Anti-Bribery and Corruption Policy

Anti-Bribery & Anti-Corruption, Third-Party Entertainment and Gifts Policy

1. Purpose and Scope

To ensure all employees, directors, officers, contractors and consultants are aware of certain types of activities which may constitute corruption, a bribe or an act of bribery and are aware that any such activities are prohibited. Ultrafair Limited ("UF", “we,” “us,” or “our”) takes a “zero tolerance” approach to acts of bribery and corruption.

"Bribery" means knowingly giving or receiving, or agreeing to give or receive, an undue reward, whether financial or non-financial, to influence the behaviour of someone in government or business either in their personal or official capacity, to obtain commercial advantage. Examples include giving improper payments or benefits to Players or paying secret commissions to an agent. A bribe does not have to be actually given – the intent to give a bribe is sufficient to be deemed a bribe.

Bribery includes indirect bribery, which occurs where a third party, whether an individual or an organisation, commits an act of bribery when acting on UFs behalf. Examples of third parties include agents, distributors, service providers, joint venture partners, and anyone acting in a fiduciary capacity.

"Corruption" is the willingness to act dishonestly in return for money or personal gain.

2. Why is this Important?

As part of UF's commitment to high ethical standards we must demonstrate care that our actions do not put UF, or business partners of UF, in breach of any applicable laws or generally accepted ethical standards.

Many countries have or are in the process of implementing legislation that aims to prevent Bribery and Corruption. The penalties for failing to comply with these laws are significant and can affect UF and its staff and Players. The consequences can include:

  • Serious civil and criminal penalties including fines for UF;

  • individual liability for employees and executives (including fines); and

  • operational costs and reputational damage.

3. What are General Guidelines of this Policy?

All acts of Bribery and Corruption are strictly prohibited. This includes payments made on behalf of UF by a third party.

Government authorities can prosecute companies and individuals for actions that occur anywhere in the world through various laws, including but not limited to the UK Bribery Act 2010, the US Foreign Corrupt Practices Act and Anti-Kickback Statute. This means all employees and other persons engaged by UF must be vigilant about ensuring that no acts of Bribery or Corruption occur, in any part of the business, in any part of the world.

UF is liable for the actions of employees and others engaged by the company who act or are perceived to act on behalf of the company. You must therefore be alert to any suspicious behaviour or events and report them immediately to the Chief Compliance Officer.


Seek approval from the Chief Compliance Officer before engaging on behalf of UF with government officials regarding political activities, unless such engagement is expressly required by your role.

Never use your position in UF to try to influence any other person (inside or outside UF) to make political contributions or provide support to any political parties or politicians.

Keep in mind UF's reputation, and how the public would perceive your actions, when accepting gifts, or engaging with government officials.

Don’t differentiate between the giving or receiving of gifts and hospitality directly or via an intermediary.

Inform the Chief Compliance Officer immediately if you suspect any Bribery or Corruption may be occurring (for example: third parties requesting any form of payment separate from the official UF invoice etc).

Don’t use or allow the use of any UF assets or resources (for example: work time, telephones, communications services, or meeting rooms for any services outside of the services offered by UF).

Inform the Chief Compliance Officer of any requests from customers to alter invoices (i.e. requests for deflated invoices for customs purposes).

4. What are the Guidelines for Charitable and Political Contributions?

Charitable contributions may be made on behalf of UF subject to the appropriate approval and only for bona fide charitable purposes i.e. for which no tangible benefit is received or is expected to be received by UF. Political contributions of any nature are strictly prohibited.

5. What are the Guidelines for Meals, Entertainment and Gifts?

Meals, Entertainment and Gifts received by UF employees and provided by UF to third parties must be within generally accepted ethical standards and in compliance with applicable laws.

5.1. General

All entertainment, gifts and meals either received by UF or provided to third parties must be reasonable in value, non-extravagant, and linked to a business purpose. Receiving or providing meals, entertainment, and/or gifts to advance a potential business transaction or regulatory approval is prohibited.

Before accepting or giving any gift or entertainment, employees and people engaged by UF should ask themselves the following questions to determine whether the gift or entertainment is appropriate:

5.1.1. Intent – Is the intent only to build a business relationship or offer normal courtesy, or is it to influence my (or the other party’s) objectivity in making a business decision? If it is to influence objectivity in making a business decision, it should not be provided or accepted.

5.1.2. Materiality and frequency – Is the gift or entertainment modest and of a reasonable frequency in light of the nature of the relationship? If no, the gift or entertainment should not be provided or accepted.

5.1.3. Legality – Am I sure that the gift or entertainment is legal both in my country and in the country of the associated party? If unsure, have I consulted the Chief Compliance Officer to help make an informed decision? If no, the gift or entertainment should not be provided or accepted.

5.1.4. Compliance with the other person’s rules – Does the recipient’s organisation allow the recipient to receive the gift or entertainment? If no, the gift or entertainment should not be provided.

5.1.5. Transparency – Would I be happy explaining my behaviour to my manager, colleagues, or anyone outside UF without any embarrassment? If not, do not engage in that conduct.

5.1.6. Hypocrisy – Am I adopting double standards? I should only offer what I would be comfortable to accept (and vice versa).

5.2. Government Officials

Government Officials are highly regulated in their work environment and it is the view of UF to not accept nor provide any gifts or entertainment.

5.3. Compliance with Local Laws

UF employees are responsible for complying with all rules, regulations, and laws of the jurisdictions in which they conduct business and are encouraged to confer with the Chief Compliance Officer for guidance.

5.4. Gifts

UF employees must never give or accept gifts valued over the values outlined without the express permission of the Chief Compliance Officer, and then only with the full knowledge of the customer or business associate’s principals.

UF will only reimburse expenses relating to entertainment or gifts that are appropriately claimed with receipts. UF retains the right to seek confirmation from the customer or business associate as to the nature, extent and benefit received following a claim for reimbursement of entertainment or a gift.

6. Reporting

If you think you are aware of a potentially unethical activity, have a doubt about a certain incident, or are uncertain whether something could be construed as a bribe, you should contact the Chief Compliance Officer for guidance.

7. Ongoing Training

UF will provide an online training course on Anti-Bribery and Anti-Corruption and must be completed by all employees, directors (executive and non-executive) and officers within 90 (ninety) days of their commencement with UF. In addition, from time to time, mandatory face-to-face training will be delivered to employees most likely to be exposed to Bribery and Corruption about how to recognise and deal with it.

8. Periodic Review of Policy

This Policy will be periodically reviewed to ensure it is operating effectively and remains up to date with relevant information. If there are any material changes to the Policy, it will be implemented by the Chief Compliance Officer and approved by the Board of Directors.

9. Material Breach of Policy

Any material breach of this Policy will be communicated to the authorised individual.

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