Anti-Bribery and Corruption Statement
Last updated 11th August 2026
1. Purpose and Commitment
TWPayz is committed to conducting business with integrity, transparency and in accordance with applicable anti-bribery and anti-corruption laws and regulatory requirements.
TWPayz is the trading name used by two separate legal and regulated entities: Transactworld Limited in the United Kingdom and Payment Infosys Limited in Mauritius.
References in this Statement to “TWPayz” or “TWPayz entities” refer to both entities collectively only where the principles described are applicable to each of them. The use of the TWPayz trading name does not affect the separate legal identity, regulatory status, responsibilities or obligations of either entity.
Each TWPayz entity is separately responsible for compliance with the anti-bribery and anti-corruption laws and regulatory requirements applicable to its activities and maintains its own governance, policies, procedures and controls appropriate to the nature, scale, complexity and risk profile of its business.
Both TWPayz entities prohibit bribery, corruption and the improper use of influence in connection with their respective business activities, whether involving public officials, private persons or organisations and whether occurring directly or through a third party.
2. Entity-Specific Legal and Regulatory Frameworks
Transactworld Limited – United Kingdom
Transactworld Limited is incorporated in England and Wales and is authorised and regulated by the Financial Conduct Authority (“FCA”) as an Electronic Money Institution under the Electronic Money Regulations 2011, with Firm Reference Number 900405.
Transactworld Limited maintains its anti-bribery and corruption framework in accordance with applicable UK legal and regulatory requirements, including the Bribery Act 2010 and relevant FCA financial crime requirements and guidance.
Its arrangements are designed having regard to the bribery and corruption risks arising from its own activities, relationships and regulatory obligations, including risks associated with persons performing services for or on its behalf.
The UK Bribery Act includes offences relating to giving and receiving bribes, bribery of foreign public officials and failure by a commercial organisation to prevent bribery by associated persons. The UK framework emphasises proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.
Payment Infosys Limited – Mauritius
Payment Infosys Limited is incorporated in Mauritius and is licensed and regulated by the Financial Services Commission of Mauritius (“FSC”) to conduct Payment Intermediary Services under the Financial Services Act 2007.
Payment Infosys Limited maintains its anti-bribery and corruption framework in accordance with applicable Mauritius legal and regulatory requirements, including the Financial Crimes Commission Act 2023, as amended, and relevant guidance issued by the Financial Crimes Commission (“FCC”).
Its arrangements are designed having regard to the bribery and corruption risks arising from its own activities, relationships and regulatory obligations.
The Mauritius framework requires legal persons to maintain adequate procedures reasonably necessary to prevent relevant offences under the Financial Crimes Commission Act 2023. The FCC’s Guidelines on Legal Persons establish principles addressing top-level commitment, risk assessment, control measures, monitoring and enforcement, and training and communication.
The legal and regulatory obligations applicable to one TWPayz entity do not, solely by reason of the common TWPayz trading name, apply to the other entity.
3. Prohibited Conduct
Each TWPayz entity prohibits bribery and corrupt conduct in connection with its respective business activities.
Direct or indirect prohibited conduct includes:
Offering, promising, giving, requesting, agreeing to receive or accepting a bribe or other improper advantage
Providing or receiving a financial or non-financial benefit intended to improperly influence a business, regulatory or other decision
Bribery involving public officials or foreign public officials
Making or receiving improper payments or benefits through agents, intermediaries or other third parties
Making facilitation payments where prohibited by applicable law or the relevant TWPayz entity’s internal requirements
Using gifts, hospitality, donations, sponsorships or other benefits to obtain or reward an improper advantage
Concealing, mischaracterising or improperly recording payments, benefits or transactions connected with bribery or corrupt conduct
No commercial opportunity, transaction or business advantage justifies conduct that breaches the anti-bribery or anti-corruption requirements applicable to either TWPayz entity.
4. Gifts, Hospitality and Other Benefits
Each TWPayz entity maintains controls governing gifts, hospitality, entertainment and other business courtesies in accordance with its applicable legal and regulatory requirements and risk profile.
Such benefits must be legitimate, reasonable and proportionate, have a genuine business purpose and comply with the relevant entity’s internal requirements.
They must not be offered, provided, requested or accepted where intended, or reasonably capable of being perceived as intended, to improperly influence a decision, obtain an improper advantage or create an inappropriate obligation.
Particular care is applied to benefits involving public officials or persons connected with them.
5. Risk-Based Approach
Each TWPayz entity separately identifies, assesses, manages and mitigates the bribery and corruption risks arising from its own activities and relationships.
Risk assessments may take into account:
The nature of business activities and relationships
Geographic and jurisdictional exposure
Interaction with public officials or public bodies
Agents, intermediaries and other third parties
Gifts, hospitality, donations and sponsorships
The nature and purpose of payments or other benefits
Other relevant bribery and corruption risk factors
The nature and extent of controls applied by each entity are proportionate to its identified risks and applicable legal and regulatory requirements.
6. Third Parties
Each TWPayz entity applies appropriate risk-based due diligence, contractual controls and oversight to agents, introducers, intermediaries, suppliers, contractors, service providers and other relevant third parties with which it establishes relationships.
The nature and extent of such measures are determined by the relevant TWPayz entity having regard to the nature and risk of the particular relationship.
Neither TWPayz entity will knowingly engage or use a third party to undertake conduct on its behalf that would be prohibited if undertaken directly by that TWPayz entity.
7. Books, Records and Internal Controls
Each TWPayz entity maintains appropriate financial, accounting and operational controls designed to support the prevention and detection of bribery, corruption, improper payments and other related misconduct.
Relevant payments, expenditure and transactions must be properly authorised, accurately and transparently recorded, and supported by appropriate documentation in accordance with the legal, regulatory and internal requirements applicable to the relevant TWPayz entity. Appropriate controls are applied to payments and benefits presenting heightened bribery or corruption risk, including, where relevant, gifts and hospitality, third-party payments, donations and sponsorships.
Off-book accounts or transactions, unauthorised payments, and false, misleading, incomplete or deliberately inaccurate records intended to conceal the nature or purpose of a payment, benefit or transaction are prohibited.
Each TWPayz entity maintains records for the periods required by applicable legal, regulatory and internal record-retention requirements.
8. Conflicts of Interest
Each TWPayz entity maintains arrangements for the identification, disclosure and appropriate management of actual, potential or perceived conflicts of interest arising in connection with its activities.
Directors, officers and relevant employees are expected to disclose conflicts in accordance with the requirements applicable to the relevant TWPayz entity and, where appropriate, refrain from participating in decisions or activities affected by such conflicts.
Personal interests, relationships or other circumstances must not be used to improperly influence a decision, obtain or provide an improper advantage, or otherwise compromise the integrity of decisions made on behalf of either TWPayz entity.
9. Training and Awareness
Each TWPayz entity provides relevant employees with anti-bribery and corruption training appropriate to their roles, responsibilities and risk exposure. Additional or enhanced training may be provided to employees whose roles present heightened bribery or corruption risks.
Training and internal communications are designed to promote awareness and understanding of applicable legal and regulatory requirements, relevant bribery and corruption risks, internal policies and controls, and the identification, prevention and appropriate escalation of suspected or actual misconduct.
Training and awareness arrangements are reviewed periodically and updated where appropriate to reflect relevant changes in applicable requirements, business activities and bribery and corruption risks.
10. Raising Concerns
Each TWPayz entity maintains appropriate arrangements for the reporting, assessment and escalation of suspected or actual bribery, corruption or other improper conduct relating to its activities.
Directors, officers and employees are expected, and other relevant persons are encouraged, to raise genuine concerns promptly through the reporting and escalation channels made available by the relevant TWPayz entity. Concerns may be escalated for further review or investigation where appropriate.
Concerns raised in good faith will be handled appropriately and, to the extent permitted by applicable law, confidentially. Neither TWPayz entity tolerates retaliation, victimisation or other detrimental treatment against a person for raising a genuine concern in good faith or participating in an investigation.
11. Breaches and Cooperation with Authorities
Suspected or identified breaches of applicable anti-bribery and anti-corruption requirements or relevant internal controls will be assessed, reviewed and, where appropriate, investigated and escalated by or on behalf of the TWPayz entity to which the relevant conduct relates, in accordance with its applicable legal and regulatory requirements and internal procedures.
Where a breach is established, the relevant TWPayz entity may take appropriate and proportionate action, including disciplinary measures and the suspension, restriction or termination of the relevant business or third-party relationship. Matters may also be referred to competent authorities where required or appropriate.
Each TWPayz entity remains separately responsible for complying with any reporting, disclosure and cooperation obligations applicable to it, including making required reports or disclosures and cooperating with regulatory, supervisory, investigative, law enforcement or other competent authorities having jurisdiction over that entity or the relevant matter.
12. Governance and Oversight
Transactworld Limited and Payment Infosys Limited each maintain their own governance and oversight arrangements for the identification, assessment and management of bribery and corruption risk, appropriate to the nature, scale, complexity and risk profile of their respective activities.
Such arrangements include, as applicable:
Documented anti-bribery and corruption policies and procedures
Bribery and corruption risk assessments
Third-party due diligence and oversight
Controls relating to gifts, hospitality and other benefits
Conflicts of interest controls
Financial and payment controls
Internal reporting and escalation arrangements
Staff training and awareness
Appropriate management oversight
Compliance monitoring
Independent review or audit where required or appropriate
Each TWPayz entity is separately responsible for the oversight, implementation and effectiveness of its anti-bribery and corruption framework and for ensuring that its arrangements remain proportionate to the risks arising from its activities.
The governance arrangements and controls of each entity are reviewed periodically and updated where appropriate to reflect changes in applicable laws and regulatory requirements, business activities, risk exposure and relevant bribery and corruption risks.
13. Review of this Statement
This Statement reflects the common anti-bribery and anti-corruption principles applied across TWPayz while recognising the separate legal identity, regulatory status and compliance responsibilities of Transactworld Limited and Payment Infosys Limited.
Each TWPayz entity remains separately responsible for maintaining, reviewing and assessing the adequacy and effectiveness of its own anti-bribery and corruption framework in accordance with the legal and regulatory requirements applicable to its activities.
This Statement is reviewed periodically and may be updated, where appropriate, to reflect changes in applicable laws, regulatory requirements and guidance, business activities, risk exposure, or bribery and corruption risks.