1.What does this policy cover?

1.1 This anti-bribery policy exists to set out the responsibilities of SpeedPay Finance Nigeria Limited (hereinafter Speedpay) and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.

1.2 It also exists to act as a source of information and guidance for those working for SpeedPay. It helps them recognize and deal with bribery and corruption issues, as well as understand their responsibilities.

1.3 It sets out the Company’s policies and procedures aimed at preventing acts of bribery and corruption and has been designed in compliance with domestic legislation governing bribery and corruption, including:

SpeedPay recognizes that bribery and corruption are punishable by at least seven years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.

The Money Laundering (Prevention and Prohibition) Act 2022

The Terrorism (Prevention and Prohibition) Act, (TPPA) 2022; and

The Proceeds of Crime (Recovery and Management) Act, 2022.

2.Policy statement

2.1. SpeedPay is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. SpeedPay has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

2.2. SpeedPay will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the Nigeria, in regards to our conduct both at home and abroad.

2.2. SpeedPay recognizes that bribery and corruption are punishable by at least seven years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.