Anti-Bribery and Corruption Policy
1. Commitment
Tairo Ventures Ltd commits to conducting business with integrity and to a zero-tolerance approach toward bribery and corruption in any form. Acting honestly is a non-negotiable condition of every engagement, every relationship, and every transaction.
2. Scope
This policy applies to all directors, officers, employees, contractors, and agents of Tairo Ventures Ltd, and to any third party acting on our behalf, in every jurisdiction in which we operate.
3. What is prohibited
The following are prohibited at all times:
- Offering, promising, giving, requesting, or accepting any financial or other advantage with the intention of inducing or rewarding improper performance of a function or activity.
- Bribing a foreign public official to obtain or retain business or any business advantage.
- Facilitation payments (small unofficial payments to expedite routine government action).
- Kickbacks of any kind.
- Failing to record, accurately and transparently, any payment or receipt covered by this policy.
4. Gifts and hospitality
Modest, infrequent, and proportionate gifts and hospitality offered or received in good faith for legitimate business purposes are permitted, provided they:
- Are not given or received with the intention of influencing a business decision.
- Are not cash or cash equivalents.
- Are reasonable in value and frequency.
- Are appropriate to the relationship and the circumstances.
- Are recorded and, where material, approved in advance by a director.
Gifts to or from public officials require prior written approval and additional scrutiny.
5. Donations and political contributions
We do not make political contributions. Charitable donations, where made, are subject to due diligence on the recipient and are recorded transparently in the company's books.
6. Third parties
Third parties acting on our behalf are subject to risk-based due diligence before engagement. Contracts with third parties include anti-bribery representations, the right to terminate for breach of this policy, and the right to audit relevant records.
7. Books, records, and controls
All transactions must be recorded accurately and in reasonable detail. No undisclosed or unrecorded accounts, funds, or assets may be maintained. Internal financial controls are designed to prevent and detect any payment that could violate this policy.
8. Reporting concerns
Anyone with a concern about possible bribery or corruption should report it to a director or by emailing info@tairoventures.com. Concerns may be raised in confidence. Tairo Ventures Ltd does not tolerate retaliation against any person who raises a concern in good faith, even if the concern is later shown to be mistaken.
Where a concern relates to the director, or where a reporter prefers to use an external channel, disclosure may be made to a "prescribed person" listed by the UK Department for Business and Trade under the Public Interest Disclosure Act 1998, or, in the EU, to the competent authority designated under the national transposition of Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law.
9. Training and awareness
All directors and employees receive a copy of this policy on joining and at material updates. Anti-bribery awareness is reviewed at least annually.
10. Consequences of non-compliance
Breach of this policy is a serious matter. It may result in disciplinary action, dismissal, termination of contractor or agency relationships, civil action for recovery of losses, and referral to law-enforcement authorities. Individuals may face criminal liability under the UK Bribery Act 2010 (penalties of up to 10 years' imprisonment for individuals and unlimited fines for companies), the US FCPA, or other applicable anti-corruption laws.
11. Related economic-crime offences
Tairo Ventures Ltd also adopts a zero-tolerance approach to the criminal facilitation of tax evasion under sections 45 and 46 of the Criminal Finances Act 2017, and applies the same standards to its operations as those expected of a "large organisation" under section 199 of the Economic Crime and Corporate Transparency Act 2023 (failure to prevent fraud), even where the size thresholds for that offence are not met.
12. Sanctions screening
We screen counterparties against the UK consolidated list of asset-freeze targets maintained by the Office of Financial Sanctions Implementation (OFSI), the EU consolidated financial-sanctions list, and the US Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list, before entering into a material engagement. We do not transact with sanctioned persons or entities.
13. Governance
This policy is owned by the board of directors of Tairo Ventures Ltd and is reviewed at least annually.
14. Approval
Approved by the sole director of Tairo Ventures Ltd by written resolution of the board on 1 May 2026, and signed on its behalf by the sole director on the same date. The identity of the sole director is filed at and publicly available from Companies House (find-and-update.company-information.service.gov.uk/company/17186608).