1: Introduction

1.1 Policy Overview
Redcone Recruitment Limited is committed to conducting all business activities with integrity and in compliance with applicable laws and regulations. The company has zero tolerance for any form of tax evasion, whether by employees, contractors, suppliers, or any other associated parties. This Anti-Tax Evasion Policy sets out Redcone Recruitment Limited’s commitment to preventing the facilitation of tax evasion and complying with the Criminal Finances Act 2017, which makes it a criminal offence for companies to facilitate tax evasion by associated persons.

Tax evasion, or the facilitation of tax evasion, is illegal and unethical. Redcone Recruitment Limited takes its obligations seriously and is committed to upholding the highest standards of ethical conduct in all aspects of its operations, including tax compliance. This policy provides guidelines to ensure that all employees and associated persons are aware of their responsibilities in preventing tax evasion and are compliant with the law.

1.2 Purpose of the Policy
The purpose of this policy is to:

• Prevent any involvement, whether direct or indirect, in tax evasion or the facilitation of tax evasion.
• Ensure that Redcone Recruitment Limited complies with all relevant laws and regulations related to tax, including the Criminal Finances Act 2017.
• Provide clear guidelines and procedures to employees, contractors, and third parties to prevent, detect, and report any activity related to tax evasion.
• Foster a corporate culture of transparency, accountability, and compliance with tax laws.

1.3 Legal Framework
This policy complies with the Criminal Finances Act 2017, which creates corporate offences for the failure to prevent the facilitation of tax evasion, as well as the following legislation:

• Taxes Management Act 1970
• Finance Act 2020
• UK Bribery Act 2010 (where relevant to financial misconduct and corruption)
• Money Laundering Regulations 2017

Under the Criminal Finances Act 2017, businesses can be held criminally liable if they fail to prevent tax evasion by individuals or third parties acting on their behalf.

2: Scope

2.1 Applicability
This policy applies to all employees, contractors, consultants, suppliers, third-party service providers, and any other individuals or organisations associated with Redcone Recruitment Limited. It covers all tax-related matters and business transactions, both within the UK and internationally, including corporate income tax, VAT, payroll taxes, and any other relevant taxes.

2.2 What Constitutes Tax Evasion?

• Tax Evasion: The illegal practice of deliberately avoiding paying taxes owed to the government. This can include underreporting income, inflating expenses, or concealing assets or income streams.
• Facilitation of Tax Evasion: Occurs when a person or company knowingly assists or encourages another person to commit tax evasion, whether through advice, financial arrangements, or misleading documentation.

Examples of tax evasion or facilitation include:

• Misreporting revenue or profits.
• Manipulating accounting records or financial statements to reduce tax liabilities.
• Offering false or fraudulent documentation to tax authorities.
• Facilitating tax evasion by clients, suppliers, or business partners.

3: Policy Details

3.1 Zero Tolerance of Tax Evasion and Its Facilitation
Redcone Recruitment Limited adopts a zero-tolerance approach to tax evasion and the facilitation of tax evasion. All employees, contractors, and third parties must:

• Avoid any involvement in tax evasion or facilitation of tax evasion.
• Comply with all applicable tax laws and regulations, both within the UK and internationally.
• Report any concerns or suspicions of tax evasion immediately, following the procedures outlined in this policy.

3.2 Employee and Third-Party Responsibilities
Employees, contractors, and third parties have a responsibility to ensure that their actions do not facilitate tax evasion. This includes:

• Employees: Ensuring that all financial and business activities comply with tax laws and that no practices are in place to deliberately evade taxes. This includes accurate record-keeping, reporting, and payment of taxes due.
• Contractors, Suppliers, and Third Parties: Any associated persons must also comply with tax laws. Redcone Recruitment Limited will perform due diligence on suppliers and third parties to ensure they operate lawfully and ethically.

3.3 Contracting and Procurement
Redcone Recruitment Limited will:

• Conduct thorough due diligence on all third-party service providers, suppliers, and contractors to ensure they are compliant with tax regulations.
• Incorporate anti-tax evasion clauses in contracts to confirm that suppliers and contractors are aware of and agree to abide by relevant tax laws.
• Refuse to do business with any third parties who are known to engage in tax evasion or unethical financial practices.

3.4 Reporting and Documentation
All financial records, tax filings, and business transactions must be accurately and transparently recorded. This includes:

• Proper documentation of income, expenses, and tax obligations.
• Maintaining accurate records of all financial transactions, including contracts, invoices, receipts, and communications with tax authorities.
• Ensuring that any advice received in relation to tax matters comes from qualified and reputable professionals.

3.5 Gifts and Hospitality
Any gifts, hospitality, or entertainment provided by or received by Redcone Recruitment Limited employees or associated parties must be modest, transparent, and not intended to influence decision-making or facilitate tax evasion. All such transactions must comply with the company’s Anti-Bribery and Corruption Policy.

3.6 Risk Assessment and Due Diligence
Redcone Recruitment Limited will undertake regular risk assessments of its business activities, supply chains, and partnerships to identify areas where there is a risk of tax evasion or facilitation. These assessments will:

• Identify areas of the business that may be vulnerable to tax evasion risks.
• Implement additional controls, where necessary, to mitigate risks.
• Ensure that any third-party relationships are monitored to prevent tax evasion or facilitation by associated persons.

4: Reporting and Whistleblowing

4.1 Reporting Suspicious Activity
Employees, contractors, and third parties are encouraged to report any concerns or suspicions regarding tax evasion or the facilitation of tax evasion to the Compliance Officer or through the company’s Whistleblowing Procedure. All reports will be handled confidentially, and the company will not tolerate any form of retaliation against individuals who raise concerns in good faith.

4.2 Whistleblowing Procedure
Redcone Recruitment Limited has an established whistleblowing procedure to allow employees and third parties to report suspected breaches of this policy. Reports can be made anonymously, and employees are protected from retaliation under the Public Interest Disclosure Act 1998. Concerns may include:

• Evidence or suspicion of tax evasion or its facilitation by employees, contractors, or business partners.
• Inaccuracies or inconsistencies in financial records or reporting that could indicate tax evasion.
• Pressure or encouragement from others to engage in unlawful tax practices.

4.3 Investigation Process
All reports of potential tax evasion or facilitation will be thoroughly investigated. The investigation process will include:

• Conducting an internal audit of relevant financial and business transactions.
• Engaging external auditors or legal professionals where necessary.
• Reporting the matter to relevant tax authorities if illegal activity is confirmed.

5: Training and Communication

5.1 Employee Training
All employees will receive regular training on the prevention of tax evasion and their responsibilities under the Criminal Finances Act 2017. This training will include:

• An overview of relevant tax laws and penalties for tax evasion.
• Guidance on how to identify tax evasion risks and red flags.
• Procedures for reporting concerns or suspicious activity.

5.2 Supplier and Contractor Communication
Suppliers, contractors, and third parties will be informed of their obligations under this policy and the company’s commitment to preventing tax evasion. Contracts will include clear expectations regarding compliance with tax laws, and suppliers will be required to adhere to the same high standards of conduct.

6: Consequences of Policy Violations

6.1 Disciplinary Actions
Any employee found to be involved in tax evasion or facilitating tax evasion will face disciplinary action, which may include:

• Formal warnings or retraining for minor breaches.
• Termination of employment for serious breaches or involvement in illegal activities.

6.2 Third-Party Violations
Redcone Recruitment Limited will terminate contracts with any third-party suppliers or contractors found to be engaging in or facilitating tax evasion. The company will also report any illegal activities to the appropriate authorities.

6.3 Legal Consequences
The company and its employees may face legal penalties under the Criminal Finances Act 2017 if they are found to be involved in or have failed to prevent tax evasion. This may include:

• Significant fines and financial penalties.
• Criminal charges leading to potential imprisonment of individuals involved.
• Reputational damage that could impact the company’s standing and business relationships.

7: Monitoring and Review

7.1 Policy Monitoring
The Compliance Officer will regularly monitor compliance with this policy and ensure that the necessary controls are in place to prevent tax evasion or its facilitation. Internal audits will be conducted to review financial records and transactions, and any discrepancies or concerns will be addressed promptly.

7.2 Policy Review
This Anti-Tax Evasion Policy will be reviewed annually to ensure it remains effective, up to date with current legislation, and relevant to Redcone Recruitment Limited’s business activities. Any updates to the policy will be communicated to all employees, contractors, and relevant stakeholders.

8: Conclusion

Redcone Recruitment Limited is committed to maintaining the highest standards of ethical conduct in all its business dealings, including strict compliance with tax laws and regulations. By adhering to this Anti-Tax Evasion Policy, the company ensures that it operates with integrity, transparency, and accountability. All employees, contractors, and business partners are expected to comply with the principles outlined in this policy, contributing to a fair, ethical, and legally compliant working environment.