In light of the Criminal Finances Act 2017, Tax Return Filer Ltd has adopted a statement of our corporate values on anti-facilitation of tax evasion. It is our policy to conduct all of our business dealings in an honest and ethical manner. The value statement governs all our business dealings and the conduct of all persons or organizations who are appointed to act on our behalf.

We request all our 'associated persons' and all who have, or seek to have, a business relationship with Tax Return Filer Ltd to familiarize themselves with our anti-tax evasion value statement and to act at all times in a way that is consistent with our anti-tax evasion value statement.

Anti-Tax Evasion Value Statement

Tax Return Filer Ltd (the 'Company') has a zero-tolerance approach to all forms of tax evasion under UK law.

Employees and Associates of the Company must not undertake any transactions that:

(a) cause the company to commit a tax evasion offense; or

(b) facilitate a tax evasion offense by a third party who is not an associate of the Company.

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.

At all times, business should be conducted in a manner such that the opportunity for, and incidence of, tax evasion is prevented.

Who Must Comply with This Policy?

This policy applies to all persons working for the Company or any subsidiary company or on our behalf in any capacity, including employees at all levels, directors, officers, and Associates (as defined below), including but not limited to agency workers, seconded workers, volunteers, interns, contractors, external consultants, third-party representatives, and business partners, sponsors, or any other person associated with us, wherever located.

Who Is Responsible for This Policy?

The Company has overall responsibility for ensuring that this policy complies with our legal obligations, and our employees and associates comply with it. This policy is adopted by the Company. It may be varied or withdrawn at any time, in the Company's absolute discretion. Employees in leadership positions are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.

What Is the Facilitation of Tax Evasion?

For the purposes of this policy:

Associates include company contractors or an agent of the Company (other than a contractor) who is acting in the capacity of an agent, or any person who performs services for and on behalf of the Company who is acting in the capacity of a person or business performing such services.

Tax Evasion means an offense of cheating the public revenue or fraudulently evading UK tax and is a criminal offense. The offense requires an element of fraud, which means there must be deliberate action or omission with dishonest intent.

Tax Evasion Facilitation means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax whether UK tax or tax in a foreign country by another person or aiding, abetting, counseling, or procuring the commission of that offense. Tax evasion facilitation is a criminal offense, where it is done deliberately and dishonestly.

Tax evasion is not the same as tax avoidance or tax planning. Tax evasion involves deliberate and dishonest conduct. Tax avoidance is not illegal and involves taking steps, within the law, to minimize tax payable (or maximize tax reliefs).

Tax means all forms of UK taxation, including but not limited to corporation tax, income tax, value-added tax, stamp duty, stamp duty land tax, national insurance contributions (and their equivalents in any non-UK jurisdiction) and includes duty and any other form of taxation (however described).

Company Responsibilities

The Company has completed a risk assessment and has established procedures governing certain transactions with third parties designed to prevent specific areas of possible tax evasion by a third party. The Company is responsible for offering employees appropriate training to understand tax evasion and actions to take to prevent tax evasion. The training program can be requested at any time during employment with Tax Return Filer Ltd.

What Team Members and Associates Must Not Do

Employees and Associates must at all times adhere to the Tax Return Filer Ltd anti-tax evasion value statement and must ensure that they read, understand, and comply with this policy.

It is not acceptable for team members and Associates to:

a) Engage in any form of facilitating Tax Evasion or Foreign Tax Evasion

b) Aid, abet, counsel, or procure the commission of a Tax Evasion offense or Foreign Tax Evasion offense by another person;

c) Fail to promptly report any request or demand from any third party to facilitate the fraudulent Evasion of Tax by another person, in accordance with this policy; or

d) Engage in any other activity that might lead to a breach of this policy; or

e) Threaten or retaliate against another individual who has refused to commit a Tax Evasion offense or a Foreign Tax Evasion offense or who has raised concerns under this policy

f) An offense under the law of any part of the UK consisting of being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax.

Prevention Through Vigilance

There is not an exhaustive list of Tax Evasion opportunities. At a more general level, the best defense against Tax Evasion and facilitation of Tax Evasion remains the vigilance of our employees and Associates and the adoption of a common-sense approach supported by our clear whistleblowing procedure. In applying common sense, team members must be aware of the following:

• Is there anything unusual about the manner in which an Associate of the Company is conducting their relationship with the Company or the third party (usually a customer)?
• Is there anything unusual about the customer's or Associate's conduct or behavior in your dealings with them?
• Are there unusual payment methods?

Unusual payment methods and unusual conduct of third parties with Company Associates can be indicative that a transaction may not be as it seems.

How To Raise a Concern

Our employees have a responsibility to take reasonable action to prevent harm to Tax Return Filer Ltd, and we hold our employees accountable for their actions and omissions. Any actions that breach the Criminal Finances Act and the tax laws of wherever we operate bring harm to The Tax Return Filer Ltd Group and will not be tolerated.

You are responsible for properly following The Tax Return Filer Ltd's policies and procedures. These should generally ensure that all taxes are properly paid. If you are ever asked by anyone either inside or outside our company to go outside our standard procedures, this should be reported without delay, as someone may be attempting to evade tax.

What Happens If the Employee Prefers, For Commercial Reasons, Not to Report Their Suspicions?

This should never happen. If there is any suspicion of any intention to evade tax and the transaction if nevertheless finalized, the Company can be criminally prosecuted, subject to a large fine, and be publicly named and shamed.

What we expect from our clients?

We intend to deal only with the clients and other associated persons who are tax-compliant, and we will not facilitate any transactions or work that seeks to circumvent or abuse UK tax laws. We expect our clients to provide reasonable assistance with our due diligence and to comply with Anti Money Laundering Regulation and other applicable UK legislation.