Code of Conduct | Situ - Our Commitments

Introduction and Purpose

This Code of Conduct (“Code”) sets out the minimum standards that Situ requires of all partners (“Partners”) when providing accommodation and related services to Situ’s corporate clients and guests in occupation.

Scope and Application

This Code applies to all Partners, their employees, workers, agents, contractors, subcontractors, and managing agents, as well as all suppliers and subcontractors involved in delivering accommodation and/or goods and services pursuant to a Situ booking (“Supply Chain”). Partners must cascade equivalent obligations through their Supply Chain and ensure compliance is monitored and enforced. Partners are responsible for ensuring that everyone within the Supply Chain, is aware of, and operates in accordance with, this Code, and shall be liable for any of their acts or omissions.

Legal Compliance and Governance

Partners must operate lawfully, ethically and with integrity, maintaining accurate records and avoiding conflicts of interest, bribery, facilitation payments or fraudulent conduct.

Accommodation must comply with applicable laws, statutes, regulations and codes in the jurisdiction where the accommodation is provided, including planning, building, health and safety, fire, gas and electrical safety, data protection, anti-bribery and modern slavery legislation.

Partners must obtain, maintain and comply with all licences, permits, registrations, notifications, consents, approvals and authorisations required to lawfully market, offer, manage, let or provide accommodation and related services in the relevant jurisdiction, including any requirements applying to short-term rentals, serviced accommodation, guest accommodation, tourism, immigration, police, municipal, tax, health and safety or hospitality registration schemes.

Partners must ensure that all required filings, registrations, notifications and renewals are completed accurately and within applicable time limits and must provide evidence of compliance to Situ on request.

Compliance is required with anti‑bribery and anti‑corruption laws and the UK Bribery Act 2010 where applicable.

Health, Safety and Security

Safe, Fit and Compliant Accommodation

Partners must ensure accommodation is safe, secure and fit for occupation, with all applicable and legally required health and safety measures in place, including, including without limitation, fire, gas, electrical and building safety compliance where applicable, and must maintain appropriate and valid insurance.

By accepting the Situ booking, Partners confirm that all accommodation supplied is safe, secure and fit for occupation and that all legally required health and safety measures are in place and appropriate insurance is maintained.

Fire and Life Safety

Partners must complete and keep current fire risk assessments for all properties, implement appropriate measures in line with guidance from a registered external fire safety professional and/or local legislation, and ensure compliance with relevant fire safety regulations and law

Security Measures and Emergency Support

Partners must provide appropriate security measures, including but not limited to, specified door and window locks, intercom/CCTV where applicable, and 24‑hour reception or a 24‑hour contact line.

They must provide emergency management and maintenance support 24/7/365 and notify Situ of any changes to emergency contacts.

Incident Management and Reporting

Partners must operate procedures to manage property incidents such as fire, flooding or loss of utilities and keep guests safe and supported.

Any material safety issue, regulatory action or serious incident affecting accommodation must be notified to Situ promptly.

Mental Health and Wellbeing

Partners must take reasonable steps to safeguard the mental health and wellbeing of guests and frontline staff during incidents and complaints, including training designated contacts to handle escalations sensitively and providing access to support information where appropriate. This supplements existing requirements to ensure guests are safe from harm or injury and not subjected to harassment.

Policies and procedures must ensure a guest is not subjected to harassment and is safe from harm or injury as far as reasonably possible.

Accessibility

Partners must identify, document and communicate property accessibility features and limitations to Situ accurately, support reasonable adjustments for guests, and ensure safe egress is considered in fire risk assessments.

Regulatory Registration and Guest Verification

Partners must identify and comply with all applicable local, regional, national and international laws, regulations and regulatory requirements relating to guest registration, identity verification, immigration compliance, right-to-rent checks, police or tourism reporting, sanctions screening, occupancy reporting and record-keeping obligations applicable to the accommodation and the guests occupying it.

This includes, where applicable:

verifying the identity of guests and permitted occupants;
carrying out legally required checks on guests, occupants or bookers before or during occupation;
collecting, maintaining and securely storing guest records and documentation;
submitting guest information to governmental, regulatory, tourism, immigration, law enforcement or municipal authorities;
maintaining accommodation registration numbers, permits or licences; and
complying with any local restrictions on occupancy, stay duration, permitted use or guest categories.

Partners are solely responsible for determining which checks, registrations, notifications and reporting obligations apply in the jurisdictions in which they operate and for ensuring that such requirements are completed accurately and within the required timescales.

Partners must implement appropriate policies, procedures and training to ensure compliance with such obligations and must retain appropriate evidence of compliance for the period required by applicable law.

Where legally permitted, Partners shall promptly notify Situ of any actual or suspected breach, investigation, suspension, revocation or enforcement action relating to any registration, licence, permit or guest verification obligation that may affect the accommodation, a booking or the Partner’s ability to provide services.

For the avoidance of doubt, unless expressly agreed otherwise in writing, Situ is not responsible for carrying out local guest verification, registration, immigration, police reporting or similar regulatory checks in relation to guests or occupants, and the Partner remains fully responsible for compliance with such obligations.

Data Protection, Confidentiality and Cyber Security

Security Measures

Partners must implement appropriate technical and organisational measures to ensure the confidentiality, integrity, availability and resilience of systems and data, including encryption, access controls, vulnerability management, secure configuration, malware protection, logging and monitoring, regular testing, and timely restoration plans. Partners are expected to take all reasonable steps to keep systems and devices secure, including antivirus, software updates and secure Wi‑Fi.

Data Breach and Security Incident Response

The Partner must notify Situ immediately and in any event within 24 hours of becoming aware of any personal data loss, unauthorised processing or personal data breach, provide specified information without undue delay and cooperate in investigation and mitigation.

Data Subject Requests and Retention

Partners must operate processes to identify and notify Situ of data subject requests within forty‑eight hours and assist Situ and the client to respond. They must follow retention and secure deletion/destruction instructions and implement proportionate data minimisation and retention controls.

Sub‑processors and International Transfers

Sub‑processors require Situ’s prior specific written authorisation and the Partner remains fully liable for their performance. The Partner shall not transfer or process personal data outside the EEA without Situ’s prior written consent and must put appropriate safeguards in place where consent is granted.

Environmental, Social and Governance (ESG)

Environmental Responsibility

Partners are encouraged to operate in an environmentally responsible manner, complying with applicable environmental laws and seeking to reduce energy use, manage waste and support sustainable practices where practicable.

Human Rights and Labour Standards

Situ requires compliance with modern slavery legislation, prohibition on forced and child labour, fair working conditions and respect for freedom of association. Partners are expected to promote equality and non‑discrimination and provide a workplace free from harassment and bullying.

Staff Training and Competence

Partners must ensure that all personnel are competent and appropriately trained for their roles, including regular training on:

Health, safety, fire and emergency procedures applicable to the accommodation.
Data protection, secure handling of personal data, confidentiality, cyber hygiene and incident reporting.
ESG topics including modern slavery, anti‑bribery/anti‑corruption and environmental responsibility.
Accessibility awareness and reasonable adjustments.
Mental health awareness for guest‑facing and incident‑handling staff.

Information Accuracy, Complaints and Client/Guest Care

Partners must provide full, accurate and not misleading information and immediately inform Situ of any changes or inaccuracies relating to the accommodation and/or ancillary services to be provided.

Partners will promptly inform Situ of any complaints received and will work collaboratively to support their timely resolution. This includes providing relevant information, engaging in discussions as required, and escalating matters where necessary to facilitate an appropriate outcome.

Speaking Up, Whistleblowing and Non‑Retaliation

Partners must operate a whistleblowing mechanism enabling staff and third parties to raise concerns in good faith about safety, misconduct, legal violations, data protection and ESG breaches, without fear of retaliation.

Material concerns that could affect guest safety, expose Situ or clients to legal or reputational risk, or undermine ethical standards must be raised with Situ promptly.

Situ will not tolerate retaliation against any individual who raises a concern in good faith.

Continuous Improvement, Audit and Assurance

Partners must monitor their compliance, review policies and controls at least annually, and implement corrective and preventive actions following incidents, complaints, audits or assessments.

Partners must carry out a reasonable level of due diligence (which shall be risk based) on the Supply Chain to ensure compliance with this Code and require corrective action, as appropriate.

In both cases and upon request, Partners will provide evidence of compliance, including certifications, policies, risk assessments and training records, and will facilitate site visits and inspections on reasonable notice.

Insurance

Partners must maintain comprehensive public liability, property owner’s and employer’s liability and other legally required or appropriate insurances, notify the insurer that premises will be let, and provide copies or evidence of valid cover on request.

Data Sharing with Third Parties

Where guest personal data is shared with third parties such as cleaners, contractors or service providers, Partners must ensure lawful basis, minimal disclosure, confidentiality and security, and that such parties are subject to equivalent obligations, including deletion and incident reporting and cooperation.

Consequences of Non‑Compliance

Failure to comply with this Code may result in remediation requests, suspension of listings, removal from sourcing channels, and/or termination of the commercial relationship. Situ may remove the Partner and/or accommodation from its website, suspend services or terminate the agreement where appropriate under the Partner Agency Terms and Conditions.

Acceptance and Ongoing Confirmation

Partners confirm they conduct business in accordance with the Code principles, will take reasonable steps to ensure their employees and Supply Chain operate to equivalent standards, will notify Situ of any material breach, and on request not more than once annually will provide written confirmation of continuing compliance.

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Accommodation Partner Code of Conduct