Overview
Payoup, operated by Enexfi LTD, is committed to conducting all business dealings ethically and with integrity. We have a zero-tolerance approach to bribery and corruption in any form. This policy is designed to support compliance with the UK Bribery Act 2010 and other applicable anti-bribery and corruption laws relevant to Payoup's operations.
The Bribery Act 2010 applies to all UK-registered companies regardless of size, and creates offences for both offering and accepting bribes, as well as a corporate offence of failing to prevent bribery. This policy sets out the standards we expect from everyone associated with Payoup.
Scope
This policy applies to:
- All directors, officers and employees of Enexfi LTD and Payoup
- All contractors, consultants and temporary workers engaged by the company
- Service providers (Payoup's suppliers/subcontractors) on the Payoup platform, who are bound by the relevant provisions of this policy within the scope of their contractual relationship with Payoup
- All third-party agents, intermediaries and business partners
- Any person or entity acting on behalf of or in association with Payoup
Key Definitions
For the purposes of this policy:
Bribery
Offering, giving, soliciting or receiving any financial or other advantage to induce or reward improper performance of a function or activity, or to influence a person in their official capacity.
Corruption
The abuse of entrusted power or position for private gain. This includes both direct and indirect forms, such as acting through intermediaries or third parties.
Facilitation Payment
A small unofficial payment made to secure or expedite a routine action by a government official or public body.
Prohibited Conduct
The following conduct is strictly prohibited for all persons covered by this policy:
- Offering, promising or giving a bribe to any person, whether in the public or private sector
- Requesting, agreeing to receive or accepting a bribe from any person
- Making payments or providing benefits to government officials to influence decisions or gain advantages
- Using platform features, accounts or funds to channel bribes or corrupt payments on behalf of third parties
- Engaging intermediaries, agents or freelancers for the purpose of making improper payments
- Threatening or retaliating against any person who refuses to participate in bribery or who reports a concern
Gifts & Hospitality
Gifts and hospitality can, in certain circumstances, amount to bribery. The following guidelines apply:
Acceptable
Modest gifts of low value given openly as a normal courtesy of business (e.g., branded merchandise, reasonable business meals). These must not be given with the intention of influencing a business decision.
Unacceptable
Cash or cash equivalents, lavish or extravagant entertainment, gifts given secretly, gifts given during an active tender or negotiation process, or anything that could reasonably be seen as intended to influence a decision.
Approval
Gifts or hospitality above a reasonable threshold defined by the company must be disclosed and approved by management. When in doubt, seek prior approval.
Facilitation Payments
Facilitation payments are illegal under the UK Bribery Act 2010, regardless of local customs or practices in other jurisdictions. Payoup strictly prohibits facilitation payments in any form. If you are asked to make such a payment, you must refuse and report the request immediately to the designated compliance contact.
Third Parties
Payoup may be held liable for acts of bribery committed by third parties acting on our behalf. We therefore require that:
- All third-party relationships are subject to appropriate due diligence before engagement
- Contracts with third parties include anti-bribery obligations and the right to terminate for breach
- Third parties are made aware of this policy and are expected to comply with its principles
- Any concerns about a third party's conduct are reported and investigated promptly
Reporting Concerns
All persons covered by this policy are encouraged to report any suspected bribery or corruption, or any situation that could give rise to such conduct:
How to Report
Reports can be made to the designated compliance contact via email at compliance@payoup.com. Reports may be made anonymously where permitted by law.
Protection
Payoup will not tolerate any form of retaliation against individuals who report concerns in good faith. Anyone who retaliates against a reporter will face disciplinary action.
Confidentiality
All reports are treated confidentially to the extent possible. Information will only be shared on a need-to-know basis for the purposes of investigating and addressing the concern.
Record Keeping
Payoup maintains accurate and transparent financial records to support our anti-bribery controls:
- All payments, expenses and financial transactions are recorded accurately and completely
- Gifts, hospitality and entertainment provided or received are logged and reviewed
- Records are retained for a minimum of 7 years and are available for audit purposes
Conflict of Interest
All employees, contractors and representatives must avoid situations where personal interests conflict, or appear to conflict, with Payoup's business interests. Any potential conflict must be disclosed to management and reviewed appropriately. This includes, but is not limited to, financial interests in competitors or business partners, personal relationships that may influence decision-making, and outside activities that could interfere with duties to Payoup.
Consequences
Breaches of this policy are treated extremely seriously. Consequences may include:
- Immediate termination of employment or engagement with Payoup
- Termination of platform access and forfeiture of account privileges
- Referral to relevant law enforcement authorities for criminal investigation
- Civil action to recover losses suffered as a result of the breach
Policy Updates
This policy is reviewed annually and updated as necessary to reflect changes in legislation, business practices or operational requirements. All persons covered by this policy will be notified of material changes.