Anti-Bribery & Corruption
1. Policy Statement
Trust is everything in our line of work. When contact centres rely on Paytia to handle their customers' card payments securely, they need to know we're running a clean operation — in every sense. We won't tolerate bribery or corruption in any form, full stop.
This policy applies to everyone who works for or with Paytia: employees, directors, contractors, consultants, and business partners. It's grounded in the UK Bribery Act 2010, but our standards go beyond mere legal compliance.
Global applicability
This policy applies to all Paytia operations worldwide, including our US entities and any customer we serve outside the UK. We treat bribery and corruption the same way wherever our people work or our platform is used.
Alongside the UK Bribery Act 2010, we hold ourselves to the US Foreign Corrupt Practices Act (FCPA, 15 USC §78dd-1 et seq.) and the OECD Anti-Bribery Convention. Where local anti-corruption law is stricter than these, we follow the stricter standard. Where it's weaker, we still hold the line described in this policy. Local law adds to our commitments; it never reduces them.
Every member of staff receives the same anti-bribery training regardless of country, and the gift, hospitality, facilitation payment, and due diligence rules that follow apply globally. If you're acting on behalf of Paytia anywhere in the world, these are the standards you're working to.
2. Scope
If you're connected to Paytia in any working capacity, this policy covers you:
- Every Paytia employee, whatever your role or location
- Directors and officers
- Contractors, consultants, and temporary staff
- Business partners, suppliers, and anyone representing us to third parties
- Joint venture partners and subsidiaries
3. Definitions
Bribery
In plain terms, bribery is offering, promising, or giving someone something of value to get them to act improperly — or accepting such an inducement yourself. It doesn't have to be cash. It could be a favour, a gift, or a business opportunity.
Corruption
Corruption is the misuse of a position of trust for personal gain. Bribery is one form, but it also covers fraud, embezzlement, and money laundering.
Facilitation Payments
These are the small unofficial payments sometimes made to speed up routine government processes. They're illegal under UK law, and we prohibit them entirely.
4. What's Prohibited
To be absolutely clear, the following are off limits:
- Offering, promising, or giving a bribe to anyone — no exceptions
- Accepting or asking for a bribe, regardless of the amount
- Making facilitation payments to government officials
- Any form of corrupt or fraudulent activity
- Handling money or assets that you know or suspect are proceeds of crime
- Staying quiet if you suspect bribery or corruption is happening
5. Gifts and Hospitality
What's Generally Acceptable
Business relationships involve the occasional coffee, working lunch, or modest gift. That's fine, as long as it:
- Is reasonable and proportionate — use common sense
- Isn't intended to sway a business decision
- Is properly recorded and transparent
- Complies with local laws
- Wouldn't embarrass you or Paytia if it appeared in the press
What's Never Acceptable
Some things are always off the table:
- Cash or cash equivalents (vouchers, gift cards, etc.)
- Gifts or hospitality directed at government officials
- Lavish entertainment or anything obviously excessive
- Anything designed to influence a decision in our favour
- Anything that breaks local laws or regulations
6. Third-Party Relationships
We're careful about who we work with. As a PCI DSS Level 1 certified payment platform, we already run extensive due diligence on our technology partners. We apply the same rigour to anti-bribery and corruption, checking that partners and suppliers:
- Share our commitment to honest business practices
- Have their own anti-corruption policies in place
- Carry a solid business reputation
- Comply with relevant laws and regulations
7. Red Flags
Trust your instincts. If something feels wrong, it probably is. Watch out for:
- Requests for cash payments or unusual payment routes
- Reluctance to provide invoices or proper paperwork
- Requests to pay a third party or route money through an offshore account
- Commissions or fees that seem disproportionately high
- A lack of transparency about who you're actually dealing with
- Pressure to make snap decisions without proper review
8. How to Report
If you suspect bribery or corruption, you have a duty to speak up. There are several ways to do it:
- Talk to your line manager or a member of senior management
- Contact the Compliance Officer directly
- Use our confidential whistleblowing procedure
- Email compliance@paytia.com
Every report is treated confidentially and investigated properly. We don't tolerate retaliation against anyone who raises a genuine concern — that's a firm commitment.
9. Training
We run regular anti-bribery and corruption training so everyone at Paytia knows:
- What this policy requires in practice
- The key laws — particularly the UK Bribery Act 2010
- How to recognise and flag potential issues
- What happens if the policy is breached
10. Consequences
We take breaches seriously. Depending on the circumstances, a violation could lead to:
- Disciplinary action, up to and including dismissal
- Criminal prosecution — bribery carries up to 10 years in prison under UK law
- Personal civil liability
- Serious reputational damage to Paytia and the people involved
- Termination of business relationships with the parties concerned
11. Monitoring and Review
We review this policy every year and update it when needed. Our Compliance Officer keeps an eye on how well it's working day to day and reports regularly to senior management and the Board. As our business grows — and it is growing — our anti-corruption controls evolve with it.
12. Contact
Got a question about this policy, or need to raise a concern?
- Compliance Officer: compliance@paytia.com
- General Enquiries: info@paytia.com
This policy reflects Paytia's commitment to ethical business conduct and full compliance with the UK Bribery Act 2010.
Related policies: Anti-Tax Evasion Policy and Modern Slavery Statement.