Zero Tolerance

Anti-Bribery & Corruption Policy

TalaStar Digital Ltd maintains a zero-tolerance position on bribery and corruption in all forms. This policy applies to all persons working for or on behalf of TalaStar Digital, including the founder, any future employees, contractors, consultants, and third-party representatives.

UK Bribery Act 2010 | Companies Act 2006 | Effective: 10 April 2026 | Version 1.0

Transparency Notice

TalaStar Digital Ltd (Company No. 17060305) is an early-stage technology company currently operated solely by its founder. While the company does not yet have the scale or complexity that typically necessitates a formal anti-bribery programme, we publish this policy voluntarily as a foundational commitment. As the company grows and engages employees, contractors, and international partners, this policy will be expanded with proportionate procedures, training programmes, and monitoring systems. Publishing early demonstrates that ethical governance is built into TalaStar's DNA, not retrofitted after problems arise.

The UK Bribery Act 2010

The UK Bribery Act 2010 is one of the strictest anti-corruption statutes in the world. It creates four criminal offences that apply to TalaStar Digital.

Section 1

Bribing Another Person

Offering, promising, or giving a financial or other advantage to another person to induce or reward improper performance of a function or activity.

Penalty: Up to 10 years' imprisonment and/or unlimited fine

Section 2

Being Bribed

Requesting, agreeing to receive, or accepting a financial or other advantage in connection with the improper performance of a function or activity.

Penalty: Up to 10 years' imprisonment and/or unlimited fine

Section 6

Bribery of Foreign Public Officials

Bribing a foreign public official to obtain or retain business or a business advantage. No requirement to prove improper performance.

Penalty: Up to 10 years' imprisonment and/or unlimited fine

Section 7

Failure to Prevent Bribery

A commercial organisation failing to prevent bribery by persons associated with it. The only defence is having adequate procedures in place.

Penalty: Unlimited fine for the organisation

What TalaStar Will Never Do

These prohibitions are absolute and apply regardless of business pressure, local custom, competitive disadvantage, or the perceived insignificance of the amount involved.

Bribes & Kickbacks

No person acting on behalf of TalaStar Digital shall offer, promise, give, request, or accept any bribe — whether in cash, gifts, favours, hospitality, or any other form of inducement — to or from any person, for the purpose of obtaining or retaining business or a business advantage.

Facilitation Payments

TalaStar Digital does not make or accept facilitation payments of any kind. These are small, unofficial payments made to secure or expedite a routine government action. Such payments are illegal under the UK Bribery Act 2010, regardless of local customs.

Political & Charitable Donations

No donations — whether political, charitable, or sponsorship — shall be made on behalf of TalaStar Digital for the purpose of obtaining or retaining a business advantage. All charitable activity is conducted through TalaStar Charity Hub with full transparency.

Third-Party Intermediaries

TalaStar Digital does not engage agents, consultants, or intermediaries to perform any act that would be prohibited if performed by TalaStar directly. All third-party relationships are subject to due diligence proportionate to the bribery risk they present.

Bribery Risk Assessment

TalaStar Digital has identified the following areas where bribery risk may arise as the company grows. Each area has proportionate mitigation measures.

Technology Procurement

Risk

Vendors offering preferential pricing, free services, or gifts in exchange for exclusive contracts

Mitigation

All vendor selections documented with objective criteria. No single person has sole authority over procurement decisions above £500.

International Partnerships

Risk

Partners in jurisdictions with higher corruption indices may operate under different norms

Mitigation

Enhanced due diligence for all international partners. Anti-bribery clauses required in all partnership agreements. Right to audit maintained.

Research Collaborations

Risk

Academic or institutional partners may expect gifts, hospitality, or undisclosed payments

Mitigation

All research collaborations governed by written agreements with transparent terms. No payments outside agreed contract scope.

Government & Regulatory Interactions

Risk

Interactions with regulators (FCA, ICO, Companies House) could involve pressure for facilitation payments

Mitigation

All regulatory interactions logged. No payments to government officials outside published fee schedules. Legal counsel consulted for any unusual requests.

Hospitality & Gifts

Risk

Giving or receiving gifts that could be perceived as inducements

Mitigation

Gifts above £50 in value must be declared and recorded. No gifts to or from anyone in a position to influence a business decision. All hospitality must have a clear business purpose.

Due Diligence Process

Section 7 of the Bribery Act provides a defence if the organisation can demonstrate "adequate procedures" to prevent bribery. TalaStar's due diligence follows four steps.

1

Risk Assessment

Before entering any new business relationship, assess the bribery risk based on the country, sector, transaction type, and counterparty profile.

2

Background Verification

Verify the identity, reputation, and business legitimacy of all counterparties. Check against sanctions lists and adverse media where proportionate.

3

Contractual Safeguards

Include anti-bribery clauses in all contracts. Require counterparties to comply with the UK Bribery Act 2010 or equivalent local legislation.

4

Ongoing Monitoring

Review high-risk relationships annually. Investigate any red flags promptly. Maintain records of all due diligence conducted.

Reporting Concerns

Internal Reporting

Any person who suspects bribery or corruption should report it immediately to the founder at [email protected]. All reports will be treated confidentially and investigated promptly.

View Whistleblowing Policy

External Reporting

If you are not comfortable reporting internally, or if you believe the matter has not been adequately addressed, you may report to:

  • Serious Fraud Office (SFO) — sfo.gov.uk
  • National Crime Agency — nationalcrimeagency.gov.uk
  • Protect (formerly Public Concern at Work) — protect-advice.org.uk

Protection for Reporters

TalaStar Digital will not tolerate any form of retaliation against anyone who reports a genuine concern about bribery or corruption in good faith. This protection applies regardless of whether the concern is ultimately substantiated. Reporters are protected under the Public Interest Disclosure Act 1998 (PIDA) and this policy.

Consequences of Non-Compliance

Any breach of this policy will be treated as a serious matter. Depending on the severity and circumstances, consequences may include:

Disciplinary Action

Up to and including summary dismissal for employees, or immediate termination of contract for contractors and consultants.

Legal Proceedings

TalaStar Digital will report suspected criminal conduct to the relevant authorities and cooperate fully with any investigation.

Contract Termination

Immediate termination of any business relationship where a third party is found to have engaged in bribery or corruption.

This Anti-Bribery & Corruption Policy was approved by the sole director of TalaStar Digital Ltd and will be reviewed annually or whenever a material change in business operations occurs.

Kristal Jane Apurado

Founder & CEO, TalaStar Digital Ltd

Company No. 17060305 | 10 April 2026