1. About this policy

CH & Co Catering Group Limited’s (“CH&Co”) policy is to conduct all its business in an honest, ethical and legal manner. CH&Co takes a zero-tolerance approach to any criminal activity including tax evasion committed by any associated persons.

If an associated person of CH&Co (including employees) is found to have facilitated tax evasion, the company could be charged with a criminal offence, bringing the risks of an unlimited fine, reputational damage and repercussions for directors.

  1. What is facilitation of tax evasion?

Tax evasion is any fraudulent activity that intends to divert funds from the public revenue. Basically, meaning tax evasion is the illegal non-payment or underpayment of tax. A facilitation offence will be committed where an individual or entity deliberately and dishonestly facilitates tax evasion.

An example of this would be if a member of staff knowingly facilitated a contractor or supplier’s tax evasion. This may be achieved, for example, through false invoicing or making payments in cash or to different bank accounts than those previously agreed.

CH&Co could be liable under the new offence if it fails to prevent the individual or entity, who was acting for or on behalf of the company at the time, from facilitating the tax evasion. The group’s defence is that it has reasonable prevention procedures in place to prevent the facilitation from taking place.

  1. Who is covered by this policy?

The legislation applies to “associated persons”. Associated persons can be an individual or a corporate; this covers employees, agents and any other person performing services on CH&Co’s behalf.

This policy is aimed at every individual who works for or provides services on behalf of CH&Co.

  1. Your responsibilities

You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of instances of facilitation of tax evasion are the responsibility of all those working for or providing services on behalf of CH&Co.

  1. Training

Online training will be provided on our e-learning platform for all staff members.

  1. How to Raise a Concern

If a member of staff has a concern about tax evasion or the facilitation of tax evasion, they should normally first raise the issue with their immediate superior. This may be done orally or in writing.

If a member of staff feels unable to raise the matter with their immediate superior, for whatever reason, they should raise the matter with their Manager and/or the Finance Director.

If a member of staff is in any doubt about how to report suspicions, they should follow the whistleblowing Policy or speak with the Finance Director.

  1. How CH&Co will Handle the Matter

Once a member of staff has raised a concern, CH&Co will look into it to assess initially what action should be taken.  This will usually involve making internal enquiries first, but it may be necessary to carry out an investigation at a later stage, which may be formal or informal depending on the nature of the concern raised.

If a member of staff is found to have deliberately and dishonestly facilitated tax evasion, action will be taken by CH&Co in accordance with the firm’s disciplinary procedures. CH&Co may also be required to report the matter externally and there may be other legal implications for the member of staff as a result.

  1. Review of Policy

This policy will be reviewed by the directors of CH&Co annually.