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In the light of Criminal Finances Act 2017, At All Time Security we have adopted a statement of our corporate value 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 organisations who are appointed to act on our behalf.
We request all our team members and all who have, or seek to have, a business relationship with our business, to familiarise themselves with our anti-tax evasion value statement and to act at all times in a way which is consistent with our anti-tax evasion value statement.
We have a zero-tolerance approach to all forms of tax evasion, whether under UK law or under the law of any foreign country.
Staff must not undertake any transactions which:
(a) cause the Company to commit a tax evasion offence; or
(b) facilitate a tax evasion offence 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.
This policy applies to all persons working for the Company or on our behalf in any capacity, including team members at all levels, directors, officers and Associates (as defined below), including but not limited to agency workers, seconded workers, contractors, external consultants, third-party representatives and business partners or any other person associated with us, wherever located.
The Managing Director has overall responsibility for ensuring that this policy complies with our legal obligations, and our team members 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 It may be varied or withdrawn at any time, in the Company’s absolute discretion. Team members in leadership positions are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate training on it.
For the purposes of this policy:
Associates includes company team members or an agent of the Company (other than a team member) 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 offence of cheating the public revenue or fraudulently evading UK tax, and is a criminal offence. The offence 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, counselling or procuring the commission of that offence). Tax evasion facilitation is a criminal offence, 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 minimise tax payable (or maximise 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).
The Company has established procedures governing certain transactions with third parties designed to prevent specific areas of possible tax evasion by a third party.
Team members and Associates must at all times adhere to the 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:
There is not an exhaustive list of Tax Evasion opportunities. At a more general level, the best defence against Tax Evasion and facilitation of Tax Evasion remains the vigilance of our team members 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:
Unusual payment methods and unusual conduct of third parties with Company Associates can be indicative that a transaction may not be as it seems – please refer to the Company’s ‘Anti-money Laundering and Counter Terrorism Financing Policy’ for examples of unusual payment methods and unusual conduct. Likewise, the Company procedures outlined in the aforementioned policy for identifying the customer are also an important part of the Company’s policy against tax evasion.
The Company maintains a policy of “stand up, speak up” in relation to any concerns. Team members are encouraged to raise concerns about any issue or suspicion of Tax Evasion or Foreign Tax Evasion as soon as possible. If there is any suspicion of any intention that a team member or Associate or third party is attempting to, or committing Tax Evasion or Foreign Tax Evasion, the details of the parties and the transaction must be reported to the Managing Director who will report the circumstances to HMRC.
This should never happen. If there is any suspicion of any intention to evade tax and the transaction if nevertheless finalised, the Company can be criminally prosecuted, subject to a large fine and be publically named and shamed.