Last updated - January, 2025

Purpose

The purpose of this policy is to ensure that ScorePlay operates in compliance with all applicable laws and regulations related to anti-bribery and corruption. It reinforces our commitment to ethical business practices across the sports and technology industries, protecting our reputation, employees, and stakeholders.

Scope

This policy applies to all employees, officers, directors, agents, consultants, contractors, and any other third parties acting on behalf of ScorePlay, regardless of their location. It covers all interactions with government officials, clients, partners, suppliers, and other stakeholders across ScorePlay’s global operations, including Europe, the UK, Brazil, and the USA.

Policy Statement

ScorePlay Inc. is committed to the highest standards of integrity and ethical conduct in all business dealings. Bribery and corruption in any form are strictly prohibited. All employees and associated persons are expected to act with honesty and integrity and to safeguard ScorePlay Inc.'s reputation by ensuring that business practices comply with this policy and all relevant laws. We actively promote transparency and accountability in all interactions.

Definitions

• Bribery: Offering, giving, receiving, or soliciting something of value to influence a decision or gain an improper advantage.
• Corruption: Abuse of entrusted power for private gain.
• Facilitation Payments: Small payments made to expedite routine government actions.
• Government Official: Any individual acting in an official capacity for or on behalf of a government, public body, or state-owned enterprise.

Prohibited Conduct

Bribery

Employees and associated persons must not:

• Offer, promise, give, or authorize a payment or gift to a government official, client, or any other person to influence a business decision.
• Accept any payment, gift, or other benefit from a third party that may influence or appear to influence an official or business decision.
• Engage in any activity that could create a perception of improper conduct, even if no tangible benefit is exchanged.

Facilitation Payments

Facilitation payments are prohibited. These are small payments made to expedite or secure the performance of a routine governmental action.