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Anti-Corruption Policy

Last Updated: October 2025


Pixel Spade is committed to conducting all business in an honest and ethical manner. We have a zero-tolerance approach to bribery, corruption and unethical conduct in any form. This policy outlines our stance on preventing, identifying and addressing corruption across all areas of our operations.


1. Purpose
The purpose of this policy is to ensure that all employees, contractors and partners of Pixel Spade act with integrity and in compliance with applicable anti-bribery and anti-corruption laws, including the UK Bribery Act 2010.


2. Scope
This policy applies to all individuals working with or on behalf of Pixel Spade, including employees, contractors, consultants, suppliers and third-party representatives in the UK or overseas.


3. Our Commitment
Pixel Spade does not tolerate corruption, bribery, facilitation payments or any unethical inducement in the course of business. We expect the same high standards from everyone we work with.

We are committed to:

  • Acting professionally, fairly and with integrity in all our relationships.
     
  • Maintaining transparent business practices.
     
  • Complying fully with all anti-corruption and anti-bribery legislation.
     

4. Definition of Bribery and Corruption
A bribe is any offer, promise, gift or payment intended to improperly influence a business decision or gain an unfair advantage.
Corruption refers to dishonest or fraudulent conduct by those in power, typically involving bribery or misuse of authority for personal gain.

Examples include:

  • Offering money, gifts or hospitality to influence a client decision.
     
  • Accepting incentives in exchange for preferential treatment.
     
  • Making unofficial “facilitation payments” to speed up services.
     

5. Gifts and Hospitality
Reasonable and proportionate hospitality may be acceptable when transparent and approved in advance. However, anything that could be perceived as an attempt to influence a decision is strictly prohibited.

All gifts or hospitality exceeding a nominal value (£50) must be declared to management before acceptance.


6. Third Parties and Contractors
We carefully vet contractors, freelancers and partners before engagement. Any individual or organisation acting on behalf of Pixel Spade must commit to the same anti-corruption principles.

Contracts will include clear terms requiring compliance with this policy. Failure to comply may result in termination of the agreement.


7. Conflicts of Interest
All potential or actual conflicts of interest must be declared immediately. We maintain transparency to ensure that personal relationships or financial interests do not interfere with business decisions.


8. Reporting Violations
Anyone who suspects a breach of this policy must report it immediately to hello@pixelspade.com.
Reports will be treated confidentially and investigated fairly. Retaliation against individuals who raise concerns in good faith will not be tolerated.


9. Record Keeping
Pixel Spade maintains accurate and transparent financial and business records. No undisclosed or unrecorded accounts, payments or transactions will be tolerated.


10. Enforcement
Breaches of this policy may result in disciplinary action, termination of contracts or legal proceedings where appropriate.


11. Review and Updates
This policy will be reviewed annually and updated to reflect best practice and legislative changes.

📍 27a Green Lane, London, England, United Kingdom
📧 hello@pixelspade.com

Copyright © 2025 Pixel Spade - All Rights Reserved. Wiseman FO Ltd t/a Pixel Spade | Registered in England Company Number: 16665231 | Registered Office: 27a Green Lane, London, England, United Kingdom 

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