Compliance and Anti-Corruption Policy

Last Updated: May 9, 2026

1. Purpose

This policy sets out Viqal's commitment to ethical business conduct. We do not tolerate bribery, corruption, unethical incentives, or any behavior that undermines trust in our company, our customers, or our partners.

2. Scope

This policy applies to all Viqal employees, founders, contractors, and anyone acting on behalf of Localpepper B.V. (trading as Viqal). All subprocessors and partners are expected to operate by equivalent standards.

3. Anti-Bribery and Anti-Corruption

  • Offering, giving, requesting, or accepting bribes is prohibited.
  • A bribe includes any payment, gift, benefit, or advantage intended to influence a business decision.
  • Facilitation payments are not allowed.
  • We comply with all applicable anti-bribery and anti-corruption laws, including the Dutch Penal Code, the UK Bribery Act 2010, and the US Foreign Corrupt Practices Act where applicable.

4. Gifts and Entertainment

  • Modest, reasonable hospitality may be permitted if it is not intended to influence a business decision.
  • Employees must not offer or accept gifts, entertainment, or favors that could create an obligation or the appearance of improper influence.
  • Any uncertain situation must be escalated to management before acting.

5. Commissions, Incentives, and Payments

  • Any commissions, referral fees, or incentives must be transparent, contractual, and reviewed by management.
  • Undisclosed payments or off-book arrangements are prohibited.
  • All financial transactions must be recorded accurately in our books and records.

6. Interactions with Customers and Government Officials

  • Extra care is required when dealing with government officials, including officials of state-owned hotels or tourism authorities.
  • No gifts, payments, or special treatment may be offered to influence official decisions.
  • Any engagement with public sector entities must follow formal procedures and approval.

7. Sanctions and Trade Compliance

Viqal complies with applicable economic sanctions and export control laws, including those of the European Union, the Netherlands, the United Kingdom, and the United States. We do not knowingly do business with sanctioned individuals, entities, or jurisdictions. Customer onboarding includes basic screening against publicly available sanctions lists.

8. Human Rights and Modern Slavery

Viqal is committed to respecting human rights in line with the UN Guiding Principles on Business and Human Rights. We do not tolerate forced labor, child labor, human trafficking, or any form of modern slavery within our operations or our supply chain. We expect the same standards from our subprocessors and partners.

9. Conflicts of Interest

Employees, founders, and contractors must disclose any actual or potential conflicts of interest that could affect their judgment in business decisions. This includes:

  • Financial interests in customers, suppliers, or competitors.
  • Personal relationships that could influence decisions.
  • Outside business activities that could compete with or affect Viqal.

Disclosed conflicts will be reviewed by management, and appropriate steps will be taken to manage or eliminate them.

10. Data and AI Ethics

Viqal develops and operates AI systems that interact with hotel guests on behalf of our customers. We are committed to:

  • Transparency: guests are informed when they are interacting with an AI system.
  • Privacy: personal data processed through our AI systems is not used to train AI models, in line with our Data Processing Agreement.
  • Human oversight: our AI is designed to escalate to human staff when instructed or when escalation is appropriate.
  • Accuracy: we make reasonable efforts to minimize errors in AI-generated communication and provide tooling for hotels to correct, configure, and override AI behavior.

11. Whistleblower Protection

Anyone raising a concern in good faith about a suspected violation of this policy, applicable law, or ethical standards will be protected from retaliation.

  • Reports can be made confidentially to info@viqal.com.
  • Concerns will be investigated promptly.
  • Reasonable steps will be taken to maintain the reporter's confidentiality.
  • Retaliation against any reporter acting in good faith is itself a violation of this policy.

12. Consequences of Violations

Breaches of this policy may result in disciplinary action, including termination of employment or contract, and may be reported to relevant authorities where required by law. Civil and criminal liability may also apply.

13. Review and Updates

Viqal reviews this policy at least annually and updates it as needed to reflect legal, operational, or industry changes. The "Last Updated" date at the top of this policy reflects the most recent revision.

14. Contact

For questions about this policy or to report a concern:

Email: info@viqal.comPost: Localpepper B.V., Barbara Strozzilaan 201, 1083HN Amsterdam, The Netherlands

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