Compliance Policy

Last updated: 2026-06-29

1. Purpose

This policy sets out CHATOTELLE LLC'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 CHATOTELLE LLC founders, contractors, representatives, and anyone acting on behalf of CHATOTELLE LLC. 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 of any kind are not permitted.

CHATOTELLE LLC complies with all applicable anti-bribery and anti-corruption laws, including the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act 2010, and equivalent laws in any jurisdiction in which we operate.

4. Gifts and Entertainment

Modest, reasonable hospitality may be acceptable if it is not intended to influence a business decision and is fully transparent.

We do not offer or accept gifts, entertainment, or favors that could create an obligation or the appearance of improper influence. Any uncertain situation must be assessed before acting.

5. Commissions, Incentives, and Referral Fees

Any commissions, referral fees, or incentive arrangements must be transparent, documented, and agreed upon in writing before being acted upon.

Undisclosed payments or off-book arrangements are prohibited.

All financial transactions are recorded accurately in company books and records.

6. Interactions with Government Officials

Extra care is required when dealing with government officials, including officials of state-owned hotels, tourism authorities, or any public sector entity — which is common in markets across the Middle East, Africa, and parts of Europe.

No gifts, payments, or special treatment may be offered to influence any official decision. Any engagement with public sector entities follows formal procedures only.

7. Sanctions and Trade Compliance

CHATOTELLE LLC complies with applicable economic sanctions and export control laws, including those administered by the US Office of Foreign Assets Control (OFAC), the United Nations, the European Union, and the United Kingdom.

We do not knowingly do business with sanctioned individuals, entities, or jurisdictions. Basic screening against publicly available sanctions lists is conducted as part of customer onboarding.

Where a jurisdiction presents legal, regulatory, or sanctions-based barriers to operation, CHATOTELLE LLC will not engage in that market until those barriers are resolved.

8. Human Rights and Modern Slavery

CHATOTELLE LLC 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 supply chain. We expect the same standards from our subprocessors and partners.

9. Conflicts of Interest

Any actual or potential conflict of interest that could affect judgment in business decisions must be disclosed. This includes:

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

10. AI Ethics

CHATOTELLE LLC 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, fine-tune, or improve any AI model, in line with our Data Processing Agreement. This is contractually enforced with our AI provider.

Human oversight: our AI is designed to escalate to hotel staff when instructed or when escalation is appropriate. Staff can take over any conversation at any time through the dashboard.

Accuracy: we make reasonable efforts to minimize errors in AI-generated communication and provide tooling for hotels to correct, configure, and override AI behavior at any time.

11. Data Protection

CHATOTELLE LLC processes personal data in accordance with its Privacy Policy and Data Processing Agreement. We are committed to handling all personal data lawfully, transparently, and securely, regardless of the jurisdiction in which our customers operate.

12. 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 contact@chatotelle.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.

13. Consequences of Violations

Breaches of this policy may result in termination of any contractual relationship with CHATOTELLE LLC and may be reported to relevant authorities where required by law. Civil and criminal liability may also apply.

14. Review and Updates

CHATOTELLE LLC reviews this policy at least annually and updates it as needed to reflect legal, operational, or market changes. The date at the top of this policy reflects the most recent revision.

15. Contact

For questions about this policy or to report a concern, contact us at contact@chatotelle.com or visit Chatotelle.com.