allpay has a number of fundamental principles and values which it believes are the foundation of sound and fair business practise and as such are important to uphold. One such principle is a zero tolerance position in relation to corruption, wherever and in whatever form that may be encountered.

The Bribery Act 2010 was passed in April 2010 and is in force from 1 July 2011.  It is allpay’s policy to comply with all laws, rules and regulations governing anti bribery and corruption law;  allpay is required to keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

allpay’s Anti-Corruption Policy applies to individual employees, agents, sponsors, intermediaries, consultants or any other people or bodies associated with allpay. Bribery is committed when an inducement or reward is provided in order to gain any commercial, contractual, regulatory or personal advantage for allpay.

No bribes of any sort may be paid to or accepted from customers, suppliers, politicians, government advisors or representatives, private person or company. It is not permitted to establish accounts or internal budgets for the purpose of facilitating bribes or influencing transactions (slush funds).  This policy does not prohibit the following practices providing they are customary in a particular market, or are proportionate and properly recorded:

•  Normal and appropriate hospitality (given or received)
• The giving of a ceremonial gift on a festival or at another special time.

Our full policy and relevant guidance is communicated to employees across the Company through our established internal communication channels as well as promoting it on this website.

All employees receive appropriate training on how to implement this policy in the scope of their employment with allpay.  Ongoing monitoring and an implementation review is carried out by the  appointed Compliance Officer in association with the Board of Directors in respect of its suitability, adequacy and effectiveness.

allpay has established mechanisms to maintain accurate records which properly and fairly document all financial transactions. Internal control systems will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

This policy is endorsed by our Managing Director to demonstrate the Board’s commitment.

Tony Killeen

Managing Director