The purpose of this policy is to communicate the MAK Integrated Services Limited’s approach to the Corporate Criminal Offence of the Failure to Prevent the Criminal Facilitation of Tax Evasion (“CCO”).
A criminal offence is committed under this legislation where an associated person of MAK Integrated Services Limited (such as an employee, contractor or agent) deliberately and dishonestly facilitates a taxpayer evading tax, and MAK Integrated Services Limited has not put in place reasonable preventative procedures.
Key principles
Ensuring that we have reasonable prevention procedures in place to prevent any person associated with MAK Integrated Services Limited from facilitating tax evasion. Our key procedures comprise:
Obtaining assurances and warranties from suppliers that they have reasonable prevention procedures in place.
Providing training to our staff and being clear about the consequences if a person associated with MAK Integrated Services Limited facilitates tax evasion.
Providing a pathway for reporting wrong doing and providing protection for whistle-blowers in line with the company whistle blowing procedure
Operating existing, and implementing new, procedures which reduce the opportunity for employees to facilitate tax evasion, and regularly reviewing these for effectiveness and improvement.
Adopting a zero-tolerance attitude towards the criminal facilitation of tax evasion.
Where internal investigations indicate a person associated with MAK Integrated Services Limited has facilitated tax evasion, they will be reported to the authorities and MAK Integrated Services Limited will fully support prosecution to the fullest extent of the law.
Not to use the services of others who are unable to provide assurance that they have reasonable prevention procedures in place.
This policy applies to:
This policy applies to all persons associated with MAK Integrated Services Limited, including for employees, contractors, agents, and any person acting on behalf of MAK Integrated Services Limited.
Responsibilities
All persons associated with MAK Integrated Services Limited are responsible for adhering to this policy
All employees / contractors / business partners are responsible for not facilitating tax evasion of taxpayers
Leadership / subject matter teams are responsible for ensuring MAK Integrated Services Limited fulfils its key principles
The Board is responsible for ensuring appropriate policies are in place and creating a corporate culture that supports compliance
