25/ Anti-facilitation of Tax Evasion

INTRODUCTION

Integrity and transparency are of utmost importance to us and so we conduct our business to the highest legal and ethical standards. We are aware of the laws in place relating to tax evasion, including the Criminal Finances Act 2017, and take our responsibilities seriously. We understand that failure to prevent the facilitation of tax evasion undertaken by representatives of the Company renders the Company liable to criminal sanctions including an unlimited fine.

This policy applies to our entire direct workforce and also those who work on behalf of us or provide services to our business including employees, directors, workers including agency workers, volunteers, contractors, consultants and any other party with whom the Company does business.

WHAT IS TAX EVASION?

Tax evasion is the practice of using illegal methods to avoid paying tax.  It involves deliberate and dishonest conduct and is not the same as tax avoidance. It frequently involves contrived, artificial transactions that serve no purpose other than to reduce tax liability.

Indicators of tax evasion are (non-exhaustive list):

●   request for payment by cash;

●   overly-complex payment mechanisms;

●   transactions involving overly complex supply chains;

●   transactions involving private banking facilities;

●   incomplete or non-standard invoices or other records relating to the payment of tax;

●   making false statements in relation to the payment of tax or failure to register with relevant bodies tasked with ensuring tax compliance;

●   failure to register for VAT;

●   any individual or supplier asking to be paid gross when they should be paid net

OUR STANCE ON THE FACILITATION ON TAX EVASION

Tax evasion and facilitating the evasion of tax are criminal offences. Both acts will damage Reprotec UK’s reputation and the confidence of our customers, suppliers and business partners.

Reprotec UK will not be party to tax evasion or the facilitation of tax evasion of any form. We take a zero-tolerance approach to the facilitation tax evasion. We are committed to:

●   rejecting the facilitation of tax evasion; and

●   not recommending the services of others who do not have reasonable prevention procedures in place.

YOUR RESPONSIBILITIES

It is strictly prohibited for any employee or person working on our behalf or in connection with us to take part in any activity, directly or indirectly, relating to tax evasion or its facilitation.

You must not:

●   undertake any action which facilitates tax evasion

●   aid or abet any action of tax evasion

You are required to report any behaviour which reasonably leads you to believe that tax evasion or the facilitation of tax evasion is occurring in any way which is connected to Reprotec UK.

If we have reason to believe that you have breached any obligation placed upon you by this policy, action will be taken which is appropriate to our relationship with you. This includes the instigation of a disciplinary procedure, or the termination of our business arrangement with you.

REPORTING CONCERNS

You must notify your manager at the earliest stage if you suspect that tax evasion or the facilitation of tax evasion may be occurring. The failure to report a suspicion, of itself, may constitute an offence of facilitation of tax evasion and therefore we strongly encourage the reporting of concerns.

Any concerns should be reported to the PA to the Directors. An investigation will then be carried out and you may need to give an account of your suspicions including names, dates and any other pertinent information.

You may also report a concern via Reprotec UK’s Whistleblowing policy which is available in the Employee Handbook, or upon request.

DETRIMENT

No individual who reports a concern relating of tax evasion under this policy, or the Whistleblowing policy, will be subject to detriment because of their actions. Additionally, no individual will be subject to detriment because they have refused to take part in any behaviour which is prohibited by this policy.