. The Terms of Stay are provided by Property Partner and are contained within the description of each Serviced Apartment. If you do not fully agree to these Terms and the relevant Terms of Stay, you are not authorised to make a Booking Request.
The Contract between you and the Property Partner will consist of these Terms, the applicable Terms of Stay and the Confirmation.
1. DEFINITIONS
1.1 The following definitions in this clause apply in these Terms:
1.1.1 Additional Services means additional services which may be offered to you and/or Guests by the Property Partner subject to the Terms of Stay or any other terms provided to you by the Property Partner in relation to a Serviced Apartment, including but not limited to dry cleaning and laundry services, transfer services, internet and telephone services and call out services, as applicable
1.1.2 Booking Period means the period during which you and/or Guests are entitled to occupy the Serviced Apartment as set out in the Confirmation;
1.1.3 Booking Request means a request made by you through the Website to book a Serviced Apartment for you and/or Guests for a specified period subject to these Terms and the Terms of Stay or a request by you to us to book any alternative Serviced Apartment that we suggest;
1.1.4 Cancellation Fee means the charge payable by you in the event that you cancel a Contract or we cancel a Contract in accordance with clause 9.3 (as applicable) as set out in the Terms of Stay (and if no cancellation fee is specified in the Terms of Stay, the cancellation fee set out in clause 5 of these Terms will apply);
1.1.5 Confirmation means the written confirmation of your Booking Request emailed to you by us when your Booking Request has been accepted by the Property Partner. The confirmation shall detail the Serviced Apartment, Booking Period and the amount due from you in accordance with the payment terms set out in the Terms of Stay and shall also include a copy of these Terms and the Terms of Stay for the property booked;
1.1.6 Contract means the contract between you and the Property Partner for your confirmed booking of the Serviced Apartment consisting of these Terms, the applicable Terms of Stay and the Confirmation;
1.1.7 Guest means the person or persons who are named in the Booking Request or otherwise authorised by the Property Partner in writing to use a Serviced Apartment during the Booking Period and this does not include you;
1.1.8 our / us / we means Capital Residencies & Accommodation Limited, a company registered in England and Wales whose registered address is at Nell Gwynn House, Sloane Avenue, SW3 3AX and whose company registration number is 10622622.
1.1.9 Property Partner means the owner or provider of the Serviced Apartment;
1.1.10 Serviced Apartment means the apartment advertised on the Website (or offered to you in accordance with clause 2.10) for which you have made a Booking Request and for which we have issued a Confirmation;
1.1.11 Serviced Apartment Rates means the fees payable for the Serviced Apartment, as set out in the Terms of Stay for the full Booking Period. For the avoidance of doubt, the Serviced Apartment Rates do not include the cost of any Additional Services;
1.1.12 Terms means these booking terms and conditions;
1.1.13 Terms of Stay the Property Partner's terms and conditions displayed on the Website (and also provided to you within the Confirmation), which may include details of the booking procedure, Serviced Apartment Rates, payment period and terms, applicable security deposit, cancellation policy, extension policy and any Additional Services in respect of the relevant Serviced Apartment;
1.1.14 Website means www.capitalresidencies.co.uk
1.1.15 Working Day means a day on which banks generally open for business in the City of London excluding Saturdays or Sundays;
1.1.16 you / your means the person, firm or company who makes a Booking Request on behalf of yourself and/or on behalf of Guests.
2. BOOKING REQUESTS
2.1 Please ensure that you read and understand these Terms and the Terms of Stay before you make a Booking Request. The Terms of Stay are provided by the Property Partner providing the Serviced Apartment and may limit or exclude the Property Partner's liability to you. By submitting a Booking Request you are confirming that you agree to these Terms and the Terms of Stay.
2.2 You must be at least 18 years old to make a Booking Request.
2.3 If you are making a Booking Request as an individual (rather than on behalf of a business) please include your credit card details in the Booking Request as we are unable to issue a Confirmation of your booking without these details.
2.4 Please let us know if you are aware of any medical conditions, disabilities or other requirements that may affect your booking when you make your Booking Request.
2.5 Please check that the details in your Booking Request are complete and accurate, before you submit it.
2.6 We will endeavour to contact you with a Booking Request Response as soon as possible and at least within 2 Working Days from when you make your Booking Request.
2.7 Please check the details in the Confirmation carefully. If anything is incorrect, you must inform us immediately.
3. PAYMENT
3.1 Payment must be made in pounds sterling and payment can be made by debit or credit card. Please note that any credit card payments refunded on cancelled bookings may take up to 10 working days to reach the cardholders account. We do not accept payment by AMEX.
3.2 Property Partners may require that payment is made in advance, and therefore your credit card may be pre-authorised or charged when the Confirmation is issued. Please check the payment terms in the Terms of Stay carefully for any such conditions prior to making your Booking Request.
3.3 The Property Partner may also require payment of a security deposit to cover any damage to the Serviced Apartment or breakages during the Booking Period, cleaning charges if the Serviced Apartment is left in an unsatisfactory condition and the non-payment of Additional Services. If this applies to your Serviced Apartment it will be set out in the Terms of Stay. We, acting as agent of the Property Partner, shall require a pre-authorisation of your credit card for the amount requested by the Property Partner when the Confirmation is issued. We will only charge your credit card if requested to do so on behalf of the Property Partner and in accordance with the relevant Terms of Stay. As we are only acting as agent on behalf of the Property Partner, any dispute about the security deposit and any deductions must be taken up with the Property Partner directly.
3.4 If you do not make any payment due under the Contract by the required date we, on behalf of the Property Partner, are entitled to assume that you want to cancel your Contract. In this case, your Contract will be cancelled immediately and the provisions in clause 5 shall apply.
3.5 Any Additional Services offered to you and/or Guests by the Property Partner shall be subject to separate fees and terms between you and/or Guests and the Property Partner.
4. CHANGES
4.1 Please let us know as soon as possible if you want to change any of the details of your original Booking Request. We will pass on any change requests to the Property Partner but we cannot guarantee that the Property Partner will be able to meet your request. In the event that the Property Partner cannot accommodate your changes and you wish to cancel your Contract the Cancellation Fee will be payable in accordance with clause 5.
5. CANCELLATION BY YOU
5.1 By making a Booking Request you agree to the relevant cancellation and no-show policy of the Property Provider which is provided as part of the Terms of Stay.
5.2 You must pay the applicable Cancellation Fee if you cancel a Contract after a Confirmation has been issued. You do not have a right to cancel the Contract under the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 as this is a contract for the rental of accommodation for residential purposes.
5.3. CANCELLATION POLICY (Updated March 2021)
For stays under 14 nights, there is a cancellation policy of 24 hours.
For stays between 14-29 nights, there is a cancellation policy of 7 days.
For stays over 30 nights, there is a cancellation policy of 14 days.
Cancelling within the policy will incur a 100% charge. Once you are in-house the same terms apply
6. CANCELLATION BY THE COMPANY
6.1 In the unlikely event that your Contract has to be changed or cancelled by the Property Partner we will notify you as soon as reasonably practicable and we shall endeavour to offer you another apartment of an equal or better standard for no extra cost, subject to your approval.
6.2 In the event that no alternative accommodation is available or you do not accept the alternative offered in accordance with clause 6.1 above and the Contract is terminated then, provided that you are not in breach of these Terms or the Terms of Stay, we will refund in full all fees paid by you for the days that you have not occupied the Serviced Apartment.
6.3 You agree to pay the Cancellation Fee in the event that we or the Property Partner cancel your Contract pursuant to clause 9.3 (termination for your default) provided that you have not paid the Booking Fee in full on the date of termination. If you have already paid the Booking Fee in full then you will not be charged the Cancellation Fee but you shall not be entitled to a refund.
7. EXTENDING THE BOOKING PERIOD
7.1 Any extensions you require to the Booking Period will be subject to the Terms of Stay and any additional terms provided to you by the Property Partner.
7.2 Please note that the Serviced Apartment may not automatically be available for a further period as it may be pre-booked for another customer.
7.3 If you would like an extension then you must contact us as early as possible and we shall contact the Property Partner to check if the Serviced Apartment is available for the dates you require or if another suitable apartment is available.
8. ARRIVAL AND DEPARTURE
8.1 Arrival and departure times for your Contract will be as stated in the Terms of Stay. In the event that no arrival and departure times have been provided, you and/or any Guests (as applicable) may occupy the Serviced Apartment after 3.00 p.m. on the first day of the Booking Period, and must vacate the Serviced Apartment by 10.00 a.m. on the last day of the Booking Period.
9. YOUR OBLIGATIONS
9.1 You agree to, and you agree that all Guests shall:
9.1.1 keep the Serviced Apartment clean and tidy and leave it in the same condition as you found it at the start of the Booking Period;
9.1.2 not remove any items provided by the Property Partner in the Serviced Apartment, for example but not limited to bedding, towels, linens and kitchen equipment. You agree to pay the Property Partner for the costs of replacing such items if any such items have been removed or are missing at the end of the Booking Period;
9.1.3 not allow any pets in the Serviced Apartment unless otherwise stated in the Terms of Stay, or agreed in writing by the Property Partner;
9.1.4 not smoke in the Serviced Apartments unless the Terms of Stay say otherwise;
9.1.5 only allow the maximum number of people permitted by the Property Partner to stay in the Serviced Apartment overnight;
9.1.6 allow the Property Partner and any workmen access to the Serviced Apartment on reasonable notice to you during the Booking Period (unless in an emergency or if a problem needs sorting out quickly and you cannot be contacted in time, in which case you agree that the Property Partner and/or its representatives can enter the Serviced Apartment at any time without notice to you).
9.2 You agree to be responsible for all damage or breakages caused by you and/or any Guests to the Serviced Apartment and all items provided within it (for example carpets, mattresses and linen) during the Booking Period and to pay the Property Partner for the costs of damage to the Serviced Apartment and the costs of repairing or replacing any damaged or broken items. If you have provided a security deposit (as described in clause 3.6) we may deduct the costs of such damage and breakages from your credit card on behalf of the Property Partner in accordance with the Terms of Stay. You or a Guest may need to check and sign an inventory of the Serviced Apartment and its contents on arrival.
9.3 The Property Partner, or we, on behalf of the Property Partner, may terminate your Contract and ask you to leave with immediate effect without providing you with a refund of the Booking Fee if in the Property Partner or our reasonable opinion, you or any visitor to the Serviced Apartment have:
9.3.1 committed any illegal activity;
9.3.2 behaved antisocially or caused a nuisance to neighbours, for example playing music in such a manner as to be audible outside the Serviced Apartment at any time;
9.3.3 caused any damage or acted in a way that is likely to cause damage to the Serviced Apartment or any other person or property;
9.3.4 acted in a way which could expose us or the Property Partner to any third party liability or to criminal liability;
and if your Contract is terminated under this clause 9.3 you shall pay the Cancellation Fee in accordance with clause 6.3.
10. INSURANCE
10.1 We are not liable for any loss of or damage to your possessions belonging to you or to any visitors to the Serviced Apartment during your stay in the Serviced Apartment. We therefore strongly recommend that you take out travel insurance for your possessions and for other risks during your stay at the Serviced Apartment.
11. INFORMATION ON THE WEBSITE
11.1 All information about the Serviced Apartments contained on the Website has been provided by our Property Partners. Property Partners are responsible for ensuring the information on the Serviced Apartment, the Serviced Apartment Rates, and their Terms of Stay are accurate, not misleading and up to date. Although we require our Property Partners to provide accurate information we cannot guarantee that this information is accurate, complete or correct, and we shall not be liable for any loss, damage, cost or expense arising either directly or indirectly from errors (including typographical errors), inaccuracies or omissions contained in such information. Each Property Partner remains responsible at all times for the accuracy, completeness and correctness of the information provided about their Serviced Apartment (including the Serviced Apartment Rates) displayed on the Website.
11.2 The Website does not constitute and should not be regarded as a recommendation or endorsement of the quality or service level of any Serviced Apartment made available.
12. COMMUNICATING WITH YOU
By submitting a Booking Request you will be sending us your personal information and the personal information of any Guests. You must have the consent of any Guests before you disclose their personal information to us. By booking with capitalresidencies.co.uk you are subscribed to receive news and information from us. For further information on how we use and share your personal information please see our Privacy Policy which can be found on our website.
13. COMPLAINTS
13.1 If you have any queries or concerns about the booking service we have provided through the Website you can contact us by emailing us at reservations@capitalresidencies.co.uk or phoning us on +44 (0)203 595 5375.
14. GENERAL
14.1 These Terms shall be read and interpreted without reference to their clause headings, which are included for convenience only.
14.2 These Terms and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims), will be governed by English law. If you are a consumer you agree to the non-exclusive jurisdiction of the courts of England and if you agree to these terms in a business capacity you agree to the exclusive jurisdiction of the courts of England.
14.3 With the exception of Capital Residencies & Accommodation Limited (acting as agent for the Property Partner), a person who is not a party to the Contract shall not have any rights to enforce any term of the Contract. The Contract may not be varied or rescinded without the consent of Capital Residencies & Accommodation Limited.
14.4 No tenancy of the Serviced Apartment is deemed to be granted or shall arise under these Terms or the Terms of Stay.
14.5 No waiver by us of any breach of these Terms by you shall be considered as a waiver of any subsequent breach of the same or any other provision. We shall not be deemed to have waived performance of any obligation by you under these Terms unless we have expressly waived such performance in writing.
14.6 If any provision of these Terms is held by any competent authority to be invalid or unenforceable in whole or in part the validity of the other provisions of these Terms and the remainder of the provision in question shall not be affected.
14.7 All rights and remedies provided under these Terms are cumulative.
14.8 These Terms are made in the English language only. By booking with williamhemmingassocaites.com you are subscribed to receive news and information from us. We will NEVER pass your details on to third parties. To unsubscribe or change your settings please contact us.
Anti-Bribery & Anti-Corruption Policy
1. What does your policy cover?
1.1 This anti-bribery policy exists to set out the responsibilities of Capital Residencies & Accommodation and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.
1.2 It also exists to act as a source of information and guidance for those working for Capital Residencies & Accommodation . It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.
2. Policy statement
2.1 Capital Residencies & Accommodation is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. Capital Residencies & Accommodation has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.
2.2 Capital Residencies & Accommodation will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.
2.3 Capital Residencies & Accommodation recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind
that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.
3. Who is covered by the policy?
3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.
3.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.
3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.
4. Definition of bribery
4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.
4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.
4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.
4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is
a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.
5. What is and what is NOT acceptable
5.1 This section of the policy refers to 4 areas:
· Gifts and hospitality.
· Facilitation payments.
· Political contributions.
· Charitable contributions.
5.2 Gifts and hospitality
Capital Residencies & Accommodation accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:
5. It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
6. It is not made with the suggestion that a return favour is expected.
7. It is in compliance with local law.
8. It is given in the name of the company, not in an individual’s name.
9. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
10. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
11. It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
It is given/received openly, not secretly.
It is not selectively given to a key, influential person, clearly with the intention
of directly influencing them.
It is not above a certain excessive value, as pre-determined by the company’s
compliance manager (usually in excess of £100).
It is not offer to, or accepted from, a government official or representative or
politician or political party, without the prior approval of the company’s compliance manager.
5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.
5.4 Capital Residencies & Accommodation recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.
5.5 As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.
5.6 The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.
5.7 Facilitation Payments and Kickbacks
Capital Residencies & Accommodation does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery
that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.
5.8 Capital Residencies & Accommodation does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.
5.9 Capital Residencies & Accommodation recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:
Keep any amount to the minimum.
Ask for a receipt, detailing the amount and reason for the payment.
Create a record concerning the payment.
Report this incident to your line manager.
5.10 Political Contributions
Capital Residencies & Accommodation will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.
5.11 Charitable Contributions
Capital Residencies & Accommodation accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.
5.12 Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.
5.13 We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager.
6. Employee Responsibilities
6.1 As an employee of Capital Residencies & Accommodation , you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.
6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.
6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.
6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. Capital Residencies & Accommodation has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.
7. What happens if I need to raise a concern?
7.1 This section of the policy covers 3 areas:
1. How to raise a concern.
2. What to do if you are a victim of bribery or corruption.
3. Protection.
7.2 How to raise a concern
If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Capital Residencies & Accommodation , you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director, or the Head of Governance and Legal.
7.3 Capital Residencies & Accommodation will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.
7.4 What to do if you are a victim of bribery or corruption
You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.
7.5 Protection
If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, Capital Residencies & Accommodation understands that you may feel worried about potential repercussions. Capital Residencies & Accommodation will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.
7.6 Capital Residencies & Accommodation will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.
7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.
7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the compliance manager immediately.
8. Training and communication
8.1 Capital Residencies & Accommodation will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.
8.2 Capital Residencies & Accommodation ’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and
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any third-parties at the outset of business relations, and as appropriate thereafter.
8.3 Capital Residencies & Accommodation will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities.
9. Record keeping
9.1 Capital Residencies & Accommodation will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.
10. Monitoring and reviewing
10.1 Capital Residencies & Accommodation’s compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.
10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.
10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager.
10.4 This policy does not form part of an employee’s contract of employment and Capital Residencies & Accommodation may amend it at any time so to improve its effectiveness at combatting bribery and corruption.