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Terms, Conditions & Policies

Terms and Conditions

Website Terms and Conditions

PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY AND ENSURE THAT YOU UNDERSTAND THEM BEFORE USING OUR SITE

INTRODUCTION

These website terms and conditions together with any other documents referred to in them, sets out the terms that apply to your use of www.paye.com[1] (“our site”) and how they relate to our notices and policies for the use of it.

WHAT’S IN THESE TERMS?

These website terms and conditions include the following sections for you to understand the rules for using our site www.paye.com
1. Who we are and how to contact us?
2. By using our site, you accept these terms
3. There are other terms that may apply to you
4. We may make changes to these terms
5. We may make changes to our site
6. We may suspend or withdraw our site
7. You must keep your account details safe
8. How you may use material on our site
9. Do not rely on information on our site
10. We are not responsible for websites we link to
11. User-generated content is not approved by us
12. How to complain about content uploaded by other users
13. Our responsibility for loss or damage suffered by you
14. How we may use your personal information
15. We are not responsible for viruses and you must not introduce them
16. Rules about linking to our site
17. Which country’s laws apply to any disputes?

1. WHO WE ARE AND HOW TO CONTACT US

www.paye.com is a site operated under licence from Goldcroft Solutions Limited (Company Number: 368522) of 89 Nexus Way. Camana Bay, Grand Cayman KY1-9009, Cayman Islands by Paye Services Limited (collectively referred to as “we”, “us” or “our” in these terms). We are registered in England and Wales under company number 13099694 and have our registered office and trading address at 24/25 The Shard, 32 London Bridge Street, London SE1 9SG.

To contact us, please email hello@paye.com or telephone our customer service line on 0330 1220 220.

2. BY USING OUR SITE, YOU ACCEPT THESE TERMS

By using our site, you confirm that you accept these terms of use and that you agree to comply with them.

If you do not agree to these terms, you must not use our site.

We recommend that you print a copy of these terms for future reference.

3. THERE ARE OTHER TERMS THAT MAY APPLY TO YOU

These terms of use refer to the following additional terms, which also apply to your use of our site:

• Our Privacy Policy.
• Our Acceptable Use Policy, which sets out the permitted uses and prohibited uses of our site. When using our site, you must comply with this Acceptable Use Policy.
• Our Cookie Policy, which sets out information about the cookies on our site.

4. WE MAY MAKE CHANGES TO THESE TERMS

We amend these terms from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time. If any part of the current version conflicts with a previous version, the current version shall prevail unless we explicitly state otherwise.

5. WE MAY MAKE CHANGES TO OUR SITE

We may update and change our site (or any part of it) from time to time to reflect changes to our products, our users’ needs and our business priorities.

6. WE MAY SUSPEND OR WITHDRAW OUR SITE

Our site is made available free of charge.

We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our site for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.

You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms and conditions and other applicable terms of use and that they comply with them.

Our site is directed to people residing in United Kingdom. We do not represent that content available on or through our site is appropriate for use or available in other locations.

7. YOU MUST KEEP YOUR ACCOUNT DETAILS SAFE

If you choose, or you are provided with, a user identification code, password, or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party.

We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these terms of use.

If you know, or suspect, that anyone, other than you, knows your user identification code or password, you must promptly notify us at the above email address.

8. HOW YOU MAY USE MATERIAL ON OUR SITE

You may access, view, and use our site in a web browser (including any web browsing capability built into other types of software or app) and you may download our site (or any part of it) for caching (this usually occurs automatically).

We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You may print off one copy, and may download extracts, of any page(s) from our site for your personal use and you may draw the attention of others to content posted on our site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences, any graphics or other content from our site separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of content on our site must always be acknowledged.

You must not use any part of the content on our site for commercial purposes without first obtaining a licence to do so from us or our licensors.

If you print off, copy, or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

9. DO NOT RELY ON INFORMATION ON THIS SITE

The content on our site is provided for general information only. It is not intended to amount to advice on which you should rely. Professional or specialist advice should always be obtained before taking, or refraining from, any action relating to the content on our site.

Although we make reasonable efforts to ensure that the content on our site is accurate, complete and to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up to date.

10. WE ARE NOT RESPONSIBLE FOR WEBSITES WE LINK TO

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them.

We have no control over the contents of those sites or resources and accept no liability for the content of third-party websites.

11. USER-GENERATED CONTENT IS NOT APPROVED BY US

This website may include information and materials uploaded by other users of the site, including to bulletin boards and chat rooms. This information and these materials have not been verified or approved by us. The views expressed by other users on our site do not represent our views or values. We accept no liability for the content of information and materials uploaded by other users of our site.

12. HOW TO COMPLAIN ABOUT CONTENT UPLOADED BY OTHER USERS

If you wish to complain about content uploaded by other users please contact us at the above email address.

13. OUR RESPONSIBILITY FOR LOSS OR DAMAGE SUFFERED BY YOU

Whether you are a consumer or a business user:
• We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.
• Different limitations and exclusions of liability will apply to liability arising as a result of the supply of any services to you, which will be set out in our terms and conditions of supply.
If you are a business user:
• We exclude all implied conditions, warranties, representations or other terms that may apply to our site or any content on it.
• We will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising out of or in connection with:
• use of, or inability to use, our site; or
• use of or reliance on any content displayed or included on our site.
• In particular, we will not be liable for:
• loss of profits, sales, business, or revenue;
• business interruption;
• loss of anticipated savings;
• loss of business opportunity, goodwill, or reputation; or
• any indirect or consequential loss or damage.
If you are a consumer user:

• Please note that we only provide our site for domestic and private use. You agree not to use our site for any commercial or business purposes, and we have no liability to you for any loss of profit, sales, business, or revenue, business interruption, loss of anticipated savings, loss of business opportunity, goodwill or reputation or any indirect or consequential loss or damage.
• If defective digital content that we have supplied, damages a device or digital content belonging to you and this is caused by our failure to use reasonable care and skill, we will either repair the damage or pay you compensation.

However, we will not be liable for damage that you could have avoided by following our advice to apply an update available to you free of charge or for damage that was caused by you failing to correctly follow installation instructions or to have in place the minimum system requirements advised by us.

14. HOW WE MAY USE YOUR PERSONAL INFORMATION

We will only use your personal information as set out in our Privacy Notice.

15. WE ARE NOT RESPONSIBLE FOR VIRUSES AND YOU MUST NOT INTRODUCE THEM

We do not guarantee that our site will be secure or free from bugs, viruses and/or malware.

You are responsible for configuring your information technology, computer programmes and platform to access our site. You are responsible for protecting your hardware, software, data and other material from viruses, malware and other internet security risks.

You must not misuse our site by deliberately introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored, or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack or by any other means.

By breaching these provisions, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities, and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.

16. RULES ABOUT LINKING TO OUR SITE

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.

You must not establish a link to our site in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

You must not establish a link to our site in any website that is not owned by you.

Our site must not be framed or embedded on any other site, nor may you create a link to any part of our site other than the home page.

We reserve the right to withdraw your linking permission without notice.

The website in which you are linking must comply in all respects with the content standards set out in our Acceptable Use Policy

.If you wish to link to or make any use of content on our site other than that set out above, please contact us at the above email address.

17. WHICH COUNTRY’S LAWS APPLY TO ANY DISPUTES?

If you are a consumer, please note that these terms of use, their subject matter and their formation and our relationship with you, are governed by and construed in accordance with English law. We both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

If you are a business, these terms of use, their subject matter and their formation (and any non-contractual disputes or claims) and our relationship with you are governed by and construed with, English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

Website acceptable use policy

PLEASE READ THE TERMS OF THIS POLICY CAREFULLY AND ENSURE THAT YOU UNDERSTAND THEM BEFORE USING THIS SITE

INTRODUCTION

This acceptable use policy sets out standards that apply when you make contact with other users on www.paye.com (“our site”) link to it or interact with our site in any other way.

WHAT’S IN THIS POLICY?

This acceptable use policy includes the following sections to help you understand the rules for using our site www.paye.com
1. Who we are and how to contact us
2. By using our site, you accept these terms
3. There are other terms that may apply to you
4. We may make changes to the terms of this policy
5. Prohibited uses
6. Interactive standards
7. Content standards
8. Breaches of this policy
9. Which country’s laws apply to any disputes?

1. WHO WE ARE AND HOW TO CONTACT US

www.paye.com is a site operated[1] by Paye Services Limited (collectively referred to as “we”, “us” or “our” in this policy).

We are registered in England and Wales under company number 13099694 and have our registered office and trading address is at 24/25 The Shard, 32 London Bridge Street, London SE1 9SG. [2]

To contact us, please email hello@paye.com or telephone our customer service line on 0330 1220 220.

2. BY USING OUR SITE, YOU ACCEPT THESE TERMS

By using our site, you confirm that you accept the terms of this policy and that you agree to comply with them.

If you do not agree to these terms, you must not use our site.

We recommend that you print a copy of these terms for future reference.

3. THERE ARE OTHER TERMS THAT MAY APPLY TO YOU

Our Website Terms and Conditions also apply to your use of our site.

4. WE MAY MAKE CHANGES TO THE TERMS OF THIS POLICY

We amend this policy from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time.

If any part of the current version conflicts with a previous version, the current version shall prevail unless we explicitly state otherwise.

5. PROHIBITED USES

You may use our site only in a lawful manner for lawful purposes. You must not use our site:
• In any way that breaches any applicable local, national, or international law or regulation.
• In any way that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect.
• For the purpose of harming or attempting to harm minors in any way.
• To bully, harass, threaten, insult, intimidate, embarrass or humiliate any person.
• Or communicate in any way using our site, that does not comply with our content standards set out below.
• To knowingly send, upload or transmit, or procure the sending of, any unsolicited or unauthorised advertising or
promotional material or any similar material (spam).
• To knowingly transmit any data, send or upload any material that contains any form of virus, Trojan horse, worm, time-bomb, keystroke logger, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware or data of any kind.
You also agree:
• Not to reproduce, duplicate, copy or re-sell any part of our site in contravention of the provisions of our Website Terms and Conditions.
• Not to access without authority, interfere with, damage or disrupt:
• any part of our site;
• any equipment or network on which our site is stored;
• any software used in the provision of our site; or
• any equipment or network or software owned or used by any third party.

6. INTERACTIVE SERVICES

We may from time to time provide interactive services on our site, including, without limitation:
• Chat rooms.
• Bulletin boards.
• Member’s login
Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).

We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our site, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks.

However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

Minors may not use the interactive services provided on our site.

Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.

7. CONTENT STANDARDS

These content standards apply to any communication via, interaction with and all material which you contribute to, our site (Contribution).

The Content Standards must be complied with in spirit as well as to the letter. The standards apply to each part of any Contribution as well as to its whole.

We will determine, in our discretion, whether a Contribution breaches the Content Standards.
A Contribution must:
• Be accurate (where it states facts).
• Be genuinely held (where it states opinions).
• Comply fully with all and any applicable local, national and international laws and regulations.

A Contribution must not:
• Be defamatory of any person.
• Be obscene, offensive, hateful, or inflammatory.
• Bully, insult, intimidate or humiliate.
• Promote or be sexually explicit material.
• Promote violence.
• Promote discrimination or be defamatory of any person, group or class of persons based on race, gender, gender identity, religion, nationality, disability, sexual orientation, or age.
• Infringe or assist infringement of any copyright, database right or trademark of us or any other person.
• Be likely to deceive any person.
• Breach any legal duty owed to a third party, such as a contractual duty or a duty of confidence.
• Promote any illegal activity.
• Be in contempt of court.
• Be threatening, abuse or invade another’s privacy, or use their personal information in a way that you do not have the right to.
• Intend or be likely to harass, upset, embarrass, alarm, or annoy any other person.
• Impersonate any person or misrepresent your identity or affiliation with any person.
• Give the impression that the Contribution emanates from Paye Services Limited or any other party if that is not the case.
• Advocate, promote, incite any party to commit, or assist any unlawful or criminal act such as (by way of example only) copyright infringement or computer misuse.
• Contain a statement which you know or believe, or have reasonable grounds for believing, that members of the public to whom the statement is, or is to be, published are likely to understand as a direct or indirect encouragement or other inducement to the commission, preparation, or instigation of acts of terrorism.
• Contain any advertising or promote any services or web links to other sites.

8. BREACH OF THIS POLICY

When we consider that a breach of this policy has occurred, we may take such action as we deem appropriate.
Failure to comply with this policy constitutes a material breach of the terms of use upon which you are permitted to use our site, and may result in our taking all or any of the following actions:
• Immediate, temporary, or permanent withdrawal of your right to use our site.
• Immediate, temporary, or permanent removal of any Contribution uploaded to our site.
• Issue of a warning to you.
• Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.
• Further legal action against you.
• Disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by
law.

We exclude any and all liability for and arising from all action we may take in response to breaches of this acceptable use policy. The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate.

9. WHICH COUNTRY’S LAWS APPLY TO ANY DISPUTES?

If you are a consumer, please note that the terms of this policy, its subject matter and its formation and our relationship with you are governed by and construed in accordance with, English law. We both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

If you are a business, the terms of this policy, its subject matter, and its formation (and any non-contractual disputes or claims) and our relationship with you are governed by and construed in accordance with, English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

Modern Anti-Slavery and Human Trafficking Statement

This Anti-Modern Slavery and Human Trafficking statement sets out commitment to ensuring that such is not accepted, permitted or facilitated in our society, in any form.

INTRODUCTION

This Anti-Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 23 March 2021 to 22 March 2022.

The statement sets down the commitment of Paye Services Limited (referred to as “we”, “us” or “our” in this statement), to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.

WHAT’S IN THIS STATEMENT?

This statement includes the following sections:

1. Organisational Structure and Supply Chains

2. Training

3. Policies

4. Due Diligence Processes

5. Performance Indicators

1. ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS

Paye Services Limited operates a site paye.com and is a company limited by shares, registered in England and Wales under company number 13099694 with our registered office and trading address at 24/25 The Shard, 32 London Bridge Street, London SE1 9SG. This statement covers our business activities.

We are an employment business and we provide employment and payroll services to workers who undertake assignments to deliver services to end-clients. The Company currently operates in the UK.

Our supply chain consists of agencies via whom assignments are sourced and end clients from whom assignments may be sourced directly. In both scenarios, binding agreements are entered into setting out the assignment details including duration and fee.

Responsibility for the Company’s anti-slavery initiatives is as follows:

1.1 Policies: The Sales and Operations Director is responsible for creating and reviewing policies. The process by which policies are developed is looking at best and industry practice and adapting to our needs.

1.2 Risk assessments: The Sales and Operations Director is responsible for risk assessments in respect of human rights and modern anti-slavery by a process of an annual review of processes and procedures and the practical impact of our activities on our workers, suppliers and customers.

1.3 Due diligence: Sales and Operations Director is responsible for due diligence in relation to known or suspected instances of modern anti-slavery and human trafficking.

2. TRAINING

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, all staff are required to renew their training annually to ensure increase awareness of the issues and to act as a reminder to look out for and how to identify, modern anti-slavery practices.

3. POLICIES

We are committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms our intention to act ethically in our business relationships.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

2.1 Whistleblowing policy - we encourage all our workers, customers, business partners and others to report any concerns related to our direct activities or our supply chains without fear of recrimination.

2.2 Corporate Social Responsibility (CSR) Policy - The Company’s CSR policy summarises how we work responsibly with suppliers and local communities.

4. DUE DILIGENCE PROCESSES

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes:

  • checking the identity and business details of clients and agencies;
  • building long-standing relationships with suppliers and making clear our expectations of business partners;
  • and evaluating the modern anti-slavery and human trafficking risks of each new supplier and client;
  • introducing contractual requirements to ensure that those we contract with also respect the principle of and implement measures with a view to combating modern slavery.

5. PERFORMANCE INDICATORS

The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains:

  • use of labour monitoring and payroll systems;
  • providing National Living Wage or National Minimum Wage, as appropriate;
  • providing paid holiday entitlement and access to full employment rights for workers; and
  • requiring agencies and direct end-clients to afford rights to workers as required by law.

This Modern Slavery and Human Trafficking Statement will be reviewed annually and updated, as necessary. The board of directors endorses this policy statement and is fully committed to its implementation.

This Modern Slavery and Human Trafficking Statement has been approved and authorised by:

Name: Simon Whitehead

Position: Sales and Operations Manager

Date: 23 03 2021

Anti-Bribery & Corruption Policy

PLEASE READ THE TERMS OF THIS POLICY CAREFULLY AND ENSURE THAT YOU UNDERSTAND THEM BEFORE USING THIS SITE

INTRODUCTION

This anti-bribery and corruption policy sets out standards that apply when working with or for Paye Services Limited (referred

to as "we", "us", "our" in this policy), in any way.

WHAT’S IN THIS POLICY?

This anti-bribery and corruption policy includes the following sections.

1. About this policy

2. Scope

3. Purpose

4. What are bribery and corruption?

5. What you must not do

6. Facilitation Payments and Kickbacks

7. Gifts, hospitality and expenses

8. Donations

9. Record Keeping

10. Your responsibilities

11. How to Raise a Concern

12. Protection

13. Training and Communication

14. Breaches of this Policy

15. Potential Risk Scenarios: “Red Flags”

1. ABOUT THIS POLICY

1.1 It is our strict policy to conduct all of our business in an honest and ethical manner and we take a zero-tolerance approach to bribery and corruption, whether under UK law or under the law of any foreign country.

1.2 We are committed to acting ethically, fairly, professionally and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure bribery and corruption is not taking place anywhere within our own business or in any of our external business arrangements.

1.3 We are also committed to ensuring there is transparency in our own business and in our approach to tackling bribery and corruption when dealing with any third party, consistent with our disclosure obligations under the Bribery Act 2010. We expect the same high standards from all of our external business partners so, as part of our contracting processes, we include specific prohibitions against bribery and corruption, and we expect those that we deal with to hold their own external business partners to the same high standards.

1.4 Making an authorised and lawful payment for the supply of business will not be considered bribery or corruption if the arrangement is conducted in accordance with commission schemes and does not breach any related policies.

1.5 Bribery and corruption requires the intention to offer and or receive an improper advantage by making an unlawful payment or offer to do something so that the recipient acts improperly by, for example, providing a commercial advantage or more favourable treatment than would have otherwise been provided but for a bribe.

1.6 We will uphold all laws relevant to countering bribery and corruption, including the Bribery Act 2010.

1.7 Unless otherwise stated, the interpretation and application of this policy applies to any bribery and corruption activity in the UK and any foreign country.

2. PURPOSE

2.1 The purpose of this policy is to:

(a) set-out our responsibilities, and of those working for us and any third party, in observing and upholding our position on bribery and corruption;

(b) ensure that any payments that we make to third parties are not in breach of this policy; and

(c) provide information and guidance to those working for us and any third party on how to recognise and deal with bribery and corruption issues.

2.2 If we fail to prevent those working for us and any third-party facilitating bribery and corruption, we can face criminal sanctions including an unlimited fine, as well as exclusion from public contracts, damage to our reputation and individuals can be imprisoned. We therefore take our legal responsibilities seriously.

2.3 We have identified that the following are particular risks for our business:

(a) a recruitment agency offers to exclusively refer its clients to us on the basis that we pay a fee to it;

(b) a recruitment agency offers to refer its clients to us on the basis that we provide an improper service;

(c) we propose (a) or (b) above to a recruitment agency;

(d) gifts and hospitality could be offered and received that are in excess of what is considered acceptable and in breach of our Gifts and Hospitality Policy; or

(e) a conflict of interest might arise that might result in the potential for bribery or a suspicion of it when members of staff have a close personal or professional relationship with third parties

2.4 To address those risks we have taken the following steps to ensure that we never offer, promise, demand, give or receive any form of bribe in return for business or commercial advantage; or any other type of favourable:

(a) our internal policies specifically prohibit the above;

(b) our internal training processes specifically prohibit the above;

(c) all proposed arrangements for payments are reviewed by our compliance manager before being agreed; and

(d) all arrangements for payments are reviewed every three months by our compliance manager.

2.5 In this policy, third party means any individual or organisation you or we come into contact with during the course of our business, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisers, representatives and officials, politicians and political parties.

3. SCOPE

3.1 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.

3.2 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

3.3 The compliance manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption.

3.4 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.

3.6 This policy will be reviewed by the board at least on an annual basis to ensure it fully complies with our ethical and legal duties and is fit for purpose.

4. WHAT ARE BRIBERY AND CORRUPTION?

4.1 Bribery is offering, promising, giving or accepting any financial or other incentive, to induce the recipient or any other associated person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the financial or other incentive.

4.2 An advantage includes money, gifts, loans, fees, hospitality, services, discounts, and the award of a contract or anything else of value.

43 A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.

4.4 Corruption is the abuse of entrusted power or position for private gain.

5. WHAT YOU MUST NOT DO

5.1 It is not acceptable for you (or someone on your behalf) to:

(a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that an unfair business advantage will be received, or to reward an unlawful business advantage already given;

(b) give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to unduly influence the outcome;

(c) accept a payment, gift or hospitality from a third party that you know or suspect is offered with the expectation that it will provide a business advantage for them or anyone else in return;

(d) accept hospitality from a third party that is unduly lavish or extravagant under the circumstances;

(e) offer or accept a gift to or from government officials or representatives, or politicians or political parties, without the prior approval of the compliance manager;

(f) threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy; or

(g) engage in any other activity that might lead to a breach of this policy.

6. FACILITATION PAYMENTS AND KICKBACKS

6.1 We do not make, and will not accept, facilitation payments or “kickbacks” of any kind.

6.2 Facilitation payments, also known as “back-handers” or “grease payments”, are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). They are not common in the UK, but are common in some other jurisdictions.

6.3 Kickbacks are typically payments made in return for a business favour or unfair advantage.

6.4 You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted.

6.5 If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the services provided. You should always ask for an invoice which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the compliance manager.

7. GIFTS, HOSPITALITY AND EXPENSES

7.1 This policy allows reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of:

(a) establishing or maintaining good business relationships;

(b) improving or maintaining our image or reputation; or

(c) marketing or presenting our products and/or services effectively.

7.2 The giving and accepting of gifts is allowed if the following requirements are met:

(a) it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;

(b) it is given in our name, not in your name;

(c) it does not include cash or a cash equivalent (such as gift certificates or vouchers);

(d) it is appropriate in the circumstances, taking account of the reason for the gift, its timing and value. For example, in the UK it is customary for small gifts to be given at Christmas;

(e) it is given openly, not secretly; and

(f) it complies with any applicable local law.

7.3 Promotional gifts of low value such as branded stationery to or from third parties will usually be acceptable.

7.4 Reimbursing a third party’s expenses, or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery. However, a payment in excess of genuine and reasonable business expenses (such as the cost of an extended hotel stay) is not acceptable.

7.5 We appreciate that practice varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justifiable given the services involved in the arrangement. The intention behind it should always be considered.

8. DONATIONS

8.1 If we make contributions to political parties they will never be made in an attempt to influence any decision or gain a business advantage, and are always publicly disclosed.

8.2 If we make charitable donations they will be legal and ethical under local laws and practices.

8.3 No contributions or donation must be offered or made without the prior approval of the compliance manager.

9. RECORD-KEEPING

9.1 We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

9.2 We must keep a written record of all gifts and hospitality provided or received in our Gifts and Hospitality register, which will be subject to review by the board.

9.3 Any attempted bribes must be reported without delay to the compliance manager for him to record in the Attempted Bribery Register and an internal investigation will be commenced.

9.4 You must submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our Expenses Policy within the Staff Handbook and record the reason for expenditure.

9.5 All accounts, invoices, and other records relating to dealings with third parties should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

10. YOUR RESPONSIBILITIES

10.1 You must ensure that you read, understand and comply with this policy.

10.2 The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

10.3 You must notify the compliance manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business. Further “red flags” that may indicate bribery or corruption are set out in Clause 4.12.

11. HOW TO RAISE A CONCERN

11.1 You are encouraged to raise concerns about any issue or suspicion of bribery or corruption in any parts of our business or supply chains of any supplier tier at the earliest possible stage with the compliance manager.

11.2 If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify the compliance manager as soon as possible.

11.3 If you are unsure about whether a particular act constitutes bribery or corruption, raise it with the compliance manager and you are referred to our Whistleblowing Policy.

12. PROTECTION

12.1 Individuals who refuse to accept or offer a bribe, or who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness by the use of our Whistleblowing Policy and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

12.2 We are committed to ensuring no one suffers any detrimental treatment as a result of:

(a) refusing to take part in, be concerned in, or facilitate bribery or corruption;

(b) refusing to aid, abet, counsel or procure the commission of bribery or corruption; or

(c) reporting in good faith their suspicion that an actual or potential bribery or corruption has taken place, or may take place in the future.

12.3 Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately.

13. TRAINING AND COMMUNICATION

13.1 Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary. Such training may form part of wider financial crime detection and prevention training.

13.2 We will ensure that mandatory training on this policy is offered to those employees, workers and associated persons who have been identified as being at risk of exposure to corruption and bribery, at least once every year.

13.2 Our zero-tolerance approach to bribery and corruption must be communicated to all third parties at the outset of our business relationship with them and as appropriate thereafter.

14. BREACHES OF THIS POLICY

14.1 Breaches of this policy by employees will result in disciplinary action which could result in dismissal for misconduct or gross misconduct.

14.2 We may terminate our relationship with third parties working with us if they breach this policy.

14.3 Breaches of this policy may require investigation to the extent permitted by data protection laws and referral to external authorities for further investigation that may result in sanctions including criminal prosecution.

15. POTENTIAL RISK SCENARIOS: “RED FLAGS”

15.1 The following is a list of possible red flags that may arise during the course of you working for or with us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.

15.2 If you encounter any of these red flags while working for or with us, you must report them promptly to the compliance manager:

(a) you become aware that a third party engages in, or has been accused of engaging in, improper business practices;

(b) you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign government officials;

(c) a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;

(d) a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;

(e) a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;

(f) a third party requests an unexpected additional fee or commission to “facilitate” a service;

(g) a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;

(h) a third party requests that a payment is made to “overlook” potential legal violations;

(i) a third party requests that you provide employment or some other advantage to a friend or relative;

(j) you receive an invoice from a third party that appears to be non-standard or customised;

(k) a third party insists on the use of side letters or refuses to put terms agreed in writing;

(l) you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;

(m) a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us; or

(n) you are offered an unusually generous gift or offered lavish hospitality by a third party.

Corporate Social Responsibility Statement

This Corporate Social Responsibility statement sets out our commitment to sustainable management of our business for the benefit of our communities and the environment.

WHAT’S IN THIS STATEMENT?

This statement includes the following sections:

1. Who we are and how to contact us?

2. Introduction

3. Staff/People

4. Customers

5. Suppliers

6. Health and Safety

7. Environment

8. The Community

1. WHO WE ARE AND HOW TO CONTACT US

www.paye.com is a site operated operated[1] by Paye Services Limited (collectively referred to as “we”, “us” or “our” in this policy). We are registered in England and Wales under company number 13099694 and have our registered office and trading address is at 24/25 The Shard, 32 London Bridge Street, London SE1 9SG.

To contact us, please email hello@paye.com or telephone our customer service line on 0330 1220 220.

2. INTRODUCTION

We are an employment business and we provide employment and payroll services to workers. Those workers undertake assignments to deliver services to end-clients. The Company currently operates in the UK. The prosperity of our business and of the communities within which we operate requires a commitment to the sustainable management of our activities. We have therefore developed a policy that affects and enhances all areas of our business. We wish to adopt and commit to the principles and practices set out below.

3. STAFF/PEOPLE

We are committed to the well-being and continual development of our people and to training our workforce, where employees are appreciated, valued and given regular feedback so that each employee has a clear understanding of their role and how they contribute to the business.

We operate a meritocracy, where all employees are recognised and rewarded on the basis of their performance, effort, contribution and achievements.

We expect our employees to act with integrity towards one another and exercise a high standard of business practice and workmanship.

We support diversity, fairness and equal opportunities and aim to involve and consult regularly with employees as to the direction of the business.

4. CUSTOMERS

We aim to build long term relationships with all our customers and other stakeholders by understanding their objectives as they evolve over time and meeting their needs.

We aim to give fair value, consistent quality and reliability.

We aim to have the highest professional and ethical standards and will be honest, open and transparent in all our dealings with customers.

5. SUPPLIERS

We aim to create and maintain strong relationships with key suppliers and contractors.

We aim to choose suppliers that share our ethos in relation to employment practices, quality and environmental controls. This will be communicated to all suppliers and potential suppliers.

6. HEALTH & SAFETY

We aim to achieve and maintain the highest standards of health and safety and provide a safe and healthy working environment for all our activities.

We have a current and effective written health and safety policy that is regularly reviewed and updated.

7. ENVIRONMENT

We have implemented an environmental policy appropriate to our business. We strive to operate on a paperless basis and to allow access to homeworking to reduce the environmental impact of transport use by our employees.

We are aware of our environmental impact as a business and have taken and continue to take appropriate steps to mitigate that impact, including implementing procedures and providing training so employees and contractors understand their environmental responsibilities and can seek to improve our environmental performance.

8. THE COMMUNITY

We recognise and understand the significance of the local community within which we operate. We aim to enhance our contribution to the community by being sensitive to the needs of local people and groups and promoting ethical and socially responsible trading. We actively support and donate to charities/non-profit organisations within our community.