The Ultimate Maldives Holiday Now at Even Better Value with Club Med

first_imgThe Ultimate Maldives Holiday Now at Even Better Value with Club MedThe Ultimate Maldives Holiday Now at Even Better Value with Club MedNow is the best time for travel agents to secure their client’s dream holiday in the Maldives at even better value as Club Med announces from May, 2019, travellers can enter a world of elevated luxury at the award-winning Finolhu Villas for the same price as Club Med Kani’s Manta Exclusive Suites.Book by 30th November, 2018, to access Club Med’s infamous Early Bird offer – up to 30% off for departures May to October, 2019. Your client could experience a Bucket List Maldives holiday in a Finolhu Beach Villa from only $3,585pp (valued at $5,090) for 7 nights all-inclusive featuring:Gourmet all-day dining including freshly caught fish from the surrounding waters and pool- side snacking with ChampagnePremium open bar to enjoy overlooking the azure waters of the MaldivesPersonal butler who caters to your every needOwn outdoor terrace with private pool overlooking the oceanState-of-the-art villa with direct access to the white-sand beachActivities such as beach yoga and Stand Up Paddle BoardingComplementary speedboat access to nearby Club Med Kani for further activities, dining options, and nightly entertainmentThe Maldives with Club Med: 1 magical destination, 3 unique experiences:Club Med Finolhu VillasClub Med Finolhu Villas is paradise redefined offering the ultimate in eco-friendly luxury in the heart of the Indian Ocean. Indulge in champagne service from your private overwater or beach villa, which comes complete with personal plunge pool and direct access to the ocean from your deck. Your butler service is there to cater to all your needs and access to Club Med Kani is just a five-minute speedboat drive away.7 nights all-inclusive from $3,585pp (valued at $5,090pp) when booked by 30th November, 2018Based on twin share in a Beach Suite for bookings between 4th April – 22nd June, 2019Club Med Kani, Manta Exclusive Collection SuitesThe Manta Exclusive area of Club Med Kani is perfectly suited for guests who seek a private escape and elevated amenities perched above the lapping waters of the Indian Ocean. These premium Maldives overwater suites include breakfast to your room, Champagne at sunset, private beach, and more, all within moments of the action and activities enjoyed at Club Med Kani.7 nights all-inclusive from $3,585pp (valued at $5,135) when booked by 30th November, 2018Based on twin share in an Overwater Suite for bookings between 4th April – 22nd June, 2019Club Med KaniClub Med Kani is the ultimate endless turquoise playground in the Maldives, suitable for families looking for an indulgent escape. Enjoy unique must-try experiences of the Maldives including Kani’s new state of the art Dive Centre, coral rebuilding program allowing guests to help repair damaged reefs*, surfing*, flyboard* and more. There’s also brand new kids facilities for the little ones! Kani brings together delicious local cuisine, colourful marine life and pristine waters in one of the most beautiful places in the world.7 nights all-inclusive from $1,845pp (valued at $2,605) when booked by 30th November, 2018Based on twin share in a Superior Room for bookings between 4th April – 22nd June, 2019The leader in premium all-inclusive holidays, Club Med’s packages include gourmet meals and snacks with international delicacies and traditional local cuisine, an open bar, a vast selection of activities, entertainment and Kids Clubs, in addition to accommodation – taking the planning out of holidays, so your clients have more time to relax.For bookings and enquiries call Club Med on 1800 258 263 or for sales tools and resources to help you sell this offer, you can download flyers and Facebook tiles from the offer page on Club Med’s dedicated Travel Agent portal: www.clubmedta.com.auAbout Club MedClub Med provides amazing holiday experiences, made easy, in the world’s most beautiful destinations. With over 70 premium and luxury all-inclusive sun and snow resorts located in some of the most beautiful places on earth, Club Med resorts blend seamlessly with their environment, drawing inspiration from the local culture and nature to immerse guests in the destination.Since 1950, Club Med has been dedicated to providing guests with amazing new experiences that make for an unforgettable holiday – from the rejuvenating to the exhilarating, and everything in-between. Each resort offers a vast selection of opportunities to try something new, immerse in local culture, revive body and mind, and give back to the local community and environment.Club Med holidays are a truly hassle-free experience, with premium all-inclusive packages and a wide range of innovative services – giving guests more time to spend doing what they love.For more information, visit www.clubmed.com.au or follow Club Med at: * Instagram @clubmed * Facebook /ClubMedAustralia * Twitter @ClubMed_Au * Travel agent Facebook /ClubMedforTravelAgents Source = Club Medlast_img read more

Once Again Rebooting A LongStanding FCPA Proposal This Time In The Aftermath

first_img Learn More & Register Including the first time I proposed this concept in 2010, this is the seventh time I have written this general post (see here, here, here, here, here and here for the previous versions) and until things change I will keep writing it which means I will probably keep writing this same general post long into the future.The proposal is this: when a company voluntarily discloses an FCPA internal investigation to the DOJ and/or SEC and when one or both of the enforcement agencies do not bring an enforcement action, have the enforcement agency publicly state, in a thorough and transparent manner, the facts the company disclosed and why the enforcement agency did not bring an enforcement action based on those facts.As highlighted in this prior post, in October 2015 Millicom, a telecom and media company headquartered in Luxembourg with shares traded over the counter (OTC) in the U.S., disclosed:“Millicom … announced that it has reported to law enforcement authorities in the United States and Sweden potential improper payments made on behalf of the company’s joint venture in Guatemala. A Special Committee of the Board of Directors made the decision in connection with an independent investigation being overseen by the Special Committee and conducted by international law firm Covington & Burling LLP, with the support of Millicom’s management team. Millicom is committed to fully cooperating with the authorities. It is not possible at this time to predict the matter’s likely duration or outcome. Millicom is committed to the highest ethical business standards and to full compliance with all applicable laws and regulations in every market in which the company operates.”Earlier this week, the company disclosed:“In October 2015, Millicom voluntarily reported to the U.S. Department of Justice potential improper payments made on behalf of the company’s joint venture in Guatemala and, since then, has cooperated fully with the Justice Department’s investigation. Yesterday, the Justice Department informed Millicom that it is closing its investigation. Millicom is committed to the highest ethical business standards and to full compliance with all applicable laws and regulations in every market in which the company operates.”If the FCPA enforcement agencies are sincere about transparency in their FCPA enforcement programs as enforcement officials frequently mention, the public (not to mention Millicom shareholders who likely shelled out millions if this instance of FCPA scrutiny followed the typical path) have a right to know the facts the company disclosed and why the enforcement agency did not bring an enforcement action based on those facts. Here is why the proposal makes sense and is in the public interest.For starters (as I first wrote in 2010 and even more relevant today), the DOJ and the SEC are already wildly enthusiastic when it comes to talking about FCPA issues. Enforcement attorneys from both agencies are frequent participants on the FCPA conference circuit and there seems to be no other single law that is the focus of more DOJ or SEC speeches than the FCPA. Thus, there is clearly enthusiasm and ambition at both agencies when it comes to the FCPA.Further (as I first wrote in 2010 and even more relevant today), both the DOJ and the SEC have the resources to accomplish this task. Both agencies have touted the increased FCPA resources in their respective offices and the new personnel hired to focus on the FCPA. Combine enthusiasm and ambition with sufficient resources and personnel and the proposal certainly seems doable considering that there are likely less than 10 relevant examples per year.In addition, the DOJ is already used to this type of exercise. It is called the FCPA Opinion Procedure Release (see here), a process the DOJ frequently urges those subject to the FCPA to utilize. Under the Opinion Procedure regulations, an issuer or domestic concern subject to the FCPA can voluntarily disclose prospective business conduct to the DOJ which then has 30 days to respond to the request by issuing an opinion that states whether the prospective conduct would, for purposes of the DOJ’s present enforcement policy, violate the FCPA. The DOJ’s opinions are publicly released and the FCPA bar and the rest of FCPA Inc. study these opinions in advising clients largely because of the general lack of substantive FCPA case law.If the DOJ is able to issue an enforcement opinion as to voluntarily disclosed prospective conduct there seems to be no principled reason why the enforcement agencies could not issue a non-enforcement opinion as to voluntarily disclosed actual conduct. If the enforcement agencies are sincere about providing guidance on the FCPA, as they presumably are, such agency opinions would seem to provide an ideal platform to accomplish such a purpose.Requiring the enforcement agencies to disclose non-enforcement decisions after a voluntary disclosure could also inject some much needed discipline into the voluntary disclosure decision itself – a decision which seems to be reflexive in many instances any time facts suggest the FCPA may be implicated. For instance, Millicom’s initial disclosure refers to “potential improper payments.”Why a company would disclose “potential improper payments” is beyond me, but then again see this prior post for the important voluntary disclosure decision and the role of FCPA counsel. Or as stated by the DOJ’s former fraud section chief: “if you get two of these [FCPA investigations] a year as a partner, you’re pretty much set.” (See here).Notwithstanding the presence of significant conflicting incentives to do otherwise, it is hoped that FCPA counsel would advise clients to disclose only if a reasonably certain legal conclusion has been reached that the conduct at issue actually violates the FCPA. Accepting this assumption, transparency in FCPA enforcement would be enhanced if the public learned why the enforcement agencies, in the face of a voluntary disclosure, presumably disagreed with the company’s conclusion as informed by FCPA counsel. If the enforcement agencies agreed with the conclusion that the FCPA was violated, but decided not to bring an enforcement action, transparency in FCPA enforcement would similarly be enhanced if the public learned why.A final reason in support of the proposal is that it would give the disclosing companies (and others similarly situated) a benefit by contributing to the mix of public information about the FCPA.In most cases, companies spend millions of dollars investigating conduct that may implicate the FCPA and on the voluntary disclosure process. When the enforcement agencies do not bring an enforcement action, presumably because the FCPA was not violated, these costs are forever sunk and company shareholders can legitimately ask why the company just spent millions investigating and disclosing conduct that the DOJ and the SEC did not conclude violated the FCPA.However, if the enforcement agencies were required to publicly justify their decision not to bring an enforcement action after a voluntary disclosure, the company would achieve, however small, a return on its investment and contribute to the mix of public information about the FCPA – a law which the company will remain subject to long after its voluntary disclosure and long after the enforcement agencies no enforcement decision. Thus, the company, the company’s industry peers, and indeed all those subject to the FCPA would benefit by learning more about the DOJ and the SEC’s enforcement conclusions.Transparency, accountability, useful guidance, a return on investment.All would be accomplished by requiring the enforcement agencies to publicly justify a non-enforcement decision after a voluntary disclosure.All points to ponder … until the next time I write this same general post.center_img FCPA Institute – Boston (Oct. 3-4) A unique two-day learning experience ideal for a diverse group of professionals seeking to elevate their FCPA knowledge and practical skills through active learning. Learn more, spend less. CLE credit is available.last_img read more