Anti-Bribery and Corruption Policy

Date of Issue: [24th September, 2025] Version: 1.0

1. Policy Statement

HYPES SB UK LTD ("the Company") is committed to conducting its business with the highest standards of ethics and integrity in all its operations worldwide. We have a zero-tolerance policy towards bribery and all forms of corruption.

This policy outlines our commitment to complying with all applicable anti-bribery laws, including the UK Bribery Act 2010, and reflects the top-level commitment of the Company to prevent bribery by any individual or entity acting on our behalf.

CEO: Satoshi Kuriga

2. To Whom This Policy Applies (Scope)

This policy applies to all of the Company's directors, officers, and employees (whether permanent, fixed-term, or temporary), regardless of their location or nationality.

Furthermore, we expect all subsidiaries, agents, consultants, contractors, suppliers, and other third-party business partners acting for or on behalf of the Company ("Associated Persons") to adhere to the principles of this policy. We will take appropriate measures to ensure their compliance.

3. What Are Bribery and Corruption?

Bribery is the act of offering, promising, giving, demanding, or accepting a financial or other advantage to induce or reward the improper performance of a person's duties.
Prohibited acts under this policy include, but are not limited to:

  • Bribing another person: Offering, promising, or giving a financial or other advantage to another person to influence their conduct improperly.
  • Being bribed: Requesting, agreeing to receive, or accepting a financial or other advantage in return for improperly performing one's duties.
  • Bribing a public official: Giving an advantage to a foreign or domestic public official* with the intention of influencing them to gain or retain business or a business advantage.
    • *A public official includes government officials, members of parliament, judges, employees of state-owned enterprises, and officials of international organisations.
  • Facilitation Payments: Small, unofficial payments made to secure or expedite a routine government action (e.g., permits, customs clearance) are considered bribes under the UK Bribery Act 2010 and are strictly prohibited.

4. Gifts, Hospitality, and Expenses

The Company permits reasonable and proportionate gifts and hospitality as a matter of business custom to build and maintain good business relationships. However, they must not carry any intention or risk of being perceived as a bribe.

  • Prohibited:
    • Gifts of cash or cash equivalents (e.g., vouchers).
    • Inappropriate, excessive, or frequent hospitality or gifts.
    • Gifts or hospitality offered at a time that could be interpreted as influencing a business decision.
    • Anything that is illegal or unethical.
  • Approval Process:
    • The offering or acceptance of any gift or hospitality with a value exceeding [e.g., £100] requires prior written approval from the Compliance Officer (or a designated manager).
    • All gifts, hospitality, and expenses must be accurately recorded in the Company's accounting books with their purpose, recipient, and value.

5. Charitable Donations and Sponsorships

As a responsible corporate citizen, the Company supports charitable donations and sponsorships. However, we strictly forbid their use as a disguise for bribery. All donations and sponsorships must be transparent, made for a legitimate purpose, and subject to prior due diligence and an approval process.

6. Your Responsibilities

All employees are responsible for reading, understanding, and complying with this policy. You must strive to prevent, detect, and report bribery and corruption. If you are ever in doubt about this policy or a specific situation, you must immediately consult the Compliance Officer.

7. Raising Concerns (Whistleblowing)

All employees and Associated Persons have a duty to report any suspected breach of this policy or any concerns regarding bribery and corruption without delay.

  • Reporting Channels:
    • Your line manager
    • The Compliance Officer
    • The Whistleblowing Hotline: legal@hypes-bet.com

Reports can be made anonymously and will be treated with the utmost confidentiality. The Company guarantees that no one will suffer any retaliation (such as demotion, harassment, or other adverse treatment) for raising a concern in good faith.

8. Consequences of Breaching This Policy

A breach of this policy is considered a very serious matter. For employees, it may result in disciplinary action up to and including dismissal. A breach may also lead to legal proceedings, potentially resulting in fines and imprisonment for individuals, and unlimited fines and the loss of business licenses for the Company.

9. Record-Keeping

All financial books, invoices, and other records relating to dealings with third parties must accurately reflect the business rationale for the transaction and be properly kept in accordance with relevant laws. The creation of false or misleading records is strictly prohibited.

10. Training and Communication

The Company will provide regular training on this policy for all employees to raise awareness of bribery risks. This policy will be accessible on the company intranet and will be updated as necessary.

11. Review of This Policy

The Compliance Officer is responsible for regularly reviewing the effectiveness of this policy. It will be reviewed at least annually, or more frequently if required, to adapt to changes in legal requirements or business risks.