Criminal Finance Act Policy

Criminal Finance Act Policy 2017 Statement

At Indigo Group, our commitment to honest and ethical business practices is unwavering. We maintain a zero-tolerance stance against tax evasion facilitation, aligning with both UK and international laws, including the Criminal Finances Act 2017. Upholding these legal standards is integral to our professional conduct, and we expect all those associated with us to fulfil their tax obligations diligently.

We have a comprehensive internal policy that delineates responsibilities, offering guidance on recognising and preventing tax evasion. It details the following key aspects:

  • A Policy Statement: Where we articulate our commitment to conducting business ethically, enforcing a zero-tolerance approach to tax evasion facilitation, and upholding the Criminal Finances Act 2017.

  • Information About The Policy: This section outlines the purpose of the policy, including setting responsibilities for preventing the criminal facilitation of tax evasion and providing information to our workforce on how to recognise and avoid such activities.

  • Who Must Comply With The Policy: This policy applies to all persons associated with us, defining the scope to include employees, directors, officers, contractors, and various other roles.

  • Who Is Responsible for the Policy: Responsibilities are clearly defined, with the Directors overseeing legal and ethical obligations, the compliance manager implementing the policy, and all management levels ensuring their teams understand and comply.

  • Information on What constitutes Tax Evasion Facilitation: A detailed definition of tax evasion, foreign tax evasion, and tax evasion facilitation, referencing the Criminal Finances Act 2017 and emphasising the company’s liability under certain circumstances.

  • What Everyone Must Not Do: Clear guidelines are set on unacceptable activities related to tax evasion facilitation, including engaging in such facilitation, aiding or abetting, failing to report, and threatening or retaliating against whistleblowers.

  • Responsibilities: Employees are obligated to read, understand, and comply with the policy. The prevention, detection, and reporting of tax evasion are highlighted as shared responsibilities among the workforce.

  • Raising a Concern: The policy outlines the procedure for raising concerns about potential tax evasion, encouraging early reporting and clarification of doubtful situations.

  • Protection: This section assures protection for individuals reporting concerns, emphasising the company’s commitment to supporting whistleblowers against detrimental treatment.

  • Training and Communication: Training on the policy is integrated into the induction process, emphasising a zero-tolerance approach to tax evasion and foreign tax evasion. This commitment is communicated to all suppliers, contractors, and business partners.

  • Breaches of This Policy: Clear consequences for policy breaches are outlined, including disciplinary actions that may result in dismissal or termination of relationships with individuals or organisations working on our behalf.

Our dedication to legal and ethical compliance is underscored by the potential disciplinary actions for policy breaches, reinforcing our commitment to transparent and responsible business operations.