Anti-Bribery and Corruption Policy

1. Purpose

Finaltable Media Ltd (“the Company”, “we”, “us”) is committed to conducting business with integrity, transparency, and fairness. This Anti-Bribery and Corruption Policy sets out our zero-tolerance approach to bribery and corruption in all its forms, in line with the UK Bribery Act 2010 and applicable international anti-corruption laws.

2. Scope

This policy applies to all directors, officers, employees (permanent, fixed-term, or temporary), consultants, contractors, interns, agents, and any other persons associated with the Company, wherever they are located. It also applies to third parties acting on the Company’s behalf, including affiliate partners, suppliers, and service providers.

3. Policy statement

The Company prohibits any form of bribery or corrupt practice. We will not offer, promise, give, request, agree to receive, or accept any financial or other advantage to or from any person in order to improperly influence a business decision or outcome.

We recognise that acts of bribery, even if committed outside the United Kingdom, may expose the Company and its officers to criminal liability under the UK Bribery Act 2010.

4. Definitions

• Bribery — offering, promising, giving, requesting, agreeing to receive, or accepting any financial or other advantage to induce or reward improper performance of a function or activity.
• Corruption — the abuse of entrusted power for private gain, including fraud, embezzlement, collusion, and the misuse of confidential information.
• Facilitation payment — an unofficial payment made to secure or expedite routine government action. These are a form of bribery and are prohibited under this policy.
• Public official — any person holding a legislative, administrative, or judicial office, including employees of state-owned or state-controlled entities and international organisations.

5. Prohibited conduct

No person covered by this policy may, directly or indirectly:

• Offer, pay, solicit, or accept a bribe in any form, whether in cash, gifts, hospitality, services, or anything else of value.
• Make, authorise, or facilitate any payment intended to influence a decision or secure an improper advantage.
• Engage a third party where there is reason to believe that the third party may pay or receive bribes on our behalf.
• Retaliate against any person who raises a concern about suspected bribery or corruption in good faith.

6. Gifts and hospitality

We recognise that modest gifts and hospitality are a legitimate part of building and maintaining business relationships. However, these must never be used to improperly influence a decision or create a sense of obligation.

Gifts and hospitality are acceptable only where they:

• Are not made with the intention of influencing a third party.
• Comply with local laws and the recipient’s own organisation’s rules.
• Are given or received openly, not in secret.
• Are of modest value and proportionate to the occasion.
• Are not given to or received from public officials without prior written approval from the Director.

All gifts or hospitality (given or received) with a value above £100 must be declared in writing to the Director and recorded in the gifts and hospitality register.

7. Facilitation payments and kickbacks

The Company does not make, and will not accept, facilitation payments or kickbacks of any kind, anywhere in the world. If any person is asked to make such a payment they must refuse and report the request to the Director immediately.

8. Charitable and political donations

The Company does not make political donations. Charitable donations are permitted where they are lawful, ethical, and not made as a quid pro quo for business advantage. All charitable donations made on behalf of the Company require prior written approval from the Director.

9. Third-party due diligence

We conduct risk-based due diligence on third parties with whom we contract, including affiliate partners, commercial agents, and material suppliers. Where a third party is engaged to act on our behalf, their contract must include a clause requiring compliance with this policy and the UK Bribery Act 2010.

Our affiliate relationships are primarily with UK Gambling Commission-licensed operators and their regulated networks; these are treated as lower risk but remain within scope.

10. Record keeping

The Company maintains accurate books and records that reflect transactions and expenses fairly. All expenses, gifts, hospitality, and payments to third parties must be properly recorded, with a clear business purpose. No off-the-books accounts or false records are permitted under any circumstances.

11. Reporting concerns

Any person covered by this policy who suspects that bribery or corruption has occurred, is occurring, or may occur must report their concern without delay to Brett Andrews at brett.andrews@finaltablemedia.co.uk. Concerns may be raised confidentially.

The Company will not tolerate retaliation against any person who raises a concern in good faith, even if the concern subsequently proves to be mistaken.

12. Training and awareness

All employees receive a copy of this policy on induction and are required to acknowledge that they have read and understood it. Periodic refresher briefings are provided and this policy is made available on the Company’s internal systems at all times.

13. Responsibilities

The Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all those under our control comply with it.

The Director (Brett Andrews) is the policy owner and is responsible for day-to-day implementation, monitoring effectiveness, and responding to reported concerns.

All personnel are responsible for preventing, detecting, and reporting bribery and corruption, and for complying with the letter and spirit of this policy.

14. Breach and disciplinary action

Any breach of this policy may constitute grounds for disciplinary action, up to and including summary dismissal. Breaches may also result in criminal prosecution. Third parties that breach this policy may have their contract terminated with immediate effect.

15. Monitoring and review

The Director reviews this policy at least annually and following any material change in the Company’s operations, applicable law, or relevant regulatory guidance. The next scheduled review date is 19 April 2027.