Policy Statement

AESN Limited (“the Company”) is committed to conducting all of our business dealings in an honest and ethical manner. We take a zero-tolerance approach to the facilitation of tax evasion, whether under UK law or under the law of any foreign country.

We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships wherever we operate. We will uphold all laws relevant to countering tax evasion, including the Criminal Finances Act 2017.

Purpose and Scope

The purpose of this policy is to:

1. Set out our responsibilities, and of those working for us, in observing and upholding our position on preventing the criminal facilitation of tax evasion.
2. Provide information and guidance to those working for us on how to recognize and avoid tax evasion.

Scope: This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term, or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us (collectively referred to as “Associated Persons”).

What is Tax Evasion?

For the purposes of this policy:

• Tax Evasion means the offence of cheating the public revenue or fraudulently evading UK tax (or foreign tax). This involves a deliberate and dishonest action to stop tax being paid.
• Tax Evasion Facilitation means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax by another person.

Under the Criminal Finances Act 2017, a separate criminal offence is automatically committed by a corporate entity where the tax evasion is facilitated by a person acting in the capacity of an “associated person” to that body.

Your Responsibilities

It is not acceptable for you (or someone on your behalf) to:

• Engage in any form of facilitating tax evasion or foreign tax evasion.
• Aid, abet, counsel, or procure the commission of a tax evasion offence by another person.
• Fail to promptly report any request or demand from any third party to facilitate the fraudulent evasion of tax.
• Engage in any other activity that might lead to a breach of this policy.
• Threaten or retaliate against another individual who has refused to commit a tax evasion offence or who has raised concerns under this policy.

Recruitment-Specific Risks (Red Flags)

As a recruitment and staffing business, we must be vigilant regarding specific industry risks. You must report any of the following “Red Flags” to the Compliance Officer immediately:

• Umbrella Companies: A candidate or umbrella company suggests a scheme where a loan, grant, or credit is paid instead of salary (often called “Loan Charge” schemes).
• Cash Payments: A request for payment in cash or to an account not in the name of the worker/supplier.
• Offshore Requests: A request to pay an entity or individual into an offshore bank account or tax haven.¹
• IR35/Off-Payroll: A client or candidate attempts to misclassify a role as “Outside IR35” without a valid Status Determination St²atement (SDS) to avoid tax liabilities.
• VAT Irregularities: A supplier or umbrella company that is not registered for VAT when they clearly should be, or requests that VAT is not charged on an invoice.

Due Diligence

AESN Limited will conduct appropriate due diligence on all “Associated Persons” (including Umbrella

Companies and other intermediaries) before entering into a business relationship.³

• We will only engage with Umbrella Companies that are FCSA accredited or have passed our intern⁴al compliance checks.
• We will ensure all temporary workers have the correct Right to Work and National Insurance documentation.

Reporting a Suspicion

If you have a suspicion that tax evasion or its facilitation has occurred, acts are in progress, or are being considered, you must report it immediately.

Who to Contact:

• Name: Mukesh Sapkota / Manager
• Email: mukesh@aesn.co.uk

Your report will be kept confidential. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in tax evasion or reporting a suspicion in good faith.

Breaches of This Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.

Review

This policy will be reviewed annually by the Board of Directors to ensure it remains effective and compliant with current legislation.  

Approved by Senior Management

 

Date Reviewed and signed: 9th October 2019 Next Review Date: 9th October 2020  Next Review Date: 10th October 2021 Next Review Date: 10th October 2022 Next Review Date: 9th October 2023

Next Review Date: 7th October 2024 Next Review Date: 6th October 2025