Paytia Limited Anti-Bribery and Corruption Policy
1. Introduction
Paytia Limited is committed to conducting business with integrity, transparency, and
accountability. This Anti-Bribery and Corruption Policy establishes our commitment to
compliance with the UK Bribery Act 2010 and other applicable laws and regulations. The
policy outlines our approach to preventing bribery and corruption and sets expectations for
employees, contractors, and business partners.
2. Purpose
The purpose of this policy is to:
• Ensure that Paytia Limited operates in a manner that upholds the highest ethical
standards.
• Define procedures to prevent, detect, and address bribery and corruption.
• Establish accountability and responsibility for compliance within the organisation.
• Promote awareness and training on anti-bribery measures.
3. Scope covered
This policy applies to all employees, directors, officers, contractors, consultants, suppliers,
and any third parties acting on behalf of Paytia Limited. It covers all business dealings and
transactions in the UK and internationally.
4. Anti-Bribery Officer
Craig Marston, Chief Technology Officer (CTO), has been appointed as the Anti-Bribery
Officer (ABO) for Paytia Limited. The ABO is responsible for:
Overseeing the implementation of this policy.
Ensuring compliance with anti-bribery laws and regulations.
Providing guidance and training to employees.
Investigating reports of bribery and corruption.
Reporting serious breaches to relevant authorities.
5. Definition of Bribery and Corruption
Bribery is the offering, giving, receiving, or soliciting of anything of value to influence an
official action or gain an improper advantage. Corruption is the abuse of entrusted power
for private gain. Examples include:
Offering or accepting cash, gifts, or hospitality in exchange for business advantages.
2 | P a g eMaking facilitation payments to expedite services.
Engaging in conflicts of interest that compromise business integrity.
6. Prohibited Conduct
Paytia Limited strictly prohibits:
The giving or receiving of bribes in any form.
Making facilitation payments to public officials.
Offering gifts, hospitality, or donations to influence business decisions.
Engaging in fraudulent accounting to conceal bribery.
Retaliation against whistle-blowers who report bribery concerns.
7. Gifts, Hospitality, and Donations
While business gifts and hospitality may be customary, they must:
Be reasonable, proportionate, and transparent.
Not create an obligation or expectation of preferential treatment.
Be recorded and reported to the Anti-Bribery Officer for approval if exceeding a set
threshold.
Donations to political parties or charitable organisations must not be used as a means to
gain an improper business advantage.
8. Due Diligence
Paytia Limited conducts due diligence on business partners, suppliers, and third parties to
mitigate bribery risks. This includes:
Assessing the integrity and compliance records of third parties.
Including anti-bribery clauses in contracts and agreements.
Conducting periodic reviews of high-risk partners.
9. Reporting and Whistleblowing
Employees and stakeholders are encouraged to report any concerns related to bribery and
corruption. Reports can be made confidentially to the Anti-Bribery Officer. Paytia Limited
ensures protection for whistle-blowers against retaliation.
3 | P a g e10. Training and Awareness
All employees receive mandatory training on anti-bribery laws and best practices. Training is
refreshed periodically to ensure continued compliance.
11. Consequences of Non-Compliance
Failure to comply with this policy may result in disciplinary action, including termination of
employment, contractual penalties, and potential legal action. Paytia Limited will cooperate
with regulatory authorities in any investigations.
12. Policy Review
This policy is reviewed annually to ensure its effectiveness and compliance with evolving
legal standards. Updates will be communicated to all employees and stakeholders.
Curtis Nash
CEO
Paytia Limited
05/01/2025
Any questions regarding the document contact@paytia.com