Anti Bribery & Corruption ('ABC') Policy

Tranzbase Policy StatementTranzbase is to constantly enforce all applicable laws relating to anti-bribery and corruption in all jurisdictions in which it operates. Primarily we are bound by the laws of the UK, including the Bribery Act 2010, in regards to our operation both in the UK and abroad.Tranzbase senior management is to prevent bribery and corruption and foster a culture within Tranzbase in which bribery and corrupt activity is not acceptable in accordance with Principle 2of the UK Bribery Act.Tranzbase is committed to conduct business in an ethical and honest manner as well as to implement policies that ensure that bribery and corruption are prevented.Tranzbase is to have zero-tolerance in regards to bribery and corruption and is committed to act professionally and fairly in all its business dealings and relationships. Tranzbase takes its legal responsibilities seriously. Tranzbase is to recognize that bribery and corruption are punishable by up to 10 years of imprisonment and a fine. If it is discovered that Tranzbase has taken part in bribery or corrupt activities, it may be subjected to a fine and suffer serious damage to its reputation.

To whom this policy applies

This Policy applies to all individuals, whether in the UK or overseas, working for or on behalf of Tranzbase at all levels including employees (permanent, fixed-term or temporary), consultants, contractors, trainees, volunteers, interns, agents, sponsors, or any other individuals associated with Tranzbase.

What is bribery and corupption?

Bribery means an illegal act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something having value or providing an advantage in order to induce or influence an action or decision. A bribe means any inducement, reward, object or item of value offered to another individual in order to gain any commercial, contractual, regulatory, or personal advantage. Bribery is not limited to the act of offering a bribe itself. If an individual accepts a bribe, he or she also breaks the law. Employees must not engage in any form of bribery, whether directly or indirectly, passively (by accepting a bribe) or actively (by providing a bribe), on their own or through a third party.Corruption is known to be any unlawful or improper behaviour pursuing to gain an advantage with the help of illegitimate means.

Policy & Procedures

Section 6.1.3 of the FCA's Financial Crime Guide states that the FCA does not enforce or give guidance on the Bribery Act, however e-money institutions and payment institutions must have governance, effective risk management procedures and adequate internal control mechanisms in accordance with Regulation 6 of EMRs 2011 and PSRs 2017. This Policy with accompanying procedures outline responsibilities of Tranzbase in this field and of those who act on behalf of Tranzbase or represent Tranzbase in other way, in relation to the prevention of bribery and corruption.All employees and other individuals including third parties are to comply with this Policy and procedures and act in accordance with up-to-date Policy at all times. Tranzbase's Board of Directors ('the Board') is responsible for supervising compliance of all individuals to whom the Policy is applicable with it and the procedures. The Board delegated authority to supervise compliance with this Policy to the Compliance Officer. Tranzbase is to regularly review and update this Policy and procedures applied and communicate these to all individuals to whom it is applicable. Tranzbase also monitors effectiveness, suitability and adequacy of implementation of this Policy.

Risk assessment

In accordance with Principle 3 of the UK Bribery Act, Tranzbase is required to execute bribery and corruption risk assessment that builds a picture of bribery and corruption risks Tranzbase faces as well as evaluates likelihood and impact of such risks and effectiveness, suitability and adequacy of ctions applied to mitigate these risks. Tranzbase is to regularly review and update its bribery and corruption risk assessment. Responsibility for carrying out bribery and corruption risk assessment and reviewing and updating it lies on the Compliance Officer. The results of bribery and corruption risk assessment are presented to the Board.

Hospitality & Gifts

Tranzbase accepts appropriate gestures of hospitality and gifts (whether given to or received from third parties) as long as it meets the following requirements:It is provided in good faith, not offered, promised or accepted as an advantage for Tranzbase or its employees or representatives or in order to influence the impartiality of the recipient; It is not cash or cash-equivalent gift (like voucher, certificate, etc.); It is not a gift offered to or accepted from government officials or representatives, politicians or political parties, without the prior approval of the Compliance Officer; It is given for or from Tranzbase, not for or from certain individual; Tranzbase authorizes only reasonable, appropriate and proportionate promotional expenditures.This applies to all individuals representing Tranzbase. See the Tranzbase Procedures for details;If it is inappropriate to decline an offer of a gift (for example, when meeting with an individual of certain religion or culture who may take offence), it may be accepted as long as it is declared to the Compliance Officer and direct supervising manager who are to assess the circumstances.

Political ContributionsTranzbase do not make donations in cash or in any other kind, by any means, in order to support any political parties or politicians. This may be perceived as an attempt to gain improper business advantage or even bribery or corrupt activity.

Charitable donations

Tranzbase permits charitable donations made through services, invested knowledge or time or in the form of financial contributions (cash or otherwise) - on condition that such charitable donations it makes are to be disclosed. Individuals should be careful in order to ensure that charitable donations are not used to facilitate or conceal acts of bribery or corruption. Tranzbase is to ensure that all charitable donations are lawful and ethical under applicable laws and practices, and that donations are not offered or made by Tranzbase without the approval of the Compliance Officer. The Compliance Officer is to keep records of all charitable donations made by Tranzbase.

Facilitation payments ('Kickbacks')

Facilitation payments are small payments (or gifts) made to public officials to facilitate actions that officials are duly bound to perform. Tranzbase is not to allow its employees or its representatives or other individuals to make or accept facilitation payments of any kind. Tranzbase do not distinct between facilitation payments and bribes regardless of their size or local culture. It considers both bribe and facilitation payments in context of a criminal offence under the UK Bribery Act.

Employees' and other individuals' rsponsibilities

All employees and other individuals associated with Tranzbase must ensure that they comply with provisions of this Policy, and with any other anti-bribery and corruption information that they are given by Tranzbase.All employees and other individuals associated with Tranzbase are responsible for the prevention, detection, and reporting of bribery and corruption. They are required to avoid any activities that lead or could lead to, imply or could imply breach of this Policy. If an employee or other individual associated with Tranzbase has reasons to believe or suspect that a case of bribery or corruption has occurred or could occur, he or she must notify the Compliance Officer as soon as possible. Issues that are needed to be reported include:any suspected or actual attempts of bribery or corruption; concerns that other employees or individuals may be involved in cases of bribery (be bribed or be bribing) or corruption. Any cases of alleged bribery or corruption will be fully investigated.Any employee who breaches this Policy is subjected to disciplinary action. Concerning other individuals or even companies which are counterparties of Tranzbase, Tranzbase has the right to terminate an existing contractual relationship in response to any breach or suspected breach of thisPolicy.

Protection

If an employee or other individual associated with Tranzbase faces proposal for offering or accepting a bribe or other potential act(s) of bribery or corruption, he or she needs to inform about this the Compliance Officer as soon as possible. Tranzbase is to support anyone who raises concerns regarding proposals for offering or accepting a bribe or other potential act(s) of bribery or corruption in good faith under this Policy, even if a subsequent investigation finds that they were nogrounds for such concerns. Tranzbase is to ensure that no one suffers any detrimental treatment because of his or her refuse toaccept or offer a bribe or conduct other corrupt activities or because he or she reported about proposals for offering or accepting a bribe or other potential act(s) of bribery or corruption.

Relatonships with third parties

Third parties include actual and potential customers, suppliers, distributors, agents, advisers, government and public bodies (with their advisors, representatives and officials), politicians, political parties, etc.Relationships with third parties may create varying degrees of bribery or corruption risk to Tranzbase. For example, if third parties make corrupt payments acting for or on behalf of Tranzbase and Tranzbase becomes liable for third parties' corrupt behavior with whom it has a relationship. Third parties who act for or on behalf of Tranzbase must comply with provisions of this Policy.

Third parties payments

Tranzbase shall have effective systems and controls in place in order to ensure that third parties' payments are processed as expected and approved. Tranzbase has implemented stable operational control for monitoring, reviewing, and approving third parties' payments. See the ABC Procedures for details.

Training & communication

In accordance with Principle 5 of the UK Bribery Act all employees are invited to undertake anti bribery&corruption training. More specific training is required for those employees that have a higher bribery and corruption risk in the course of their work.Anti bribery&corruption training prevent employees from committing bribery or corrupt practices and promote ethical behaviour. Post anti bribery&corruption training assessments or attestations are completed by employees with their completion records. Tranzbase also ensures that its zero-tolerance approach towards bribery and corruption is communicated to all suppliers, contractors, business partners and other third parties by making them aware of provisions of this Policy on the Tranzbase's website.

Monitoring & reviewing

In accordance with the Principle 6 of the 2010 UK Bribery Act, time-to-time and risk-based testing is carried out to confirm compliance with the ABC Policy and procedures. Any risks shall be mitigated, and appropriate control measures shall be applied. Testing of compliance shall be performed by independent parties, e.g. Compliance Monitoring or Internal Audit. The Board is responsible for monitoring the effectiveness, suitability and adequacy ofimplementation of this Policy on a regular basis.

Management information

Tranzbase senior management shall be provided with sufficient information in order to understand bribery and corruption risks to which Tranzbase is exposed. This is to help Tranzbase senior management to effectively manage and minimize these risks and adhere to Tranzbase's zero-tolerance approach towards bribery and corruption.Information shall be provided to Tranzbase senior management regularly and ad hoc if necessary.

Breaches

All breaches of the ABC Policy and procedures shall be recorded in the Tranzbase's Breaches Register.

Persistent control

Persistent staff and recruitment control that takes into account bribery and corruption risks associated with employees' roles, are important for Tranzbase to reduce the risk of Tranzbase's employees to engage in any corrupt practices or commit bribery. Employees on higher positions shall be subjected to more thorough control.

Recordkeeping

Tranzbase is to keep detailed and accurate records including financial ones and apply appropriate internal control and analysis of all payments made. Tranzbase is to keep written records of amount and reasons for any gifts and other things accepted and given that are subjected for monitoring by the Compliance Office