POLICY STATEMENT

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to the facilitation of tax evasion, whether under UK law or under the law of any foreign country. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter tax evasion facilitation.

2. ABOUT THIS POLICY

2.1 The purpose of this policy is to:

Set out our responsibilities, and of those working for us, in observing and upholding our position on preventing the criminal facilitation of tax evasion; and Provide information and guidance to those working for us on how to recognize and avoid tax evasion. As an employer, if we fail to prevent our employees, workers, agents or service providers facilitating tax evasion, we can face criminal sanctions including an unlimited fine, as well as exclusion from tendering for public contracts and damage to our reputation. We therefore take our legal responsibilities seriously. We have identified that the following are particular risks for our business independent contractors that we instruct to carry out work on our behalf paying their workers or sub-contractors in cash and/or without pay slips or invoices.

To address those risks we have written to all our independent contractors providing them with our policy and requesting by return either a copy of the policy they have in place to comply with the Criminal Finances Act 2017, or that we expect them to immediately adopt this policy. We are also training relevant staff.

2.2 In this policy, third party means any individual or organization you come into contact with during the course of your work for us, 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. This policy does not form part of any employee’s contract of employment, and we may amend it at any time.

3. WHO MUST COMPLY WITH THIS POLICY?

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.

4. WHO IS RESPONSIBLE FOR THE POLICY?

· 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.

· The Financial Controller 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 preventing the facilitation of tax evasion.

· 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.