ZYC-ABC-001 Anti-Bribery & Corruption (ABC) Policy
(Applies to all Zeyro staff, directors, contractors, and consultants — Updated October 2025)
Background
Zeyro is authorised by the FCA and must comply with the Bribery Act 2010, FCA SYSC 3.2.6R (systems and controls) and Principle 1 – Integrity. We maintain zero tolerance for bribery, corruption, facilitation payments, or any activity that could influence decision-making improperly. This policy supports our culture of transparency and fair dealing.
Purpose
This policy ensures that:
No person associated with Zeyro offers, gives, requests, or accepts a bribe.
All corporate hospitality, gifts, and payments are legitimate, proportionate, and approved.
Zeyro can demonstrate adequate procedures to prevent bribery under section 7 of the Bribery Act 2010.
Scope
Applies to:
All employees, contractors, directors, and anyone acting on Zeyro’s behalf.
All jurisdictions in which Zeyro operates or has clients.
All business interactions — including with clients, introducers, regulators, and service providers.
Key Rules
1. No Bribes or Improper Payments
Never offer, give, or receive anything of value to improperly influence a business decision.
Facilitation payments (small unofficial payments to speed up routine actions) are strictly prohibited, even where customary overseas.
We do not make or accept referral fees or commissions.
How this controls our risks: Prevents financial crime, improper inducements, and reputational damage.
2. Gifts and Hospitality
Gifts and hospitality must be reasonable, proportionate, and clearly business-related.
Generally acceptable: modest working lunches, coffee, pens, or low-value items under £50.
Not acceptable: cash, cash equivalents (gift cards, vouchers), luxury items, or anything that could be perceived as an attempt to influence.
Any gift or hospitality valued at £50 or more (single or cumulative) must be notified to the Compliance Officer.
The Board must sign off any entertainment or hospitality ≥ £50 cumulative per client.
How this controls our risks: Ensures any benefit is legitimate, transparent, and not perceived as bribery.
3. Payments and Sponsorships
All payments over £1,000 must be approved by the Board before being made.
Payments in (other than service fees) also require Board approval.
Sponsorships, charitable donations, or training events must have a clear, legitimate business or charitable purpose — not to obtain an advantage.
Payments must be made directly to the contracted entity; never to an individual or third party.
How this controls our risks: Prevents concealed inducements and ensures financial transparency.
4. Record Keeping and Registers
We maintain:
A Bribery & Gifts Register, recording all declared or approved gifts, hospitality, sponsorships, or payments.
A Personal Investment Register, recording staff trading accounts (see Market Abuse and Personal Investment Policy).
Records are reviewed quarterly by the MLRO/Compliance Officer and reported to the Board.
How this controls our risks: Demonstrates active monitoring and an audit trail for all inducement-related activity.
5. Employee Conduct
Staff must act with integrity and avoid any situation where personal interests conflict with Zeyro’s.
Employees must report any offered bribe, suspicious payment, or pressure to provide inducements immediately to the MLRO.
Failure to report is a disciplinary matter and may constitute a criminal offence.
How this controls our risks: Encourages a transparent culture and early identification of misconduct.
6. Third Parties
Zeyro conducts proportionate due diligence on suppliers, partners, and introducers.
Any third party acting for or representing Zeyro must comply with this policy and the Bribery Act 2010.
We do not outsource compliance responsibility — third parties must meet equivalent standards.
How this controls our risks: Prevents indirect bribery through intermediaries.
7. Reporting and Escalation
If you suspect or are offered a bribe:
Stop the interaction immediately.
Report the incident to the MLRO/Compliance Officer (Gareth Malna).
Record details in the Bribery Register. Zeyro will investigate promptly and report any criminal activity to the appropriate authorities.
How this controls our risks: Ensures prompt action and compliance with reporting obligations.
Training and Awareness
All staff complete ABC training on induction and annually thereafter. Training includes recognising red flags such as: unusual payments, excessive hospitality, and conflicts of interest.
How this controls our risks: Ensures understanding and compliance across the firm.
Enforcement
Breaches of this policy may lead to:
Disciplinary action (up to termination).
Reporting to the FCA or law enforcement.
Civil or criminal penalties under the Bribery Act 2010.
Maximum penalties:
Individuals – up to 10 years’ imprisonment and/or unlimited fines.
Firms – unlimited fines and reputational damage.
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