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Anti-Bribery & Corruption Policy

1. Introduction 

This is the Anti-Bribery and Corruption Policy of Spot Payments Limited (“Spot Payments “ or “the firm”), which captures the firm’s internal procedures and controls to detect, prevent and deter bribery and corruption.


Spot Payments is committed to conducting business in an ethical manner and demonstrating the highest standard of integrity. Consequently, Spot Payments recognises the importance of espousing a strong culture of Anti-Bribery and Corruption through the firm and its employees, so as not to adversely affect the firm’s reputation, our customers and the sector in which we operate.

This policy outlines Spot Payments’ approach to preventing Anti-Bribery and Corruption by anyone associated with the firm. In developing this policy, the firm considered its legislative obligations under the Bribery Act 2010 and guidance issued by the Ministry of Justice. This policy has also been created using guidance issued by the Wolfsberg Group and the Financial Conduct Authority (FCA), specifically, the Financial Crime Guide. This policy is designed to ensure that no bribes or other corrupt payments, inducements or similar are made, offered, sought or obtained by us or anyone working on our behalf.

The responsibility of the implementation of this policy lies with the firm’s Board of Directors, as advised by senior persons responsible for the firm’s Financial Crime framework.  


1.1 Scope 

The policy applies to the following parties:

  • Full-time employees of Spot Payments. 

  • Part-time employees of Spot Payments.

  • Temporary contractors of Spot Payments. 

  • Individuals on work experience or interning at Spot Payments.

  • Agents of Spot Payments. 

  • All subsidiaries or branches of Spot Payments operating in the UK, European Economic Area (“EEA”) state, or any other third country.

Failure to comply may result in disciplinary action.


1.2 Objectives 

The objectives of the policy are to:

  • Emphasise Spot Payments’ zero-tolerance approach to Bribery and Corruption. 

  • Clearly, describe the systems and procedures that Spot Payments has in place for employees to report possible instances of bribery and corruption. 

  • Explain Spot Payments’ commitment to developing procedures and processes in accordance with the Ministry of Justice’s six principles for firms to prevent bribery. 

  • Outline how Spot Payments employees are trained to prevent Bribery or Corruption being facilitated by the firm. 

  • Summarise the most up-to-date Bribery and Corruption risks that Spot Payments is vulnerable to and how the firm intends to counteract these risks in accordance with our risk-based approach. 

  • Identify which individual within Spot Payments is responsible for maintaining and overseeing compliance with the policy. 


2. What is Bribery? 

Spot Payments takes the view that bribery, as defined by the Bribery Act 2010, is: ‘giving or receiving a financial or other advantage in connection with the improper performance of a position of trust, or a function that is expected to be performed impartially or in good faith.’ Furthermore, the FCA outlines bribery as ‘the offering or acceptance of an undue advantage in exchange for the improper performance of a function or activity.’

Monetary incentives and actual payments exchanging hands are not the only methods that constitute bribery. Bribery can take many forms, including gifts, lavish treatments during a business trip, tickets and/or hospitality at an event and promising favours.

There are many possible motives an individual or organisation may have for either accepting or offering a bribe. Some of the most common are as follows: 

  • Paying a bribe to secure or keep a contract (either within the private sector or government). 

  • Paying a bribe to secure an order. 

  • Paying a bribe to secure an advantage over a competitor. 

  • Accepting a bribe in return for facilitating an illegal activity (such as Money Laundering) for an individual.

The Bribery Act 2010 applies to all companies, regardless of size or nature, established under UK law and non-UK companies that conduct business in the UK. Spot Payments thus recognises that it is subject to the provisions of the act and liable to prosecution if the firm fails to implement adequate procedures and process to prevent bribery.

3. What is Corruption? 

Spot Payments takes the view that corruption, as defined by Transparency International, is: ‘the abuse of entrusted power for private gain. It can be classified as grand, petty and political, depending on the amounts of money lost and the sector where it occurs’. Corruption, per the FCA, is the abuse of public or private office to obtain an undue advantage. Corruption includes not only bribery but also other forms of misconduct or improper behaviour. This behaviour may or may not be induced by the prospect of obtaining an undue advantage from another person.

When it occurs within the private sector, corruption can distort competition, create cartels, enable regulated markets to be manipulated and illicitly influence the political decision-making process. This not only damages business and the sectors in which they operate, but also the interests of taxpayers. In some cases, within the private sector, corruption and bribery go hand-in-hand, especially when business pay bribes in order to win lucrative public contracts.

As a company that abides by the highest degree of ethical standards, Spot Payments is committed to the non-facilitation of corruption for the wrongful benefit of the business, any of its employees or representatives and any of our customers. 


4. Statement of Zero Tolerance to Bribery & Corruption 

Spot Payments does not tolerate bribery or corruption in any form. The scope of the firm’s zero-tolerance approach encapsulates all individuals listed in section 1.1 of this policy, including management and employees of the firm’s branches and subsidiaries. While the zero-tolerance approach does not completely prevent or protect the firm against corruption and/or bribery, the firm aims to implement the relevant controls and measures to mitigate bribery and corruption risk.

Under this policy, Spot Payments representatives are prohibited from offering, promising, requesting or receiving anything of value from another person if it would entail: 

  • Improperly performing their position so that it would benefit the person paying a bribe. 

  • Assisting to facilitate a crime with or on behalf of the person paying the bribe. 

  • Spot Payments improperly obtaining or retaining business or securing an advantage (whether it be from a private sector company or a public body/government). 

  • Leaking sensitive information to the public and/or Spot Payments’ competitors.

In the eyes of Spot Payments, such behaviour would constitute acts of bribery and corruption which are strictly forbidden by the firm.

Anything of value would include (but is not limited to) the following:

  • Cash.

  • Preferential Treatment.

  • Gifts and Entertainment.

  • Offers of Employment.

  • Political Donations.

  • Charitable Donations.

This policy does not prohibit the granting or receiving of gifts/hospitability as long as the following conditions apply: 

  • The gift is proportional. 

  • The gift is presented within the normal and expected course of the individual’s business.

  • The gift is not received/granted with the intention or understanding that you or the other party will improperly perform their function for a defined benefit. 

  • The gift is recorded in the firm’s gifts and hospitality register. 

  • Gifts that appear lavish/expensive are referred to the firm’s Responsible Officer for Anti-Bribery and Corruption before they are accepted. 


5. Responsibilities of Senior Management & Employees 

Spot Payments clearly defines the roles and responsibilities of all individuals with oversight of the firm’s Anti-Bribery and Corruption strategy and responsibility for the firm’s compliance with all Anti-Bribery and Corruption requirements. 


5.1 Responsible Officer

Spot Payments has appointed Charlie Pentol-Levy as the Responsible Officer for implementing, maintaining and monitoring compliance with this policy. Charlie Pentol-Levy assumed this responsibility on 01/01/2023 and is judged to be adequately skilled to hold the role by the firm’s senior management. The individual is responsible for: 

  • Implementing the procedures and processes outlined in this policy to prevent bribery and corruption. 

  • Taking ownership of the risk-based approach to Anti-Bribery and Corruption applied by the firm. 

  • Conducting a periodic risk assessment to identify any emerging risks to Bribery and Corruption the firm is facing or will face. 

  • Keeping up-to-date with legislative changes that impact the firm’s Anti-Bribery and Corruption strategy, as well as industry best practice issued by relevant bodies. 

  • Update Anti-Bribery and Corruption policies and procedures in accordance with any legislative changes or advancements in best practice. 

  • Monitor compliance with the policy throughout the firm. 

  • Maintaining a gifts and hospitality register for employees to register any gifts and/or hospitality that have accepted from other parties. 

  • Approving or rejecting the acceptance of any gifts or hospitality judged to be too expensive, lavish or out of proportion to the normal course of business. 

  • Regularly updating senior management on the effectiveness of the firm’s Anti-Bribery and Corruption strategy and making appropriate recommendations for improvement. 


5.2 Senior Management 

The senior management of Spot Payments fully endorses the firm’s Anti-Bribery and Corruption policy. The senior management body is responsible for: 

  • Ensuring that the firm conducts its business with integrity and tackles the risk that the firm, or anyone acting on its behalf, engages in bribery and corruption.

  • Developing and disseminating a corporate culture within the firm which helps prevent Bribery and Corruption. 

  • Retaining oversight of the firm’s Anti-Bribery and Corruption policy. 

  • Investing significant responsibility to the firm’s Responsible Officer for Anti-Bribery and Corruption to implement and maintain effective processes and policies. 

  • Allocate significant resources toward the firm’s Anti-Bribery and Corruption strategy so the firm complies with all current requirements. 

  • Being involved in the creation of Anti-Bribery and Corruption policies and procedures. 

  • Remaining up to date with, and staying fully abreast of, bribery and corruption issues.

  • Approving and periodically reviewing the strategies and policies for managing, monitoring and mitigating this risk.

  • Ensuring staff are aware of their interest in the prevention of bribery and corruption. 

To ensure there is a Anti-Bribery and Corruption culture, senior management is dedicated to leading by example, in complying with the firm’s ABC policies and procedures. 


5.3 Employees 

All Spot Payments employees are required to follow this policy and all Anti-Bribery and Corruption procedures. Spot Payments employees are also required to: 

  • Update the firm’s gifts and hospitality register when they receive a gift from a client or customer. 

  • Refer any gift which is construed as being too expensive, lavish and out of proportion to the normal course of their business to the Responsible Officer for the firm’s Anti-Bribery and Corruption policy. 

  • Attend regular training on Anti-Bribery and Corruption organised by the firm. 


6. UK Legislation

Spot Payments is fully aware of the UK’s legislative framework relating to Anti-Bribery and Corruption. Spot Payments also provides regular training to our employees, agents, and subsidiaries to ensure they have sufficient knowledge of the UK’s legislative framework.

Spot Payments is required to adhere to the following legislation, regulations, and guidance: 

  • Bribery Act 2010. 

  • FCA Financial Crime: A Guide for Firms. 

  • The Bribery Act 2010 – Guidance by Ministry of Justice.


 6.1 Offences 

The above legislation outlines multiple Anti-Bribery offences, which Spot Payments is committed to avoiding. The key offences under the applicable legislation are as follows: 

  • Bribing another person (Subject to a maximum 10-year jail term and/or a fine)

    • It is an offence to offer, promise or give a financial or other advantage to another person if the individual intends the advantage to bring about the improper function of another person or if the individual knows that the acceptance of the advantage offered itself constitutes the improper function. 

  • Accepting a bribe (Subject to a maximum 10-year jail term and/or a fine)

    • It is an offence to request, agree to receive or accept a financial or other advantage in return for an intended or already completed improper performance of an individual’s function. 

  • Bribing a foreign public official (Subject to a maximum 10-year jail term and/or a fine)

    • It is an offence to offer, promise or give financial or other advantages to a foreign public official with the intention of including the official in the performance of his or her official function. This is done in the hope of obtaining or retaining business or an advantage in the conduct of business. 

  • Failure to prevent bribery (Subject to conviction and an unlimited fine) 

    • It is an offence for an individual representing a firm to bribe another person to obtain and retain business or another advantage for the firm if the firm itself doesn’t have adequate procedures in place to prevent bribery from occurring. In this instance, the firm is liable for prosecution. 


7. Risk-Based Approach 

In line with the Ministry of Justice guidance on the Bribery Act 2010, Spot Payments has adopted a risk-based approach to bribery. The firm’s risk-based controls are designed to mitigate corruption risks associated with:

  • Engagement of third-party providers, including Intermediaries

  • Principal investments and controlled fund acquisitions/joint ventures

  • Giving Anything of Value: 

    • Gifts and hospitality (e.g., meals, entertainment, transportation, lodging, training and conferences)

    • Charitable giving and political contributions

    • Marketing sponsorships, and 

    • Employment and work experience (e.g., internships)


8. Six Principles 

Guidance issued by the Ministry of Justice (MoJ) on the Bribery Act 2010 details six principles that firms should consider when drafting their Anti-Bribery procedures. These principles are not prescriptive and, as recommended by MoJ, should be incorporated by Spot Payments in accordance with the size and nature of the business in accordance with our risk-based approach. 

The MoJ’s six principles are listed below: 

  • Proportionate Procedures. 

  • Top-Level Commitment. 

  • Risk Assessment. 

  • Due Diligence. 

  • Communication (including training).

  • Monitoring and Review. 


8.1 Proportionate Procedures 

Spot Payments implements procedures which are proportionate to the identified specific bribery risks faced by the firm. As such, these procedures are also proportionate to the nature and size of the firm. 

The procedures that Spot Payments have designed cover the following areas: 

  • Receiving gifts and hospitality from clients. 

  • Procuring government contracts. 

  • Obtaining and retaining business from clients. 


8.2 Top-Level Commitment 

The senior management of Spot Payments recognises how important it is to be personally involved in fostering a culture where bribery and corruption, in any form, is viewed as wholly unacceptable. Senior management relishes its responsibility to set a personal example to everyone associated with Spot Payments so that they always act with the utmost integrity in the course of their business and do not succumb to bribery.

Spot Payments’ senior management pledges to be appropriately involved in the following areas of the firm’s anti-bribery strategy: 

  • Making key decisions relating to the firm’s bribery risk. 

  • Communication of the firm’s anti-bribery stance. 

  • Developing the firm’s anti-bribery procedures. 


8.3 Risk Assessment

Spot Payments acknowledges the importance of assessing the nature and extent of its exposure to potential internal and external risks of bribery. The firm’s Responsible Officer for the Anti-Bribery and Corruption strategy will conduct a risk assessment periodically to identify and assess any evolving risks that the firm is vulnerable to. This risk assessment will be contained within the firm’s Financial Crime Risk Assessment.

The risks considered are associated with the products and/or services the firm offers, all customers and jurisdictions that the firm does business with, all delivery channels used by the firm, the firm’s exposures to public officials and public office holders, and the firm’s own business practices i.e., the firm’s approach to providing corporate hospitality, charitable and political donations and the firm’s use of third parties.  

The risk assessment further addresses the risk of staff or third parties acting on behalf of the firm, offering or receiving bribes. The risk assessment will be regularly reviewed and updated to ensure that all real and emerging risks are accounted for. Additionally, the risk assessment will be documented and be utilised to inform Spot Payments’ policies and procedures relations to Anti-Bribery and Corruption.

Spot Payments will periodically assess the nature and extent of the firm’s risk of bribery and corruption. Further to the above, when conducting a risk assessment, the firm will take the following factors into account: 

  • The firm’s relationship with law enforcement, regulatory bodies and trade organisations. 

  • The firm’s relationship with customers and third parties. 

  • The firm’s relationship with third-party providers of products and services we use. 

  • The firm’s tender process for public and private contracts. 

  • The firm’s delivery channels and how we engage with customers and clients. 

  • Internal relationships between staff. 

  • The geographical regions and jurisdictions in which the firm operates. 

  • The frequency with which the firm pursues private sector and public contacts. 

  • The jurisdictions in which the firm’s customers are based. 

  • The sectors with which the firm engages.

  • Business partnership risks, including the use of intermediaries in transactions with foreign public officials and relationship with Politically Exposed Persons (“PEP”).


The key identified bribery and corruption risks to Spot Payments, as verified in the firm’s last Financial Crime Risk Assessment, are as follows: 

  • Bonus culture which rewards risk-taking.

  • Changes in business activities.

  • Charitable / Political donations.

  • Corporate hospitality. 

  • Expenses not being registered.

  • Bribery of Human Resources (HR)

  • Political connections. 

  • Security (including information security).

  • Third-parties / Outsourcers.

  • Whistleblowing and complaints log. 


Following any risk assessment, Spot Payments’ Responsible Officer will review and recommended changes to the firm’s Anti-Bribery and Corruption procedures and controls to mitigate the identified risks. Once these recommendations have been signed-off by the firm’s senior management, the firm’s policies, procedures, and controls will be subsequently updated.

The Responsible Officer has been identified as the person in charge of ensuring that the Bribery and Corruption risk assessment remains up to date. As part of the firm’s senior management team, the Responsible Officer has been judged has having the appropriate level of expertise and seniority to complete this duty. 


8.4 Due Diligence 

Spot Payments will apply due diligence measures to mitigate bribery risks in accordance with the firm’s risk-based approach. Due diligence is a key measure to mitigate the risk of individuals within the firm being bribed or individuals issuing bribes on the firm’s behalf. Spot Payments’ procedures are informed from the firm’s periodic risk assessment.

In accordance with the risk assessment, Spot Payments will conduct bribery-related due diligence on the following persons: 

  • Intermediaries. 

  • Contractors. 

  • Business relationships. 

  • Customers (when a high-risk of bribery is identified).

The level of due diligence conducted on each person will depend on their respective risk levels. In circumstances where the is a very low risk of bribery identified, Spot Payments will apply the following measures: 

  • Identification and verification of persons. 

  • Scrutiny of the intended nature of the business relationships. 

  • Adverse media check

In situations where the risk of bribery is considered to be high risk, Spot Payments will apply the following due diligence measures: 

  • Direct interrogative enquiries. 

  • Indirect investigations. 

  • Research on persons involved. 


8.5 Communication (including training) 

Spot Payments seeks to ensure that its bribery prevention policies and procedures are embedded and understood throughout the firm, including through the use of training. Through the firm’s communication plan, Spot Payments is enhancing awareness and understanding of the firm’s procedures and a zero-tolerance approach to bribery and corruption.

The firm communicates policies, procedures and its approach to relevant internal and external parties associated with Spot Payments in numerous ways. See below for a summary of our communication methods: 

  • Uploading our Anti-Bribery and Corruption policy onto the firm’s website. 

  • Uploading our policy and procedures onto the firm’s intranet site. 

  • Providing the firm’s employees with the location of the Anti-Bribery and Corruption policy and procedures on the firm’s internal server.

  • Informing potential business partners of the firm’s Anti-Bribery and Corruption policy at the point of contact. 


Training is provided to all employees and agents during their induction to Spot Payments and at regular intervals during the course of their association with the firm. The firm’s training programme covers the following areas: 

  • Zero-tolerance approach to bribery.

  • An overview of anti-bribery legislation.

  • An overview of key bribery risks.

  • Examples of how those risks may occur within the business.

  • Employee’s obligations and responsibilities to report suspected bribery.

  • Details on how to make such a report.


8.6 Monitoring and Review 

It is important that Spot Payments continually monitors the effectiveness of its Anti-Bribery and Corruption policies and procedures and implements a function to review and update them where necessary. The bribery risk that the firm is subject to may change over time, so Spot Payments’ monitoring and review plan has been put in place to mitigate the risks as soon as practicable after they are identified.

Spot Payments has the following measures in place to monitor the effectiveness of its strategy: 

  • Conducting periodic risk assessments to identify areas of vulnerability and update controls accordingly.

  • Ongoing training and awareness programs for employees to reinforce the importance of compliance.

  • Regular reviews of third-party relationships and due diligence checks to ensure compliance with anti-bribery and corruption policies.

  • Analysis of bribery and corruption trends and incidents to identify potential areas of improvement in the firm's policies and procedures.


9. Firm Requirements

Spot Payments is aware of its obligations to prevent the firm being used to facilitate bribery and corruption. As well as adapting its Anti-Bribery & Corruption policies and procedures along the lines of the six principles as part of the firm’s risk-based approach, Spot Payments is also required to implement other measures to mitigate the risk of bribery. These include:


9.1 Pre-employment Screening

During Spot Payments’ recruitment process, the firm will undertake pre-employment screening of potential candidates. In doing this, Spot Payments will affirm each candidate’s qualifications, suitability, and experience for the specified role. During the screening process, the firm will obtain and retrieve information that will help us assess whether a potential candidate is likely to engage in bribery or corruption. The screening process will help reduce the likelihood that an individual with a history of bribery and unethical behaviour will be offered a role within the firm.

The firm’s pre-employment screening techniques include: 

  • Confirming the education and professional qualifications of the candidate. 

  • Verification of the candidate’s employment background. 

  • Criminal history searches. 

  • Credit checks.

Only once Spot Payments is satisfied that a potential candidate doesn’t pose any inherent bribery and corruption risks will he/she be offered a position in the firm. 


9.2 Stress Testing 

Spot Payments’ systems and controls should be subject to periodic ‘stress tests’ to ascertain the strengths and weaknesses of the firm’s Anti-Bribery and Corruption systems and controls. The firm has in place methods for testing the stability of our systems and controls to uncover any deficiencies and areas for further improvement. Once deficiencies have been identified, the firm will promptly address them. 


9.3 Due Diligence 

Due diligence is an important method for ascertaining whether an individual associated with the firm or business partners/clients pose a bribery and corruption risk. Spot Payments has due diligence procedures in place to mitigate these risks. The firm’s approach to bribery and corruption due diligence can be observed in section 8.4. 


9.4 Record Keeping 

Spot Payments is required to maintain adequate records as part of our Anti-Bribery & Corruption procedures. The records that the firm is required to maintain include: 

  • The client’s identity. 

  • The supporting evidence of verification of identity. 

  • The firm’s business relationship with them. 

  • Details of any occasional transactions. 

  • Details of monitoring of the relationship.

Spot Payments will retain these records for a minimum of five years after the termination of the business relationship with each customer, except for situations where legal obligations placed upon Spot Payments require otherwise.


10. Financial Reporting and Management Information

Financial Reporting

Spot Payments strives to have accurate financial reporting, and as such, does not permit any improper accounting or the concealment of financial activity. All employees share responsibility for accurately reporting anything of value provided to existing and potential customers, public officials and payments made to third parties. The firm also maintains documentation for anything of value provided by existing or potential customers, public officials and third parties.

Anything of value provided to, or received by the customer will be logged and will need to first receive approval from the relevant persons. This ensures that there is complete transparency regarding gifts and hospitality. 


Management Information  

Management information is periodically provided to the firm’s board, regarding existing and emerging bribery and corruption risks that the firm is vulnerable to. This will include compiled data used to assist the board and senior management in assessing the effectiveness of their internal controls and overall ABC framework. The management information submitted to the board will ensure that the board is adequately informed of all bribery and corruption risks, whether they are internal or external, allowing there to be a swift and effective response. Reporting will be done as part of the firm’s overall reporting on financial crime.

Senior management receives and analyses information / data about bribery and corruption which include:

  • Status updates on the ABC framework, including key performance indicators/metrics

  • Major deviations from the internal policies and procedures by employees (i.e. on gifts and business hospitality)

  • Relevant legal and regulatory developments 

  • Updates on any internal reviews of the ABC framework (e.g. audits, compliance testing) 

  • Any other significant issues such as regulatory reporting or filings in relation to bribery and corruption committed by officers, employees or third-party providers 


11. Training 

Spot Payments’ employees and agents are provided with Anti-Bribery & Corruption training upon their induction to the firm. Employees and agents are also provided with annual training/refresher training by the firm. Employees are trained in all areas detailed in section 8.5 of this policy.

Employee training records are to be retained and evidenced on each individual employee’s Continual Professional Development (“CPD”) Log alongside the firms central training log. Records are required to be retained for five years.


12. Suspicious Activity 

All employees and agents at Spot Payments, regardless of position, have a responsibility to report incidents or suspicions of bribery. Possible cases of bribery, when they go unreported, may bring the firm and the sector in which it operates into disrepute. As such, it is important that any individual associated with Spot Payments who are in a position to detect bribery follow the firm’s procedures for reporting bribery. 

Spot Payments provides training to all employees on how to identify suspicious activity related to bribery and steps they must undertake to report it. 


Should an employee have a suspicion of bribery, the employee should inform their line manager who will notify the firm’s Responsible Officer.

The Responsible Officer will need to make a judgement on whether the gift being offered is reasonable and proportionate. Should they deem the gift to be a bribe, the Serious Fraud Office (SFO) and Financial Conduct Authority (FCA) should be made aware of the suspicion.

Examples of suspicious activity include (but not limited to) the following: 

  • Third Parties or Agents who are deemed valuable for their Personal Ties rather than for their Services, or who request compensation out of proportion to the value of their services.

  • Client requests for favours, such as Job Interviews for family members. 

  • Requests to engage Third Parties without a written contract.

  • Client requests for favours, such as Job Interviews for family members. 

  • Gifts or Hospitality that could be lavish or inappropriate.

  • Conditional requests for Donations to Charities or Political Parties.

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