Criminal Finances Act 2017: Tax Evasion Facilitation Prevention Policy

1. Introduction and Purpose

Coaley Peak Ltd is committed to the highest standards of legal and ethical conduct. This policy sets out our approach to preventing the facilitation of tax evasion in compliance with Part 3 of the Criminal Finances Act 2017 (the “Act”) and any equivalent legislation in other jurisdictions in which we operate.

The Act created two corporate criminal offences:

• failing to prevent the facilitation of UK tax evasion (section 45); and
• failing to prevent the facilitation of foreign tax evasion (section 46).

A company commits an offence if an “associated person” (an employee, agent, or other person providing services on its behalf) criminally facilitates tax evasion whilst acting in that capacity. The only defence available is demonstrating that reasonable prevention procedures were in place.

2. Scope

This policy applies to all individuals acting on behalf of Coaley Peak Ltd, including:

• directors, officers, and employees;
• contractors, consultants, and agency workers;
• agents, introducers, and other third parties acting on our behalf; and
• any joint venture partners or subsidiaries under our control.

3. What Constitutes Tax Evasion Facilitation

Tax evasion facilitation occurs when an associated person deliberately and dishonestly assists a third party in evading tax, whether in the UK or overseas. This includes but is not limited to:

• assisting a client or counterparty to conceal income, gains, or assets from HMRC or any overseas tax authority;
• structuring transactions in a way that is designed to misrepresent their true nature for tax purposes;
• creating or maintaining false documentation or records intended to deceive a tax authority; or
• advising on arrangements where the primary purpose is illegal tax evasion rather than legitimate tax planning.

This policy does not prohibit lawful tax planning or the provision of legitimate tax advice.

4. Our Zero-Tolerance Position

Coaley Peak Ltd has a zero-tolerance approach to the facilitation of tax evasion. We will not tolerate any associated person facilitating tax evasion on our behalf, whether in the UK or in any other jurisdiction, regardless of whether it would benefit the company commercially.

5. Risk Assessment

We have conducted a risk assessment of our business activities in relation to the offences created by the Act. As an AI consultancy and technology services provider operating exclusively in the United Kingdom, our risk exposure is assessed as low, for the following reasons:

• We do not provide financial services, accountancy, legal advice, or tax advisory services.
• We do not operate in high-risk jurisdictions or sectors identified by HMRC guidance as presenting elevated risk of tax evasion facilitation.
• Our client base consists of established UK businesses, and our services relate to operational improvement, AI implementation, and business intelligence.
• We do not handle client funds, hold assets on behalf of clients, or structure financial transactions.

This risk assessment will be reviewed annually and following any material change to our business activities, client base, or the jurisdictions in which we operate.

6. Prevention Procedures

Notwithstanding our assessed low risk, the following prevention procedures are in place:

6.1 Policy Communication

This policy is published on our website and communicated to all employees and relevant third parties. All new employees receive a copy during induction.

6.2 Due Diligence

We apply proportionate due diligence when onboarding new clients and engaging third parties who act on our behalf. Where any arrangement presents characteristics associated with tax evasion risk, enhanced due diligence will be conducted before proceeding.

6.3 Contractual Commitments

Our standard supplier and partner agreements include provisions requiring compliance with applicable anti-facilitation-of-tax-evasion legislation.

6.4 Training and Awareness

Employees with client-facing or financial responsibilities receive periodic awareness training on their obligations under the Act and the warning signs of tax evasion facilitation.

6.5 Reporting Concerns

Any employee, contractor, or third party who suspects that tax evasion facilitation has occurred, is occurring, or is being planned must report this immediately. Reports can be made:

• to a director of Coaley Peak Ltd directly; or
• via our Whistleblowing Policy, which provides for confidential reporting and protection from retaliation.

Reports may also be made externally to HMRC or the relevant authority in the applicable jurisdiction.

7. Consequences of Breach

Any associated person who facilitates tax evasion, or who fails to report a known or suspected instance of facilitation, will be subject to disciplinary action up to and including termination of employment or engagement. Where criminal conduct is identified, the matter will be referred to the relevant authorities.

8. Monitoring and Review

Responsibility for this policy rests with the directors of Coaley Peak Ltd. The policy and our underlying risk assessment will be reviewed at least annually, or sooner if there is a material change in our business activities, applicable legislation, or HMRC guidance. Updates will be published on this page.

9. Related Policies

This policy should be read alongside our other compliance documents, including:

• Anti-Corruption and Bribery Policy
• Whistleblowing Policy
• Supplier Code of Conduct
• Code of Conduct, Ethics and Standards