Anti-Bribery & Corruption Policy

1. Our commitment

PPay has zero tolerance for bribery and corruption in any form. We will not, directly or indirectly, offer, promise, give, solicit, or accept any bribe, kickback, or other improper advantage in order to obtain or retain business, or to secure any improper advantage, in our dealings with customers, partners, regulators, government officials, or any other party.

2. What is prohibited

PPay strictly prohibits:

• —Offering, promising, or giving any bribe, gift, or other advantage to any person — including public officials, regulators, bank partners, or customers — to improperly influence a decision or business outcome.
• —Soliciting or accepting any bribe or improper advantage from customers, vendors, partners, or any other party in connection with PPay's business.
• —Making facilitation payments (small payments to speed up a routine government action) in any jurisdiction where this is unlawful.
• —Using PPay's products or services to facilitate bribery or corruption by customers or third parties — this is treated the same way PPay treats other prohibited activity such as fraud, money laundering, or sanctions violations, and may result in transaction refusal, account restriction, or reporting to the relevant authorities.
• —Falsifying or concealing information in PPay's books, records, or accounts to disguise any improper payment.

3. Interactions with public officials

Because PPay interacts with government and regulatory bodies — including the Central Bank of Nigeria (CBN), the Corporate Affairs Commission (CAC), and its anchor bank — in the course of licensing, registration, and compliance activity, PPay applies enhanced care to any interaction involving a public official. This includes:

• —No facilitation payments, gifts, or informal payments to any government official, regulator, or agency staff to speed up, expedite, or secure any licence, registration, approval, filing, or inspection outcome — including small or “customary” payments.
• —Any gift, hospitality, meal, or contribution offered to or received from a public official, regulator, or their close associates requires prior approval from PPay's designated compliance contact, regardless of value.
• —All engagement with regulators and government agencies (e.g. CBN, CAC, NDPC, anchor bank) must go through PPay's designated representative(s) and be conducted transparently, on the record, and through official channels.
• —PPay keeps a basic record of significant interactions with public officials — who was involved, the purpose, and any gift, hospitality, or payment exchanged — for as long as the company retains compliance records generally.
• —Any request from a public official for a payment, gift, or favour outside normal, transparent channels must be refused and reported immediately to PPay's designated compliance contact.

4. Gifts, hospitality & political/charitable contributions

Modest, reasonable, and transparent gifts or hospitality exchanged in the normal course of business are not prohibited, provided they are not intended to improperly influence a business decision and are proportionate to the occasion. Political donations and charitable contributions made on PPay's behalf must be transparent, properly recorded, and must never be used to disguise or facilitate a bribe.

See “Interactions with public officials” above for the additional approval requirement where a public official is involved.

5. Third parties

PPay expects the same standard of integrity from any third party acting on its behalf — including compliance, verification, and technology partners — as it holds itself to. PPay will not knowingly engage a third party to do indirectly what PPay is prohibited from doing directly.

6. Reporting concerns

Anyone who becomes aware of, or suspects, a breach of this Policy — whether by a staff member, partner, or customer — is encouraged to report it promptly to PPay's designated compliance contact. Reports will be treated seriously and, where appropriate, escalated for investigation. PPay will not tolerate retaliation against anyone who raises a genuine concern in good faith.

7. Oversight & review

As a newly incorporated company, PPay's Founder & Director currently holds responsibility for oversight of this Policy, including approvals related to public officials. As the team grows, PPay will designate additional compliance oversight and provide ABC awareness to staff and contractors as part of onboarding. This Policy will be reviewed periodically and updated to reflect PPay's growth and any changes in applicable law.

8. Consequences of breach

Breach of this Policy by a staff member or contractor may result in disciplinary action up to and including termination. Breach by a customer or partner may result in transaction refusal, account restriction or closure, and reporting to the relevant regulatory or law enforcement authorities, consistent with PPay's AML, CTF & Sanctions Policy.