Code of Ethics
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Contents:
Foreword
I. The purpose of the Code of Ethics
II. The scope of the Code of Ethics
II. 1. Personal scope
II. 2. Temporal scope
III. Core values and expectations towards all employees, guests, and business partners
III. 1. Lawfulness and fairness
III. 2. Strengthening commitment, reliability, and loyalty
III. 3. Openness, transparency
III. 4. Protection of privacy and private interests
III. 5. Combating bribery (corruption)
III. 6. Competition
III. 7. Conflict of interest
III. 8. Safety and security
III. 9. Communication
III. 10. Employment and working conditions
III. 11. Harassment
III. 12. Non-discrimination, equal treatment, equal opportunities
III. 13. Environmental responsibility
IV. Further Company expectations of our employees in the workplace and in their relationships with colleagues
IV. 1. In the course of their work, our employees should
IV. 2. Employees in their workplace relationships should
IV. 3. Employees in private life should
V. Other specific conduct requirements for managers
V.1. To enforce the principles of the Code of Ethics
V. 2. For effective work managers should
V. 3. In carrying out management tasks managers should
V. 4. In their interactions with employees, managers should
V. 5. On recruitment, change of job, termination of employment managers should
V. 6. When assessing or recognising performance managers should
V. 7. In their relations with interest representation and advocacy organisations managers should
VI. Closing provisions
Appendix 1. Tax evasion policy
Appendix 2. Compliance policy on sanctions and restricting measures
Dear Colleagues, Guests, and Partners,
Ethical operation has been an important element of the continued success of our company for more than 50 years.
This is a minimum standard we observe and continue to uphold in the future so that we can proudly say that we belong to the well-respected community of Danubius Hotels Zrt.
Not only do we earn the trust of our guests and build partnerships with our suppliers with excellent professionalism, but we also create a safe environment and a supportive, retaining community of employees for all of us.
Success and integrity go hand in hand. This is what we believe, and this is what our parent company, the British CP Holdings Limited believes, too.
This Code of Ethics collects and structures the values we profess and stand for but also ensures their accountability. It is a tool for all of us. A compass that shows the right and unerring direction to follow.
Finally, the Code of Ethics is also a guarantee. A guarantee that Danubius Hotels Zrt. will always and in all situations stand up for those who abide by our rules. It protects them by enforcing the rules set out in it without exception and in all cases.
I trust that these core values and guidelines will strengthen the bonds between us, build trust in our business and human relationships.
Balázs Kovács
CEO
Danubius Hotels Zrt.
I. The purpose of the Code of Ethics
1. The purpose of issuing the Code of Ethics applicable to our Company is to establish the ethical principles adopted by CP Holdings Limited, the Company’s owner, and the Company’s Board of Directors,
- to set out a framework of ethical standards of behaviour, based on our Company's core values, which all our employees, guests and business partners must understand and comply with;
- to let all our employees, guests and business partners know that our Company is committed to complying with the law and the Code of Ethics and that we will protect all our employees, guests and business partners against any violations of the Code of Ethics or any alleged wrongdoing;
- to deter persons who commit an offence or engage in objectionable conduct from committing the infringement;
- to prevent the wrongful conduct from happening.
2. This Code of Ethics summarises and defines the standards of conduct and behaviour that:
- provide a good basis for identifying ethically objectionable conduct, acceptable conduct, conduct that should be encouraged or sanctioned, as well as for impartial judgement;
- help us make the right decisions and take the right positions in the situations that arise, thus ensuring efficient and transparent operations;
- provide a moral basis for building and deepening trust in employee and business relationships;
- are consistent with the standards and requirements that guide those concerned in managing the relationships they have or wish to establish with their workplace, guests and business partners, resolving problems or managing conflicts;
- provide protection for all standard setters and contribute to the preservation of human dignity.
3. While this Code of Ethics does not contain standards for all possible conduct, nor does it provide guidance for all possible situations, our Company will continue to monitor and, take action against ethically objectionable conduct, whether committed by an employee, guest, business partner or any other third party, using all legal means available.
4. Our Company expects the principles set forth in this Code of Ethics to be observed in all its relations with its guests, current and future business partners, and employees, and treats this as a top priority.
5. The present Code of Ethics does not contain provisions on offences covered by the Criminal Code (e.g.: theft, fraud, embezzlement, bribery, etc.) or other violations of the law. Where a legal standard is stricter than those described here, it must be complied with.
6. The „Tax evasion policy” and the „Compliance policy on sanctions and restricting measures” form an integral part of this Code of Ethics attached as an Appendix.
II. The scope of the Code of Ethics
II. 1. Personal scope
1. The Code of Ethics applies to all current and future employees, guests, and business partners of Danubius Hotels Zrt. or any other third party with whom our Company comes into contact.
II. 2. Temporal scope
1. The provisions of this Code of Ethics took effect on March 1, 2024, and were updated as of June 12, 2026. The updates are indicated in bold italics.
III. Core values and expectations towards all employees, guests, and business partners
A. We set expectations for all areas of our organisation to comply with and enforce the Code of Ethics.
We operate a whistleblowing system as required by law, the details of which are set out in a separate policy.
B. If an employee is in doubt about the appropriateness or inappropriateness of their own or another employee's, guest's or business partner's conduct, or is uncertain about an ethical issue, they may seek prior assistance from the compliance officer, their line manager, any manager, HR staff they are in connection with, the audit or legal director or any member of the Executive Committee.
III. 1. Lawfulness and fairness
1. All our employees are expected to report any suspected or actual violations of the law that come to their attention, as set out in the Code of Ethics or other policies.
2. It is a fundamental requirement of our Company that our employees, guests and business partners are bound by the Fundamental Law, legislation, other legal instruments of corporate governance and the basic norms of social coexistence as set out in this Code of Ethics.
3. We believe that all business is based on legality, integrity, and honesty. We provide a fair description of our services and price them accordingly. We respect the laws and regulations of the countries in which we operate, pay the appropriate public charges, and expect our business partners to do the same.
4. We are committed to tax compliance that focuses on the timely and accurate filing of complete tax returns in accordance with applicable tax laws and regulations, whereby our Company takes into account not only the text of the law but also—where clearly determinable—its spirit. In accordance with our parent company’s policy, our Company applies a zero-tolerance policy toward all forms of tax evasion and tax avoidance, as well as the facilitation of tax evasion and tax avoidance, regardless of where such activities occur, and expects the same from its business partners.
Our business operations require the identification and prudent management of risks, and we apply management practices that are necessary to mitigate the risks associated with taxes and other public charges. We expect all our business partners to operate lawfully and transparently. To manage the risks identified by our Company, we ensure that all identified risks and the procedures designed to mitigate them are communicated to relevant third parties throughout the business chain, so that they are incorporated into our relationships with our business partners and are clearly understood. In addition, our management requires those in our business chain and other relevant third parties to review, understand, and confirm with their signature their understanding of this and other relevant policies. Our stated principles, procedures, and expectations regarding tax compliance are set forth in the “Tax Evasion Policy,” attached as Appendix 1, which forms an integral part of this Code of Ethics
5. We are committed to paying close attention to compliance with all international and domestic sanctions and restrictive measures; our commitments and expectations in this regard are set forth in the “Compliance policy on sanctions and restricting measures,” attached as Appendix 2, which forms an integral part of this Code of Ethics. Compliance with and enforcement of the provisions contained therein is mandatory for all our employees and business partners.
III. 2. Strengthening commitment, reliability, and loyalty
1. All employees and business partners of our Company are expected to contribute to the enhancement of our more than half a century of good reputation, the promotion and conscious communication of our values, by working in a disciplined and ethical manner and in full compliance with the law and internal rules, and in accordance with generally accepted social standards.
2. We expect our employees to use the assets, valuables, and tools entrusted to them and to make use of the professional skills, methods, and information they have acquired with due care and diligence.
III. 3. Openness, transparency
1. We believe that openness and transparency promote informed decisions, understanding, and trust. We give everyone - whether an employee, a guest, or a business partner - the opportunity to speak up if they experience something that does not seem right, to come forward with confidence against unethical behaviour without concern for any negative consequences.
2. We aim to provide a workplace, business and hotel environment that is free from any form of abusive or threatening behaviour.
3. The Company offers protection against all forms of retaliation, so that no one in the company will be discriminated for voicing their concerns.
4. To protect the interests of our guests, business partners, and employees, the company proactively manages risks associated with third parties by conducting appropriate due diligence, rather than relying solely on good faith.
III. 4. Protection of privacy and private interests
1. The company respects the privacy and private interests of its employees, guests and business partners, while expecting loyalty and openness to the group and its interests.
III. 5. Combating bribery (corruption)
1. Bribery is the act of offering, giving, promising, agreeing to, accepting, or soliciting something of value or advantage in order to induce or otherwise influence another person to act or make a decision. Bribery may take the form of any reward or item of value offered to another person to obtain a business, contractual or personal advantage. Bribery is not limited to offering a bribe. It is also against the law for a person to stand on the receiving end of a bribe and to accept it.
2. In accordance with the Anti-bribery and Corruption policy of our owner, CP Holdings Limited, our Company has zero tolerance for bribery and corrupt activities and expects its business partners to take similar measures to prevent these from taking place.
3. The anti-corruption provisions apply to all our current and future employees, guests, business partners and all their agents and representatives. Our business relationships with our business partners is based on the principle that the parties will act professionally, fairly and in good faith in the conduct of their business. If there is reasonable ground to suspect that an employee or business partner has violated the rules against bribery and corruption set forth in this Code of Ethics, theCompany reserves the right to terminate the relationship with said employee or business partner, subject to the law.
4. In view of our zero-tolerance policy against bribery and corruption, our employees must not engage in any form of bribery, either actively or passively, or through a third party (such as an agent or distributor).
5. Gifts and hospitality
To avoid bribery, our employees may accept business gifts only on a limited basis, depending on the circumstances and in accordance with the specific rules applicable to them.
The Company will consider a customary business gift (regardless of who gives it to whom) to be acceptable if the giving or receiving of the gift meets the following requirements:
- it is in line with local legal regulations;
- it is clearly given on behalf of the business partner;
- it is appropriate to the circumstances, of the right type and value, and given at the right time, taking into account the reason for the gift;
- it is not given with the intent to influence, in exchange for an implied favour or benefit, to obtain or retain business or business advantage;
- it is non-cash or another cash substitute (e.g. vouchers or gift vouchers), excluding normal tips given to our employees directly involved in catering.
6. Facilitation payments and kickbacks
Facilitation payments are small payments (in cash or in kind) made to public officials for routine tasks that they are otherwise required to perform (e.g. to obtain permits, issue postal items or speed up the connection of utilities). Employees of our Company do not give or accept any Facilitation payments or kickbacks.
Legitimate administrative fees paid to an organisation (other than an individual) and legitimate payments made for expedited procedures, as well as payments for which an invoice can be issued on request, are not considered as facilitation payments.
7. Political contributions
Our Company will not make any donations, whether in cash, kind, or by any other means, to support any political parties or candidates as this may be perceived as an attempt to gain an improper business advantage.
8. Charitable contributions
Our Company 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.
Our Company will take all steps to ensure that charitable contributions are legal and ethical under local laws and practices, and that donations are not used to facilitate or cover up acts of bribery. Donations may only be offered/transferred through the compliance officer of our company with prior approval of the compliance officer of CP Holdings Limited.
9. Other high risk behaviours
Making false statements or providing false data, abuse of position, and withholding information are considered high-risk, common behaviours that are classified as risks of unlawful conduct. Financial reporting, procurement, and sales are high-risk areas for our Company, and we have implemented special customer due diligence procedures for these areas. To ensure transparency in its operations, the Company operates a preventive framework designed to eliminate unlawful conduct through the coordinated application of multiple safeguards. This framework is built around our employees, our processes, and our governance mechanisms to effectively mitigate risks.
The most important elements of prevention include risk assessments, internal audits, segregation of duties, a system of approval authorities, due diligence, training, and ongoing oversight of implementation by the Board of Directors, which is linked to accountability.
10. If any of our employees is unsure about whether something is a bribe, a facilitation payment, a gift or how to behave in relation to political or charitable donations, they can seek advice from the compliance officer.
III. 6. Competition
1. Our company conducts its business in accordance with fair competition standards and in compliance with applicable competition law. We collect information about our competitors only lawfully and use only publicly disclosed sources to acquire information about business, consumer, supplier and professional trends and actions of suppliers and competitors. We obtain this information lawfully and by fair means.
III. 7. Conflict of interest
1. Our Company believes it is important that no conflict of interest arises between its employees an in its relationships with guests and business partners, and therefore expects its employees, guests, and business partners to disclose any conflicts of interest they may encounter. Our Company is therefore in a position to take the necessary measures to remedy the situation to ensure fair business practices.
III. 8. Safety and security
1. Security must be a priority at work and in all areas of business, whether it's cybercrime, personal data or even potential dangers on working sites. We expect our employees, guests, and business partners to consider their own safety and security and that of others, ensuring the protection and security of everyone.
2.Security and protection are fundamental aspects of ethical conduct and are essential for preventing fraud and the misuse of sensitive information. Data protection compliance is linked to fraud prevention, as financial crime and cyber risks are closely interrelated. To mitigate these risks, our employees are provided trainings and must adhere to internal control measures to ensure the effective prevention of fraud and cyber risks in practice. The company expects all of its business partners to take the necessary measures to reduce the risks outlined in this section.
3.The company ensures the resilience, responsiveness, and effectiveness of its risk management framework through the proactive assessment and management of fraud, cyber, and third-party risks.
III. 9. Communication
1. Our company is committed to giving all employees, guests, and business partners the opportunity to share their ideas, concerns, suggestions, and feedback about our business without fear and with respect for the other party. In our communications, we will be careful and thoughtful, and we will go to great lengths to ensure that the language and tone we use is appropriate. All our business partners, guests, employees and third parties on our Company's premises are expected to behave in a courteous, polite, and respectful manner.
III. 10. Employment and working conditions
1. Regarding employment conditions, the Company is committed to the following principles, which it equally requires from its business partners:
- Child labour is not tolerated. Employees (including those working actually in any other form of employment) must not be younger than the minimum legal age for employment or the maximum legal school age. No underage workers/students may be employed between 22:00 and 6:00. When employing under-age workers/students, the age-specific characteristics must be considered.
- We condemn all forms of forced labour.
- Physical or psychological punishment, verbal abuse and all forms of intimidation are strictly prohibited.
- Work must be performed within the framework of employment established and recognised in accordance with the applicable legislation.
- We take all necessary measures to ensure a clean, safe, and healthy working environment.
- We take special care to protect the health of our employees, and we expect our business partners to refrain from any behaviour or production processes that could have a negative impact on the health of our employees.
- We take accident and fire prevention measures to ensure that our facilities and their equipment are safe. We provide continuous and well-documented information and risk management training to our employees to ensure safety on a broader basis.
- Employees are entitled in particular, but not exclusively, to wages, paid annual leave as provided by law, fringe benefits, social security benefits and other leave and benefits provided by law. Overtime shall be paid at the legally determined rate.
- Workers must receive a certificate of payment of their wages. The payroll should be scheduled at least monthly. Our company fully complies with the legal requirements and rules on remuneration, income and all other forms of fringe benefits, and expects its business partners to comply with them.
- Our Company recognises the right of its employees to form elected organisations without prior authorisation and acknowledges that employees may be members of such organisations and may freely and independently participate in collective bargaining.
III. 11. Harassment
1. Our company prohibits, classifies as harassment, and takes firm action against any conduct that is offensive, abusive, sexual, or otherwise of a nature that is related to a characteristic of a person and is intended to create an intimidating, hostile, humiliating, degrading, or offensive environment for the individual.
2. Our Company firmly rejects all forms of conduct that are not based on mutual respect, in the knowledge that harassment occurs when our conduct offends others, regardless of its intentionality. Our company firmly rejects harassment and any form of behaviour that is not based on mutual respect.
3. Our Company has a zero-tolerance policy for any conduct by current or prospective employees, guests or business partners that is directed against employees be it:
- unwelcome sexual advances, sexual comments, emails, messages in any format or physical contact (sexual harassment);
- against all forms of insulting or degrading remarks about an individual's personal qualities, even if they are intended as a joke or light banter (verbal harassment)
- hostile and unethical communication, usually by one or more persons towards a person who is left in a vulnerable and hopeless situation (psychological harassment).
4. If one of our employees believes that he or she has been harassed by another employee, guest, or employee of our business partner, or if one of our guests or business partners believes that he or she has been harassed by one of our employees:
- can clearly indicate to the harasser that their behaviour is unacceptable, they should stop, recalling that our Company firmly prohibits all forms of harassment and that any violation of this prohibition will be strictly sanctioned within the limits of the law;
- note down what happened (date, time, place, situation, witnesses) and keep all evidence of the misconduct (e.g. documents, written conversations etc.);
- if you consider it necessary for our Company to intervene, report the incident immediately, even if you do not wish to disclose your name, through the dedicated reporting system.
5. The Company will stand firmly by the persons who have suffered harassment, will treat his or her report strictly confidential and will provide him or her with special protection if he or she reports in good faith. No employee of the Company who has suffered any form of harassment is alone.
6. In case of harassment the person concerned may turn to the compliance officer, their line manager, any manager, HR staff he is in connection with, the audit or legal director or any member of the Executive Committee.
7. We assure all our employees, guests, and business partners that harassment cases will be investigated professionally and in full confidentiality, and that strict action will be taken against the harasser.
III. 12. Non-discrimination, equal treatment, equal opportunities
1. Our Company condemns negative, open, or implicit discriminatory treatment (act, activity, statement, omitted act, behaviour). We are firmly opposed to any form of discrimination that affects the equal opportunities of a person or group of persons.
2. Our Company considers discrimination any judgement that is made against a person not on the basis of his or her actions, but on the basis of his or her alleged characteristics or membership of a group with such characteristics. Considering that discrimination is a violation of the human dignity of all persons equally, the Company has a zero tolerance policy towards discrimination based on race, origin, social, national or ethnic origin, colour, sex, sexual orientation, marital status, parental status, childbearing status, age, disability, language, religion, political or other opinion, personal beliefs, property or other status, or any other characteristic, and expects full acceptance of all forms of discrimination against its employees, guests and business partners.
3.We are committed to the principle of equal treatment andexpect all our employees, guests, and business partners to treat all people, any group of people and other economic actors with the same respect and care, with equal consideration for the individual and without discrimination.
4. In light of the above our Company has zero tolerance towards the following conduct:
- Direct discrimination: if a person or group is, has been, or would be treated less favourably than another person or group in a comparable situation is, because of a perceived or real protected characteristic.
- Indirect discrimination: conduct which does not constitute direct discrimination, and which appears to comply with the requirement of equal treatment, and which puts persons with a protected characteristic at a substantially greater disadvantage than a person or group in a comparable situation is, was or would be in a comparable situation.
- Unlawful segregation: if, on the basis of a protected characteristic, a person or a group of persons is segregated from persons or groups of persons in a comparable situation, without this being expressly permitted by law.
- Retaliation: conduct which causes, seeks to or threatens to cause legal harm to a person who objects to, initiates or participates in proceedings for breach of the requirement of equal treatment.
5. Different treatment should in all cases be based solely on expertise and professional experience in our Company
1. Our company is committed to integrating sustainability into all areas of its business operations and to making decisions—and, where appropriate, taking concrete actions—with sustainability considerations in mind. This includes implementing measures to reduce water waste and energy consumption, as well as expanding the use of renewable energy sources.These practices should extend beyond day-to-day operations and influence the attitudes and behaviors of our employees and all parties with whom the Company conducts business, thereby promoting the wider adoption of sustainable practices. By encouraging everyone to consider the environmental impact of their daily activities, we contribute to fostering a culture of continuous improvement toward a more responsible mindset and sustainable operations.
2. The company is committed to environmental protection, sustainable development, and the conservation of natural resources. We expect all our employees and business partners to act responsibly in this area. If an employee observes unhealthy conditions or environmental damage, it must immediately be reported to their line manager or the responsible person so that the necessary measures can be taken. We require our business partners to support alternatives to harmful manufacturing practices, prioritize the use of products produced or manufactured using environmentally friendly methods, and ensure that their procedures regarding hazardous materials fully comply with legal regulations.
3. We believe that ethical conduct in the field of environmental protection goes beyond legal compliance. Promoting sustainability and responsible procurement helps reduce risks and fosters the company’s long-term resilience, while placing value-based operations at the forefront of the organization’s activities.
1. We expect our employees, regardless of their position in the organisational hierarchy, to continuously improve their professional and general knowledge, skills, competences, and abilities, and to perform their work professionally and to a high standard. All our employees must take responsibility for their actions and decisions.
2. At our company, all employees are expected to cooperate continuously, to be helpful and supportive, to build and maintain good working relationships in line with the hierarchical relationships in the areas concerned, and to be collegial in order to achieve common goals. In addition to the basic rules of social coexistence, and without being exhaustive, the following general guidelines and behavioural requirements are laid down:
IV.1. In the course of their work, our employees should
a) act in a way that is appropriate for the convincing and effective representation of the organisational goals and aspirations;
b) show their colleagues, managers, guests and business partners the respect they deserve, carry out the instructions they receive to the best of their ability and require each other to do the same;
c) behave in a manner consistent with the principles set out in this Code of Ethics and take action to address conduct that violates the Code of Ethics so that our Company can take appropriate action in a timely and appropriate manner;
d) display loyalty to the Company and its parent company, CP Holdings Limited and other members of the CP Group, as well as to its managers and employees;
e) act responsibly, reasonably, proactively and independently in the absence of clear job descriptions and in unforeseen and unexpected situations;
f) complete their working time efficiently, effectively, conscientiously and actively, meeting quality and quantity requirements;
g) act with integrity, care and good faith;
h) be aware of the importance of the tasks they have to carry out and the weight of their responsibilities;
i) keep up to date with internal regulations and legislation affecting their work and continuously strive to acquire, maintain and improve their professional knowledge, using it to the best of their ability in the performance of their duties;
j) show due consideration and courtesy to others;
k) place trust in others and earn the trust of others;
l) not put their managers, colleagues, guests, customers or partners in an unpleasant, humiliating, degrading or undignified situation, avoid personal or intrusive behaviour, or the denigration or discrediting of others;
m) display an appearance in accordance with the standards for their workplace;
n) keep their workplace and environment tidy and clean; they should consider it their personal responsibility to protect their health and safety and that of their colleagues, as well as the living and natural environment;
o) not consume alcohol, drugs or other mind-altering or psychotropic substances during working hours, and report to work well rested and free of these substances.
IV. 2. Employees in their workplace relationships should
a) always strive for cooperation and joint problem-solving when carrying out tasks;
b) their formal and informal contacts should be characterised by a collegial attitude based on mutual respect, acceptance and understanding, and in the event of any interruption or breakdown in communication for whatever reason, they should endeavour to restore the expected state of affairs;
c) try to resolve their professional and other problems and disagreements related to their work and conduct in a timely manner; if this is not possible, inform their manager of what has happened, if possible, in the presence of the other party, and ask for his help in resolving the disagreement;
d) not claim for themselves benefits or privileges beyond the agreed and regulated limits, and refuse such offers if any;
e) take care to protect each other's dignity, human and professional integrity, and remember that you are also protecting the honour of your workplace;
f) take responsibility for any wrong or inappropriate decisions or actions, do their utmost to correct or remedy them in a lawful and professionally appropriate manner, and accept and respond to valid criticism from managers and staff made as an opportunity to improve;
g) show a willingness to cooperate and provide selfless, collegial assistance to help our new colleagues integrate into the workplace; new colleagues should be actively involved in getting to know each other;
h) provide their managers, staff and other employees involved in the implementation of their professional tasks with the information they need to perform their work effectively, in a timely and effective manner;
i) do everything possible to achieve common results, to make group work more efficient, avoid competition and unnecessary rivalry where mutual cooperation, and assistance would be more beneficial.
IV.3. Employees in private life should
a) give no cause to doubt their integrity,
b) develop their relationships in such a way that they do not conflict with their obligations at work and do not create an unprincipled conflict of interest, commitment or dependency situation that would be contrary to the law or the specific company policy on conflict of interest;
c) not engage in activities in their free time that are unworthy of their work or service;
d) refrain from making any ambiguous or misleading statements or information, whether written or oral, in relation to their job duties, in particular on social media and to the press/media;
e) refrain from using obscene, abusive or violent language or discrimination on certain external media (e.g. Facebook, Instagram, etc., where our name is used as an employer) or internal communication platforms (e.g. DH CheckIn) that may be associated with your employment with our Company and that may reflect badly on our Company or cause fear or distress;
f) may make statements to the press only in accordance with the relevant internal rules.
V. Other specific conduct requirements for managers
In addition to meeting the general standards of conduct set out in this Code of Ethics, our top management is also required to comply with the following specific standards of conduct in the performance of their duties:
V.1. To enforce the principles of the Code of Ethics
a) in the event of a suspected or actual breach of ethics, regulations or the law, the necessary actions should be determined in consultation with their line manager or the compliance officer;
b) they should do their utmost to protect the privacy, reputation, honour, interests and confidentiality of victims of ethical or legal offences (with particular attention to victims of harassment, sexual violence and coercion as well as to minors);
c) employees under their authority should be encouraged to report incidents contrary to the principles of the Code of Ethics in order to enforce those principles.
V. 2. For effective work managers should
a) promote, by personal example, the development and maintenance of a cooperative, supportive, constructive and good working relationship and atmosphere in the departments under their leadership;
b) when allocating resources and assigning tasks, not abuse the power and opportunities of their position, and strive for equal workload when organising the division of labour also during cooperation with and between employees;
c) obtain the information needed to make decisions; provide other managers and employees with the information they need to carry out their work in a timely and appropriate manner; avoid withholding information, concealing information or providing information that could be misleading, in a way that could adversely affect the operation of the areas concerned;
d) encourage the development and fulfilment of talent and ensure equal opportunities for progress;
e) firmly refrain from any conduct that is contrary to this Code of Ethics and firmly uphold the core values set out in this Code of Ethics.
V.3. In carrying out management tasks managers should
a) take responsibility for communicating and enforcing instructions issued by other managers to all employees under the manager within the organisational hierarchy;
b) in issuing tasks, orders and instructions - for the successful or unsuccessful execution of which they are responsible - strive for clarity, objectivity and the use of an appropriate tone of voice that maintains the authority of the manager without compromising the dignity and self-respect of those reporting to him;
c) seek and take into account the opinions, ideas and suggestions of their subordinates, depending on the nature of the work to be done and the possibilities offered by the situation;
d) encourage their subordinates to actively engage in planning and managing their own work by delegating a specific range of managerial functions, and to consciously exploit the benefits of creativity, self-expression, and self-realisation.
V. 4. In their interactions with employees, managers should
a) display exemplary behaviour at work and in their private lives that is worth following;
b) demonstrate an open, tactful, patient and understanding attitude when listening to and solving professional and human problems, issues and concerns of their colleagues;
c) protect their employees by all possible means against unfounded accusations, slander, harassment and all forms of discrimination; in such cases, give the accused employees the opportunity to defend themselves; if the accusations are substantiated, cooperate with the compliance officer in implementing the necessary measures or take such measures consistently after consultation with the compliance officer;
d) resolve workplace problems and conflicts with tact, empathy and care, but without hesitation or delay;
e) contribute to establishing and maintaining their trustworthiness and credibility through their honesty and openness;
f) not instruct their subordinates to work or perform activities that serve explicitly their personal goals and interests;
g) take into account the personal circumstances of their staff when unforeseen situations require extraordinary work;
h) show due social sensitivity in solving the problems of their subordinates; know and take into account their family, health, financial, existential and other - humanly reasonable - circumstances; in relation to them, observe any phenomena that indicate an unjustified change of lifestyle and do their best to solve or alleviate these problems;
i) help their subordinates who are facing difficulties; provide all necessary assistance within their competence, and, in the absence of their possibilities, initiate the Company's support for their staff in need;
j) be helpful and constructive in their dealings with each other, respect each other's authority and work together with the Company's objectives in mind.
V. 5. On recruitment, change of job, termination of employment managers should
a) take into account the professional qualifications of job applicants and refrain from any form of discrimination, both in the recruitment process and in the selection decision;
b) ensure equal opportunities for job applicants;
c) pay particular attention and care to applicants and new recruits; provide them with all the information they need to be properly informed and to help them make employment decisions and settle in as quickly as possible;
d) consider it an important task to introduce new staff and familiarise them with their job;
e) in all cases, terminate the employment of subordinates in a spirit of mutual respect and appreciation, and do not put them in an undignified position in the event of dismissal;
f) ensure a dignified farewell at retirement and that retirees have the opportunity to keep in touch with their former colleagues, if they wish;
g) place particular emphasis on the education of young people and on ensuring the placement of students in training who are temporarily employed by our Company.
V. 6. When assessing or recognising performance managers should
a) be consistent, realistic and fair in performance-related controls, accountability, incentives and recognition;
b) strive for objectivity and fairness in their assessments, always communicating their opinions personally to the colleagues;
c) aim performance appraisal interviews primarily at developing subordinates and encouraging better results;
d) judge the work, behaviour and attitude of their subordinates on the same basis, whether it is a question of pay, rewards or sanctions;
e) focus the continuous assessment of their subordinates on performance, improvement and personal development and not on the individual.
V. 7. In their relations with interest representation and advocacy organisations managers should
a) seek agreement on contentious issues and avoid unnecessary conflict;
b) strive to cooperate with the interest representations and advocacy organisations and to establish equal partnership.
VI. Closing provisions
1. The content of the Code of Ethics must be communicated to all employees concerned through training.
2. Before hiring new employees, the Code of Ethics should be shared with new employees.
3. The Code of Ethics constitutes a part of all agreements drawn up with guests and business partners.
Budapest, 12 June 2026
Appendix 1.
Tax evasion policy
Tax evasion and the facilitation of tax evasion or tax avoidance are prohibited.
The Parent Company of Danubius Hotels Zrt. and CP Regents Park Two Ltd. (hereinafter the Company), CP Holdings Ltd., is committed to ensuring that the members of the Group of Companies (hereinafter the Parent Company and its subsidiaries as CP Group) conduct their business activities in a fair and ethical manner. The CP Group has a zero-tolerance policy against any form of tax evasion and facilitation of tax evasion, regardless of whether the tax evasion or facilitation of tax evasion is committed in the United Kingdom or any other country, in which the Company conducts business.
As a member of the CP Group, the Company is committed to acting professionally, fairly and with integrity in all its business affairs and relationships, wherever it operates, and to implementing and enforcing effective systems against tax evasion or the facilitation of tax evasion.
The members of the CP Group will uphold all laws relevant to tax evasion and countering tax evasion, including the Criminal Finance Act of the United Kingdom of 2017. (Criminal Finances Act 2017, hereinafter: CFA 2017), in all jurisdictions in which they operate.
Definitions used:
Tax: for the purposes of this Policy, all mandatory monetary payments required by the state or other public authority on the basis of law, which must be made by individuals and organizations without receiving direct, individual compensation for this.
Tax evasion: tax evasion refers to behaviour where a person, in relation to an obligation to make payments into the public budget or to funds originating from the public budget:
- deceives another person, keeps them in error, makes a false statement, or conceals a material fact in connection with an obligation to pay into the public budget;
- unlawfully claims or takes advantage of a tax benefit, allowance, or relief connected with an obligation to pay into the public budget; or
- uses funds originating from the public budget for purposes other than those for which they were approved.
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 that there must be a deliberate action or omission with dishonest intent.
Foreign tax evasion: foreign tax evasion means evading tax in a country other than that of the Company, provided that the conduct is an offence in that country and would be a criminal offence if committed in the UK or any other relevant country. As with tax evasion, the element of fraud here as well, in line with Hungarian legal terminology, means there must be deliberate action or omission with dishonest intent.
hereafter as, tax evasion and foreign tax evasion together as Tax evasion
Tax avoidance: in a broader sense, it refers to the use of arrangements that may formally comply with the law but are primarily intended to reduce the tax burden and often run counter to the legislature’s intent. In some cases, the authorities may classify these as abusive.
Facilitating tax evasion or tax avoidance: this means that a person knowingly participates in fraudulent tax evasion or tax avoidance committed by another person (whether involving a UK tax, or a tax of any other country), or takes steps, provides assistance, encourages, advises, or assists in the commission of this offense. Facilitating tax evasion or tax avoidance is a criminal offense if done intentionally and dishonestly.
Third party: any individual or organization with whom one of our employees comes into contact in the course of their work at the Company; this includes actual and potential customers, clients, suppliers, distributors, business partners, agents, consultants, as well as government and public bodies—including their advisors, representatives, and officials, as well as politicians and political parties.
The purpose of this policy is:
If our company fails to prevent its employees or third parties from facilitating tax evasion or tax avoidance, it may face sanctions - including unlimited fines - and in light of this, we consider it important that our Parent Company, in line with the relevant policies of CP Holdings Ltd.:
a) determines the responsibility of our Company, our subsidiaries and our employees to comply with and maintain our position on tax evasion, tax avoidance and the prevention of its facilitation; and
b) provides information and guidance to our employees on how to identify and
what to do if they encounter tax evasion, tax avoidance or its facilitation
Who Must Comply with the Policy?
The policy applies to all persons working for the Company or any Companies where we have influence on our behalf in any capacity including employees of all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners, sponsors, or any other person associated with us wherever they are located.
What risks have been identified?
The CP Group has identified that the following are particular risks to the business:
- Work status of contractors in a form that can easily qualify as a disguised employment relationship or assignment or other legal relationship,
- Tax status of third parties / suppliers, particularly, but not exclusively registration in a tax haven, if the identity of the beneficial owner cannot be known from public data base
- Compliance with construction industry scheme
- Labor not provided by companies with a special license
- Sub-contractors
- Non-cooperative countries where business is performed;
- Changes in invoice details – bank account, dates of services, company name
- Cross border transactions
In addition to the above following is a list of possible red flags that may arise while you work for us, and which may raise concerns related to tax evasion or foreign tax avoidance.
If you encounter any of these red flags or if a business partner:
I. has filed or intends to file a false tax return, or has failed to file a tax return,
II. has failed to disclose income or gains to the tax authorities,
III. has set up or intends to set up a business structure to try to hide income, gains, or assets from the tax authorities,
IV. you become aware that an employee asks to be treated as a self-employed contractor, but without any material changes to their working conditions.
V. has deliberately failed to register for VAT (or the equivalent tax in any relevant non-UK jurisdiction) or failed to account for VAT.
VI. requests payment in cash not payment through an account held at a recognized bank and/or refuses to sign a formal commission or fee agreement or to provide an invoice or receipt for a payment made.
VII. requests that the regulations concerning the reverse charge mechanism not be applied;
VIII. requests that payment is made to a country or geographic location different from where the third party resides or conducts business,
IX. insists on the use of “side letters” (a separate agreement that hides the actual content of the contract (order) or refuses to put terms agreed in writing or asks for contracts or other documentation to be backdated,
X. asks us to change the description of services rendered by us on an invoice to another service,
XI. an invoice is received from a third party that appears to be non-standard or customised,
XII. an invoiced is received for a commission of fee payment that appears too large or too small, given the service stated to have been provided,
XIII. requests or requires the use of an agent, intermediary, consultant, distributor or suppler that is not typically used by or known to us.
the incident must immediately be reported to the supervisor.
b) To address the risks described above, the Company’s top management ensures that all identified risks and the procedures designed to mitigate them are communicated down the business chain to relevant third parties to ensure that they are embedded and understood by the third party and thus become acceptable. In addition, the Company requires participants in its supply chain and other relevant third parties to review, understand, and provide signatures demonstrating their understanding of this and relevant policies.
Who Is Responsible For The Policy?
The Board of Directors of the Company have overall responsibility for ensuring this Policy complies with our legal and ethical obligations and that all those under our control comply with it.
The CP Group Compliance Officer (Group Compliance Officer) has primary and day-to-day responsibility for implementing the policy issued by CP Holdings Ltd., while the Company Compliance Officer (Company Compliance Officer) for the monitoring of 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 and tax avoidance.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and head of HR is responsible for ensuring adequate and regular training on it.
What is Tax evasion or tax avoidance facilitation?
Under the CFA 2017, a separate criminal offence is automatically committed by a legal or corporate entity or partnership where the tax evasion, tax avoidance or its facilitation is done 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 accidently ignorantly or negligently facilitates the tax evasion, or tax avoidance 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 (tax optimisation) or tax planning. Tax evasion involves deliberate and dishonest conduct. Tax avoidance is not illegal and involves taking steps within the law to minimise tax payable.
What you must not do
It is not acceptable for any employee (or someone else acting on behalf of the employee) or any third party:
- to engage in any form of facilitating tax evasion or tax avoidance.
- to aid, abet, counsel or procure the commission of a tax evasion offence or offence by another person.
- to fail to promptly report any request or demand from any third party to facilitate the fraudulent evasion or avoidance of tax (whether UK tax or tax in any other country) or any suspected fraudulent evasion or avoidance of tax (whether UK tax or tax in a foreign country) by another person in accordance with this policy.
- to engage in any other activity that might lead to a breach of this policy; or
- to threaten or retaliate against another individual who has refused to commit a tax evasion offence or who has raised concerns under this policy.
Responsibilities of employees
All employees must ensure that they read, understand and comply with this policy.
The prevention, detection and reporting of tax evasion and tax avoidance are the responsibility of all those working for Companies belonging to CP Holdings Ltd. or under its control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
The employees must notify their direct manager as soon as possible if they 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 the payment is not subject to applicable tax.
How to raise a concern
Employees are encouraged to raise concerns about any issue or suspicion of tax evasion or tax avoidance at the earliest possible stage including in relation to potential “Red flags”.
If an employee becomes aware of any fraudulent evasion or avoidance of tax (whether UK tax or tax in any other country) by another person in the course of your work, or you 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 or avoidance of tax has occurred or may occur, whether in respect to UK or tax in a foreign country, you must notify your direct manager as soon as possible.
If an employee is unsure whether a particular act constitutes tax evasion, or tax avoidance, or not raise it with your direct manager as soon as possible. You should note that the corporate offense is only committed where you deliberately and dishonestly take action to facilitate the tax evasion or tax avoidance. However, a deliberate failure to report suspected tax evasion or tax avoidance or “turning a blind eye” to suspicious activity, could amount to criminal facilitation of tax evasion or tax avoidance.
Protection
Individuals who raise concerns or report another’s wrongdoing are sometimes worried about possible repercussions. The aim of CP Holdings Ltd. and the Company is to encourage openness and support anyone who raises genuine concerns in good faith under this policy even if they eventually turn out to be mistaken.
CP Holdings Ltd. and the Company are committed to ensuring no one suffers any detrimental treatment as a result of:
- refusing to take part in, be concerned in or facilitate tax evasion or tax avoidance by another person,
- refusing to aid, abet, counsel or procure the commission of a tax evasion offence or a tax avoidance offence by another person; or
- reporting in good faith their suspicion that an actual or potential tax evasion offence or tax avoidance 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 an employee believes that he has suffered any such treatment, he should inform the compliance manager immediately. If the matter is not remedied, any you are an employee, you should raise it formally by filing a report through the whistleblowing channels in line with our Whistleblowing Policy.
Training and 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; it may also form part of a training for relevant employees aimed at detecting and preventing financial crimes.
Our zero-tolerance approach to tax evasion and tax avoidance must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate after that, who by accepting our Code of Ethics also accept and acknowledge this Policy.
Breaches of this Policy
We will initiate proceedings against any employee who violates the provisions of this Policy, and a finding of a breach of obligations or a serious breach of obligations may result in employment-related disciplinary measures. Furthermore, we will terminate our business relationship with any third party that violates the provisions of this Policy.
Appendix 2.
COMPLIANCE POLICY ON SANCTIONS AND RESTRICTIVE MEASURES
Danubius Hotels Zrt. and CP Regents Park Two Ltd. (as the Company ) is committed to ethical, lawful, and transparent business practices and conducts its activities in accordance with the principles set forth in the Code of Ethics, with particular emphasis on legality, integrity, transparency, and the fight against corruption.
This Compliance Policy on Sanctions and Restrictive Measures forms part of the Code of Ethics and provides specific guidance on our Company’s expectations and procedures regarding sanctions, embargoes, and restrictive measures.
1. Scope of the Policy
A These regulations apply to:
- all business activities of the Company, that is, all business relationships, legal relationships, and transactions related to the operations, services, or collaborations of the Company, regardless of the form of the contract;
- legal entities that have a business or other cooperative relationship with the Company;
- any natural person who comes into direct or indirect contact with the Company, including:
- individuals providing services and sole proprietors,
- contributors and agents,
- employees of the Company, and
- within the framework of applicable laws
- guests using the Company’s services.
2. Applicable sanctions and restrictive laws
In the course of its business activities, the Company pays particular attention tothe European Union,
- the United Nations,
- the United States of America,
- the United Kingdom,
- as well as compliance with sanctions and restrictive measures imposed by applicable domestic laws.
3. Basic principles
The Company requires that any person or company associated with it in any capacity:
- not be subject to sanctions or embargoes;
- not engage in any activity aimed at directly or indirectly circumventing sanctions;
- comply with applicable laws and the principles of ethical business conduct in the course of their business operations or when utilizing the services provided by our Company, in accordance with the Code of Ethics of the Company.
4. Definitions
- Sanctions: International, EU, Hungarian, or other regulatory measures that restrict business activities with certain countries, organizations, or individuals.
- Embargo: A foreign trade restriction that prohibits certain goods, services, or financial transactions.
- Business partner: Any legal entity or individual with whom the Company has a legal relationship or conducts a transaction.
5. Risk management and Control
The Company is entitled to:
- request additional information in the event of a risk;
- screen its business partners using publicly available databases and sanctions lists
(e.g. Sanctions Map); - refuse to establish or terminate a business relationship where justified,
These measures serve the responsible and transparent operating principles set forth in the Company’s Code of Ethics.
6. Risk-taking principle
The Company reserves the right to refuse or terminate the establishment of a legal relationship or the execution of a transaction that:
- conflicts with the fundamental principles of this Policy, or
- although permitted under applicable Hungarian or European Union laws and not subject to sanctions or embargoes, is contrary to the values set out in the Company’s Code of Ethics, or
- entails disproportionate legal, financial, or reputational risk.
7. Legal consequences
Any violation of the fundamental principles set out in this Policy may result in the termination of the business relationship, the enforcement of claims for damages, and/or taking other legal actions.
8. Contact
If you have any questions, concerns, or would like further information, please contact our company using the contact details below:
- E-mail: compliance@danubiushotels.com
9. Regular review
The Company regularly reviews this policy in light of changes in legislation and business risks, ensuring that it always complies with current sanctions and embargo regulations.
Last updated: 12 June 2026.
