Anti-Bribery & Corruption Policy

1. Purpose

This policy sets out SuperSubBetting's zero-tolerance approach to bribery and corruption. It is required because the Bribery Act 2010 applies to all UK businesses and individuals regardless of size.

2. Legal context

The Bribery Act 2010 creates the following offences relevant to this business:

• Section 1 — Active bribery: Offering, promising or giving a financial or other advantage to another person to induce improper performance.
• Section 2 — Passive bribery: Requesting, agreeing to receive or accepting a bribe.
• Section 6 — Bribery of a foreign public official.
• Section 7 — Failure of a commercial organisation to prevent bribery by an associated person. This offence applies to all commercial organisations, including sole traders operating a business. The defence is having "adequate procedures" — which this policy documents.

Maximum penalty: 10 years' imprisonment and/or an unlimited fine for individuals; unlimited fine for organisations.

3. Scope

This policy applies to all business activities of SuperSubBetting, including relationships with operators, advertisers, content partners, freelancers and other third parties.

4. What is prohibited

• Offering, promising or giving any financial advantage, gift or hospitality to any person to obtain or retain business, a favourable ranking, editorial coverage or any other commercial advantage.
• Accepting any financial advantage, gift or hospitality that could reasonably be seen as intended to influence editorial judgement or business decisions.
• Making any payment — however small — to a public official to expedite a routine action ("facilitation payments").
• Using a third party to offer or receive a bribe on the business's behalf.

5. Commercial relationships

The following are not bribery in the context of this business, provided they are transparent, proportionate and recorded:

• Receiving ordinary contractual payments under documented commercial agreements that are disclosed where required.
• Receiving press materials, product access or publicly available operator information for editorial research purposes.
• Accepting modest, infrequent business hospitality (e.g. a meal at an industry event) provided it does not influence or appear to influence editorial decisions.

6. Practical controls

• Transparency: Material commercial relationships are disclosed where required.
• Editorial independence: Rankings, reviews and editorial content are based on verified reader-facing facts, not third-party payment terms or operator requests.
• No secret payments: The sole trader does not accept undisclosed payments or off-record inducements from operators to alter content.
• Gifts and hospitality: Any gift or hospitality with a value above £50 is recorded in a gifts register and assessed for whether it could improperly influence a business decision. Gifts above £100 are declined unless they are entirely promotional materials of nominal value.
• Operator due diligence: Before entering a commercial agreement, the operator is checked for UKGC licensing or equivalent regulation. Unregulated or anonymous operators are not engaged.
• No facilitation payments: No facilitation payments are made under any circumstances.

7. Reporting and escalation

1. If the sole trader is offered a bribe, the offer is declined immediately and documented.
2. If the offer involves a public official or appears to be connected to organised crime, report to the National Crime Agency or relevant police force.
3. If the offer involves an operator partner, report to the operator's compliance team and, if not resolved, to the UKGC (for UKGC-licensed operators).
4. Concerns about potential bribery can also be raised via the Whistleblowing Policy.

8. Record-keeping

• Gifts and hospitality register — reviewed annually, retained for six years.
• Records of any bribery concerns, investigations or reports — six years.
• This policy document — retained with version history.