Anti-Bribery and Corruption Policy

Global Pathway Partners Ltd. (GP2)
Effective Date: 29/09/2026
Policy Owner: Directors of Global Pathway Partners Ltd.
Review Frequency: Periodically and whenever there is a material change to applicable law or business activities

1. Introduction

Global Pathway Partners Ltd. is committed to conducting its business with integrity, transparency and professionalism. We have zero tolerance for bribery and corruption and expect everyone who works for, represents or conducts business with GP2 to uphold the highest standards of ethical conduct.

This Anti-Bribery and Corruption Policy sets out the standards of conduct expected from our directors, employees, workers, contractors, consultants, representatives, referral partners, suppliers and other third parties acting for or on behalf of GP2.

GP2 is committed to complying with all applicable anti-bribery and anti-corruption laws and regulations, including the UK Bribery Act 2010, where applicable.

2. Purpose

The purpose of this Policy is to:

• prevent bribery, corruption and other forms of improper influence;
• promote honest, ethical and responsible business practices;
• ensure that business decisions are made fairly and without improper influence;
• establish clear standards regarding gifts, hospitality, payments and conflicts of interest;
• support compliance with applicable anti-bribery and anti-corruption laws; and
• provide a clear process for raising concerns about suspected misconduct.

GP2 expects all business relationships to be conducted fairly, transparently and on legitimate commercial grounds.

3. Scope

This Policy applies to all GP2 activities and to anyone acting for or on behalf of GP2, including:

• directors and officers;
• employees and workers;
• contractors and consultants;
• agents, representatives and intermediaries;
• referral and business partners;
• suppliers and service providers; and
• other third parties acting in connection with GP2.

The Policy applies to interactions involving students, prospective students, education providers, referral partners, suppliers, consultants, government or public officials and other individuals or organisations connected with GP2.

Where a third party acts on behalf of GP2, GP2 expects that party to comply with the principles and requirements of this Policy.

4. What Is Bribery and Corruption?

Bribery generally involves offering, promising, giving, requesting or accepting a financial or other advantage with the intention of improperly influencing a person or decision.

A bribe does not have to involve cash. It may include gifts, employment opportunities, travel, entertainment, services, discounts, favours, commissions or other benefits.

Corruption includes the misuse of entrusted authority, position or influence for an improper personal or business advantage.

An improper advantage may constitute a concern even if the offer is refused or the intended outcome is not achieved.

5. Prohibited Conduct

GP2 prohibits bribery and corrupt practices in all forms. No person covered by this Policy may:

• offer, promise, give, request or accept a bribe or improper payment;
• make or accept a payment intended to secure an improper business or regulatory advantage;
• make unofficial facilitation payments to speed up or secure a routine governmental or administrative action;
• use an agent, intermediary, referral partner or other third party to carry out conduct that GP2 could not lawfully undertake itself;
• disguise an improper payment as a commission, marketing expense, business expense, refund, charitable contribution or other legitimate transaction;
• offer employment, travel, accommodation, entertainment, gifts or other benefits for the purpose of improperly influencing a decision;
• make payments or provide benefits to public officials or other persons where doing so would breach applicable law;
• create or maintain undisclosed or inaccurate accounts or records for the purpose of concealing improper payments; or
• knowingly participate in any arrangement designed to circumvent this Policy or applicable anti-bribery laws.

No employee, representative or business partner will be penalised for refusing to participate in bribery or corrupt conduct, even where this may result in the loss of business or another commercial opportunity.

6. Gifts and Hospitality

Reasonable and proportionate gifts and hospitality may be appropriate in legitimate business circumstances. However, they must never be offered or accepted with the intention of improperly influencing a decision or obtaining an improper advantage.

Any gift or hospitality should:

• have a legitimate business purpose;
• be reasonable and proportionate in value and frequency;
• comply with applicable laws and regulations;
• be appropriate in the circumstances;
• not create an expectation of favourable treatment;
• not be offered or accepted during a sensitive decision-making process where it could create an actual or perceived conflict; and
• be recorded or disclosed where required by GP2 procedures.

Cash and cash-equivalent gifts must not be offered or accepted.

Where there is uncertainty about whether a gift or hospitality is appropriate, the individual should seek guidance from GP2 management before proceeding.

7. Facilitation Payments

GP2 does not permit unofficial facilitation payments intended to expedite or secure routine governmental or administrative actions.

If an individual is asked to make such a payment, they should refuse where it is safe and lawful to do so and report the matter to GP2 management as soon as reasonably practicable.

A payment made under an immediate threat to personal safety may require different treatment and should be reported to GP2 as soon as possible.

8. Conflicts of Interest

Individuals working for or representing GP2 must avoid situations where personal, financial, family or other interests could improperly influence, or reasonably appear to influence, their professional responsibilities.

Any actual, potential or perceived conflict of interest should be disclosed promptly to the appropriate GP2 manager or director.

GP2 will assess the circumstances and determine what steps, if any, are required to manage the conflict. Such measures may include changing responsibilities, introducing additional oversight or requiring the individual to withdraw from a particular decision.

9. Third-Party Due Diligence

GP2 recognises that bribery and corruption risks may arise through third parties.

Where appropriate and proportionate to the level of risk, GP2 may conduct due diligence before entering into or continuing a relationship with a third party.

This may include considering:

• the identity and reputation of the third party;
• the nature and purpose of the proposed relationship;
• the services to be provided;
• the proposed payment or commission structure;
• the third party’s ownership and relevant business relationships;
• any connection with public officials;
• the geographic and regulatory environment; and
• other relevant compliance risks.

Contracts and agreements with relevant third parties should, where appropriate, include provisions requiring compliance with applicable anti-bribery and anti-corruption laws.

Payments to third parties must be commercially reasonable, properly authorised and proportionate to legitimate services actually provided.

10. Charitable Contributions, Sponsorships and Donations

Charitable contributions, sponsorships and donations must not be used as a means of obtaining an improper business advantage or influencing a decision.

Any such payment made by or on behalf of GP2 must have a legitimate purpose, be appropriately authorised and be accurately recorded in GP2’s financial records.

11. Political and Public Official Interactions

GP2 does not permit payments, gifts or other benefits to be provided to public officials for the purpose of obtaining an improper advantage.

Where employees or representatives interact with public officials, such interactions must be conducted professionally, transparently and in accordance with applicable laws and GP2 policies.

12. Books, Records and Financial Controls

GP2 is committed to maintaining accurate, complete and transparent financial and business records.

Business payments, referral commissions, discounts, expenses and other financial transactions must be recorded accurately and supported by appropriate documentation.

GP2 prohibits:

• false or misleading accounting entries;
• undisclosed or hidden accounts;
• inaccurate descriptions of transactions;
• incomplete supporting documentation;
• recording an improper payment as a legitimate business expense; or
• any other arrangement intended to conceal the true nature or purpose of a transaction.

For clarity, this Policy does not govern student tuition payments made directly to the relevant education provider. Such payments should follow the applicable arrangements established between the student and the education provider.

13. Raising a Concern

Anyone who becomes aware of, suspects or is asked to participate in conduct that may breach this Policy should raise the concern promptly through GP2’s designated management or compliance contact.

Reports may concern, for example:

• suspected bribery or attempted bribery;
• requests for improper payments;
• undisclosed conflicts of interest;
• suspicious commissions or expenses;
• inappropriate gifts or hospitality;
• concerns involving third-party representatives; or
• attempts to conceal or falsify transactions.

GP2 will treat concerns confidentially to the extent reasonably possible and consistent with applicable law.

GP2 does not tolerate retaliation, victimisation or detrimental treatment against anyone who raises a genuine concern or assists with an investigation in good faith.

14. Investigations and Cooperation

GP2 may investigate concerns or suspected breaches of this Policy where appropriate.

Everyone covered by this Policy is expected to cooperate honestly with reasonable compliance reviews and investigations.

Information relating to an investigation should be handled confidentially and should not be disclosed unnecessarily.

15. Breaches of This Policy

A breach of this Policy may result in appropriate action depending on the circumstances and applicable law.

For employees and workers, this may include disciplinary action, up to and including termination of employment or engagement.

For contractors, suppliers, referral partners or other third parties, GP2 may suspend or terminate the relevant relationship, recover funds where appropriate, seek contractual remedies or refer matters to an appropriate authority.

Serious matters may also be reported to law enforcement or relevant regulatory authorities where required or considered appropriate.

16. Responsibilities

The directors of GP2 have overall responsibility for approving and overseeing this Policy.

Managers and individuals with responsibility for business relationships are expected to support compliance with this Policy and escalate significant concerns appropriately.

Every person within the scope of this Policy has an individual responsibility to:

• understand and follow the Policy;
• act honestly and ethically;
• avoid and disclose relevant conflicts of interest;
• maintain accurate records;
• seek guidance where requirements are unclear; and
• report suspected bribery or corruption promptly.

17. Training and Awareness

Where appropriate to an individual’s role and level of risk, GP2 may provide guidance or training on anti-bribery and anti-corruption requirements.

Individuals are expected to familiarise themselves with this Policy and seek clarification where they are uncertain about their responsibilities.

18. Policy Review

GP2 will review this Policy periodically and whenever there is a material change to its business activities, operating environment or applicable legal and regulatory requirements.

Any amendments will be approved through the appropriate GP2 governance process.

19. Contact

If you have a question about this Policy or wish to report a suspected bribery or corruption concern, please contact GP2 through its designated management or compliance contact:

Global Pathway Partners Ltd.
Website: https://gp2.online/
Compliance Contact: info@gp2.online