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Anti-Bribery & Corruption Policy

Effective Date: 8 May 2026 · Version 1.0

Vyete Technologies Ltd ("Vyete") maintains a zero-tolerance policy toward bribery and corruption in all its forms. This Policy applies to all Vyete employees, directors, contractors, agents, and platform partners acting on Vyete's behalf, and sets out the standards expected of all parties conducting business with or through Vyete.

1. Purpose and Scope

1.1 Purpose

This Policy is designed to:

  • Protect Vyete, its employees, and its platform participants from legal and reputational risks associated with bribery and corrupt practices.
  • Comply with applicable anti-bribery legislation, including the UK Bribery Act 2010 and equivalent legislation in jurisdictions where Vyete operates.
  • Create a culture of integrity in which all decisions are made fairly and on merit.

1.2 Scope

This Policy applies to:

  • All Vyete employees, directors, and officers worldwide.
  • All contractors, consultants, and temporary workers engaged by Vyete.
  • Agents and intermediaries acting on Vyete's behalf.
  • Platform partners, shops, and brands who are on notice of this Policy.

Platform participants who engage in bribery or corruption involving Vyete, Vyete employees, or other platform participants are in breach of their applicable terms and conditions.

2. What Is Bribery?

Bribery is the offering, promising, giving, accepting, or soliciting of a financial or other advantage as an inducement or reward for a person to act improperly in the performance of their function.

Corruption is a broader term covering bribery and also includes the misuse of entrusted power for private gain.

Both are illegal and a serious breach of this Policy.

3. Prohibited Conduct

The following are prohibited under this Policy at all times and in all circumstances:

  • Bribing a public official: Offering or giving anything of value to a government official, regulator, customs officer, or other public officer to obtain or retain business, secure a licence, or gain any other improper advantage.
  • Commercial bribery: Offering or giving anything of value to a private-sector employee or representative to obtain an improper advantage in commercial dealings.
  • Soliciting or accepting a bribe: Requesting or accepting anything of value (beyond permitted gifts — see Section 5) in return for acting or failing to act in a particular way in your role.
  • Facilitation payments: Small unofficial payments made to public officials to speed up routine government actions ("grease payments") are prohibited regardless of local practice or custom.
  • Third-party bribery: Arranging or authorising a third party (agent, partner, sub-contractor) to pay or receive a bribe on your behalf.
  • Kickbacks: Paying or receiving a payment from a supplier, partner, or contractor in exchange for directing business to them in breach of a duty of impartiality.

4. Risk Areas

The following areas carry elevated bribery risk and require heightened vigilance:

| Risk Area | Why It Matters | |---|---| | Government and regulatory approvals | Officials may seek unofficial payments in some jurisdictions | | Sales and new business development | Pressure to win contracts may create incentives for improper payments | | Procurement and supplier selection | Suppliers may offer inducements to influence selection | | Licensing and customs | Officials may solicit facilitation payments | | Charitable donations and sponsorships | May be misused as a vehicle for disguising bribes | | Acquisitions and joint ventures | Third-party conduct becomes a legal risk to Vyete |

5. Gifts, Hospitality, and Entertainment

Reasonable, transparent, and proportionate gifts and hospitality that serve a legitimate business purpose are permitted. The following standards apply:

5.1 Permitted

  • Branded promotional items of nominal value (below the equivalent of 25 local currency units).
  • Modest business meals in connection with a legitimate business meeting.
  • Hospitality (events, travel) that is openly given, reasonable in scale, and consistent with normal business practice.

5.2 Not Permitted

  • Cash or cash equivalents (gift cards, vouchers).
  • Any gift or hospitality given or received during active procurement, tender, or negotiation processes.
  • Lavish or disproportionate entertainment that could reasonably be seen as creating obligation.
  • Gifts given to a public official without prior approval from Vyete's legal team.
  • Any gift or hospitality given or received in secret.

5.3 Record-Keeping

All gifts and hospitality received or given above the equivalent of 50 local currency units must be recorded in the Vyete gifts register. Employees should request the register form from the legal team.

6. Political Contributions and Charitable Donations

  • Vyete does not make political contributions of any kind.
  • Charitable donations must be made only through Vyete's approved channels and must not be directed to charities designated by a third party as a condition of any commercial transaction.
  • Sponsorships of events involving government officials or public sector bodies require prior approval from the legal team.

7. Due Diligence on Third Parties

Before engaging agents, intermediaries, or representatives in high-risk markets or functions, Vyete conducts risk-appropriate due diligence, including:

  • Verification of business registration and ownership.
  • Screening against sanctions and anti-corruption watchlists.
  • Review of reputation and track record.
  • Contractual commitments to this Policy's standards.

Vyete will not engage a third party where it has reasonable grounds to believe that party will engage in bribery on Vyete's behalf.

8. Reporting Concerns

Vyete takes all reports of bribery or corruption seriously. If you know of, suspect, or have been offered a bribe in connection with Vyete's business:

  • Report confidentially: Contact [email protected] or use the anonymous reporting channel published on Vyete's internal intranet (for employees).
  • Platform participants: Report via [email protected] or the platform's general complaint form.
  • Do not feel pressured to comply: No employee or partner will be disadvantaged for refusing to participate in bribery or for making a good-faith report.

Vyete operates a strict non-retaliation policy. Any employee who suffers detriment for raising a genuine concern will have access to Vyete's grievance and escalation procedures.

9. Consequences of Breach

Violations of this Policy are treated with the utmost seriousness:

  • Employees: Breach may result in disciplinary action up to and including dismissal. Criminal referral may follow where conduct constitutes a criminal offence.
  • Contractors and agents: Breach will result in immediate termination of the engagement and, where appropriate, civil or criminal referral.
  • Platform partners (shops, brands, couriers): Account suspension and termination under the applicable terms, with potential referral to the relevant authorities.

Vyete itself may face criminal liability under applicable anti-bribery laws if it fails to prevent bribery by associated persons. Vyete will cooperate fully with any regulatory or law enforcement investigation.

10. Training

All Vyete employees in relevant roles receive anti-bribery training at induction and refresher training every two years. Employees in high-risk functions receive enhanced training.

11. Policy Review

This Policy is reviewed annually by Vyete's legal team and approved by the Board. Updates are communicated to all affected parties.

12. Contact

Bribery and integrity concerns: [email protected]

Legal and compliance: [email protected]