10.
TRAINING AND COMMUNICATION
10.1
Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary. Such training may form part of wider financial crime detection and prevention training. Our zero-tolerance approach to tax evasion and foreign tax evasion must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate after that.
10.2
11.
BREACHES OF THIS POLICY
11.1
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
11.2
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
12.
POTENTIAL RISK SCENARIOS: "RED FLAGS"
The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns related to tax evasion or foreign tax evasion. The list is not intended to be exhaustive and is for illustrative purposes only.
If you encounter any of these red flags while working for us, you must report them promptly to your manager:
12.1
you become aware, in the course of your work, that a third party has made or intends to make a false statement relating to tax, has failed to disclose income or gains to, or to register with, HMRC (or the equivalent authority in any relevant non-UK jurisdiction), has delivered or intends to deliver a false document relating to tax, or has set up or intends to set up a structure to try to hide income, gains or assets from a tax authority; you become aware, in the course of your work, that a third party has deliberately failed to register for VAT (or the equivalent tax in any relevant non-UK jurisdiction) or failed to account for VAT;
12.2
12.3
a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
12.4
you become aware, in the course of your work, that a third party working for us as an employee asks to be treated as a self-employed contractor, but without any material changes to their working conditions;
12.5
a supplier or other subcontractor is paid gross when they should have been paid net, under a scheme such as the Construction Industry Scheme;
12.6
a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
12.7
a third party to whom we have provided services requests that their invoice is addressed to a different entity, where we did not provide services to such entity directly;
13.
a third party to whom we have provided services asks us to change the description of services rendered on an invoice in a way that seems designed to obscure the nature of the services provided;
13.1
you receive an invoice from a third party that appears to be non-standard or customised;
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