TalaStar Digital Ltd maintains a zero-tolerance position on bribery and corruption in all forms. This policy applies to all persons working for or on behalf of TalaStar Digital, including the founder, any future employees, contractors, consultants, and third-party representatives.
UK Bribery Act 2010 | Companies Act 2006 | Effective: 10 April 2026 | Version 1.0
TalaStar Digital Ltd (Company No. 17060305) is an early-stage technology company currently operated solely by its founder. While the company does not yet have the scale or complexity that typically necessitates a formal anti-bribery programme, we publish this policy voluntarily as a foundational commitment. As the company grows and engages employees, contractors, and international partners, this policy will be expanded with proportionate procedures, training programmes, and monitoring systems. Publishing early demonstrates that ethical governance is built into TalaStar's DNA, not retrofitted after problems arise.
The UK Bribery Act 2010 is one of the strictest anti-corruption statutes in the world. It creates four criminal offences that apply to TalaStar Digital.
Offering, promising, or giving a financial or other advantage to another person to induce or reward improper performance of a function or activity.
Penalty: Up to 10 years' imprisonment and/or unlimited fine
Requesting, agreeing to receive, or accepting a financial or other advantage in connection with the improper performance of a function or activity.
Penalty: Up to 10 years' imprisonment and/or unlimited fine
Bribing a foreign public official to obtain or retain business or a business advantage. No requirement to prove improper performance.
Penalty: Up to 10 years' imprisonment and/or unlimited fine
A commercial organisation failing to prevent bribery by persons associated with it. The only defence is having adequate procedures in place.
Penalty: Unlimited fine for the organisation
These prohibitions are absolute and apply regardless of business pressure, local custom, competitive disadvantage, or the perceived insignificance of the amount involved.
No person acting on behalf of TalaStar Digital shall offer, promise, give, request, or accept any bribe — whether in cash, gifts, favours, hospitality, or any other form of inducement — to or from any person, for the purpose of obtaining or retaining business or a business advantage.
TalaStar Digital does not make or accept facilitation payments of any kind. These are small, unofficial payments made to secure or expedite a routine government action. Such payments are illegal under the UK Bribery Act 2010, regardless of local customs.
No donations — whether political, charitable, or sponsorship — shall be made on behalf of TalaStar Digital for the purpose of obtaining or retaining a business advantage. All charitable activity is conducted through TalaStar Charity Hub with full transparency.
TalaStar Digital does not engage agents, consultants, or intermediaries to perform any act that would be prohibited if performed by TalaStar directly. All third-party relationships are subject to due diligence proportionate to the bribery risk they present.
TalaStar Digital has identified the following areas where bribery risk may arise as the company grows. Each area has proportionate mitigation measures.
Risk
Vendors offering preferential pricing, free services, or gifts in exchange for exclusive contracts
Mitigation
All vendor selections documented with objective criteria. No single person has sole authority over procurement decisions above £500.
Risk
Partners in jurisdictions with higher corruption indices may operate under different norms
Mitigation
Enhanced due diligence for all international partners. Anti-bribery clauses required in all partnership agreements. Right to audit maintained.
Risk
Academic or institutional partners may expect gifts, hospitality, or undisclosed payments
Mitigation
All research collaborations governed by written agreements with transparent terms. No payments outside agreed contract scope.
Risk
Interactions with regulators (FCA, ICO, Companies House) could involve pressure for facilitation payments
Mitigation
All regulatory interactions logged. No payments to government officials outside published fee schedules. Legal counsel consulted for any unusual requests.
Risk
Giving or receiving gifts that could be perceived as inducements
Mitigation
Gifts above £50 in value must be declared and recorded. No gifts to or from anyone in a position to influence a business decision. All hospitality must have a clear business purpose.
Section 7 of the Bribery Act provides a defence if the organisation can demonstrate "adequate procedures" to prevent bribery. TalaStar's due diligence follows four steps.
Before entering any new business relationship, assess the bribery risk based on the country, sector, transaction type, and counterparty profile.
Verify the identity, reputation, and business legitimacy of all counterparties. Check against sanctions lists and adverse media where proportionate.
Include anti-bribery clauses in all contracts. Require counterparties to comply with the UK Bribery Act 2010 or equivalent local legislation.
Review high-risk relationships annually. Investigate any red flags promptly. Maintain records of all due diligence conducted.
Any person who suspects bribery or corruption should report it immediately to the founder at [email protected]. All reports will be treated confidentially and investigated promptly.
View Whistleblowing PolicyIf you are not comfortable reporting internally, or if you believe the matter has not been adequately addressed, you may report to:
TalaStar Digital will not tolerate any form of retaliation against anyone who reports a genuine concern about bribery or corruption in good faith. This protection applies regardless of whether the concern is ultimately substantiated. Reporters are protected under the Public Interest Disclosure Act 1998 (PIDA) and this policy.
Any breach of this policy will be treated as a serious matter. Depending on the severity and circumstances, consequences may include:
Up to and including summary dismissal for employees, or immediate termination of contract for contractors and consultants.
TalaStar Digital will report suspected criminal conduct to the relevant authorities and cooperate fully with any investigation.
Immediate termination of any business relationship where a third party is found to have engaged in bribery or corruption.
This Anti-Bribery & Corruption Policy was approved by the sole director of TalaStar Digital Ltd and will be reviewed annually or whenever a material change in business operations occurs.
Kristal Jane Apurado
Founder & CEO, TalaStar Digital Ltd
Company No. 17060305 | 10 April 2026