This Vendor Code of Conduct document (Code), and related material, are the property of 9 Payment Service Bank Limited (9PSB). It is a 9PSB propriety document and strictly meant to provide guidance to both the Bank’s employees, vendors and stakeholders.

Violations of the Code will be treated in line with the Bank’s applicable policies.

1.     About the Code

1.1. Introduction

9 Payment Service Bank is committed to maintaining the highest standards of ethical and professional conduct. This Code sets out the minimum standards of behaviour that is expected by organizations, their representatives and employees, and subcontractors (herein referred to as “Vendors”) who provide goods or services to 9PSB . If a Vendor has any questions about this Code, they should seek advice from the 9PSB’s Head of Corporate Services.

1.2. 9 Payment Service Bank’s Values

9PSB’s Values – Collaboration, Leadership, Integrity, Innovation, Passion – guides the way that the 9 Payment Service Bank Group conducts its business. 9PSB seeks out Vendors that provide support in meeting these Values and who maintain the highest ethical standard.

1.3. Key Principles

9PSB expects all its Vendors to adhere to the following key principles:

  • Comply with all applicable laws, regulations and standards.
  • Provide a safe working environment for their employees and those affected by their activities.
  • Have proportionate, up to date and operational business continuity capabilities in place.
  • Refrain from offering gifts and hospitality to Directors, employees or contractors of 9PSB.
  • Maintain the privacy and confidentiality of any information relating to 9PSB, its employees and its customers that a Vendor may receive in their capacity as a Vendor.
  • Maintain appropriate and proportionate cyber security measures to prevent the use of their systems for criminal purpose; and
  • Notify 9PSB of any event or action that causes a breach of this Vendor Code of Conduct or otherwise may affect the good standing of 9PSB.

1.4. Compliance with the Code

The Code addresses a number of situations in which issues related to 9 Payment Service Bank’s reputation or ethics may arise.

It is recognized that the Code cannot cover all situations and Vendors are required to exercise good sense and sound judgement to make the right decision. In applying such judgement, the following should be considered to make the right ethical decision:

  • Do I have all the information that I need to make an informed decision?
  • Is it legal and in keeping with the spirit of the law?
  • Is it consistent with this Code?
  • Could it reflect negatively on my company or 9PSB?
  • How would it look in the media?
  • Does it feel right?

Vendors should inform 9PSB should their business change in a way that may affect the Vendor’s compliance with this Vendor Code of Conduct.

Vendors who enter into a contract agreement with 9PSB will be provided with a copy of this Code. Vendors should understand that non-compliance with this Code may adversely affect their commercial relationship with 9PSB in the future.

2.   Conflicts Management and Business Ethics

2.1 Conflicts Management

It is important that our Vendors avoid situations where the interests of the Vendor or an employee of the Vendor conflicts, or appears to conflict, with the interests of 9PSB or its clients.

A conflict of interest exists, or may be perceived to exist, where a personal, or corporate, circumstance impairs professional judgment or the ability to act in the best interest of 9PSB or its clients.

9PSB expects its Vendors to disclose and manage any actual, potential, or perceived conflicts of interest in relation to their engagement with the Bank.

2.2 Business Ethics

9PSB expects that its Vendors conduct their business in compliance with all applicable laws, rules and regulations of the jurisdictions in which they operate. This includes the expectation that Vendors will:

  • Comply fully with all their obligations in relation to all taxes due within the jurisdictions in which they operate. Vendors must not participate in tax evasion or facilitate tax evasion by others.
  • Have policies and procedures in place designed to prevent and detect fraud, money laundering, bribery & corruption.
  • Follow a practice of “fair competition” and “fair dealing” by not participating in practices such as entering into non-compete agreements (whether formal or informal) to fix prices, allocate markets or clients, boycotting (or refusing to deal with) certain Vendors or clients (unless legally required to do so) or making the provision of a product or service conditional upon their use of 9PSB’s products or services.
  • Not enter into any secret agreement or side arrangement with any 9PSB employee, director or shareholder.
  • Not take any action on behalf of 9PSB that could be perceived as an attempt to bribe, accept a bribe, or engage in corrupt activity.
  • Not use any 9PSB name, or logo, in any advertising, promotional material, press release, client list or similar material without first obtaining written consent from 9PSB.

Raising Concerns

9PSB is committed to integrity, honesty and transparency in everything that it does.

If a Vendor becomes aware, or suspects, violations to this Code or of 9PSB’s policies, standards or procedures, applicable laws or regulations, such Vendor is required to report such violations using the resources described below.

Vendors can raise their concerns through the Bank’s Email:, with the email addressed to: The Chief Compliance Officer, 9 Payment Service Bank.