Anti-Bribery and Corruption Policy

1. Policy Statement

Paytia is committed to conducting business ethically and with integrity. We have a zero-tolerance approach to bribery and corruption in all forms. This policy applies to all employees, directors, contractors, consultants, and business partners acting on behalf of Paytia.

2. Scope

This policy applies to:

• All Paytia employees, regardless of location or position
• Directors and officers of Paytia
• Contractors, consultants, and temporary workers
• Business partners, suppliers, and third-party representatives
• Joint venture partners and subsidiaries

3. Definitions

Bribery

The offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal, unethical, or a breach of trust.

Corruption

The abuse of entrusted power for private gain, including acts of bribery, fraud, embezzlement, and money laundering.

Facilitation Payments

Small payments made to government officials to expedite routine administrative processes. These are prohibited under this policy.

4. Prohibited Activities

The following activities are strictly prohibited:

• Offering, promising, or giving bribes to any person or organization
• Accepting or soliciting bribes from any person or organization
• Making facilitation payments to government officials
• Engaging in any form of corruption or fraudulent activity
• Money laundering or handling proceeds of crime
• Failing to report suspected bribery or corruption

5. Gifts and Hospitality

Acceptable Gifts and Hospitality

Modest gifts and reasonable hospitality may be acceptable provided they:

• Are proportionate and reasonable in the circumstances
• Are not intended to influence business decisions
• Are transparent and properly recorded
• Comply with local laws and customs
• Would not cause embarrassment if disclosed publicly

Unacceptable Gifts and Hospitality

The following are never acceptable:

• Cash or cash equivalents
• Gifts or hospitality offered to government officials
• Excessive or lavish entertainment
• Gifts or hospitality that could influence business decisions
• Anything that violates local laws or regulations

6. Third-Party Relationships

Paytia conducts due diligence on all business partners, suppliers, and third-party representatives to ensure they:

• Share our commitment to anti-bribery and corruption
• Have appropriate policies and procedures in place
• Maintain good business reputations
• Comply with applicable laws and regulations

7. Red Flags

Be alert to potential warning signs of bribery or corruption, including:

• Requests for cash payments or unusual payment methods
• Reluctance to provide proper invoices or documentation
• Requests for payments to third parties or offshore accounts
• Unusually high commissions or fees
• Lack of transparency in business relationships
• Pressure to make urgent decisions without proper review

8. Reporting Procedures

All employees have a duty to report suspected bribery or corruption. Reports can be made:

• To your line manager or senior management
• To the Compliance Officer
• Through our confidential whistleblowing hotline
• Via email to compliance@paytia.com

All reports will be treated confidentially and investigated thoroughly. Paytia prohibits retaliation against anyone who reports suspected wrongdoing in good faith.

9. Training and Awareness

Paytia provides regular training on anti-bribery and corruption to ensure all employees understand:

• The requirements of this policy
• Relevant laws and regulations
• How to identify and report potential issues
• The consequences of non-compliance

10. Consequences of Non-Compliance

Violations of this policy may result in:

• Disciplinary action, up to and including termination
• Criminal prosecution
• Civil liability
• Damage to Paytia's reputation
• Termination of business relationships

11. Monitoring and Review

This policy is reviewed annually and updated as necessary to ensure it remains effective and compliant with current laws and best practices. The Compliance Officer monitors adherence to this policy and reports regularly to senior management and the board.

12. Contact Information

For questions about this policy or to report concerns, contact:

• Compliance Officer: compliance@paytia.com
• Whistleblowing Hotline: [To be established]
• General Inquiries: legal@paytia.com

This policy demonstrates Paytia's commitment to the highest standards of ethical business conduct and compliance with the UK Bribery Act 2010 and other applicable anti-corruption laws.