Tax Evasion Policy¶
| Document Reference | POL_HSQE_23 |
|---|---|
| Revision | 3 |
| Issue Date | 1st July 2025 |
| Next Review | 1st July 2026 |
| Status | Uncontrolled when printed |
Purpose¶
A M Water Services Ltd maintains a zero-tolerance approach to the criminal facilitation of tax evasion to protect our business, reputation, and all stakeholders from the serious consequences of tax-related offences. This policy ensures we comply with the Criminal Finances Act 2017 and demonstrates our commitment to ethical business practices across all our water infrastructure and grab operations.
Scope¶
This policy applies to all employees, directors, contractors, subcontractors, suppliers, customers, and any other associated persons acting on behalf of A M Water Services Ltd in any capacity, whether in the UK or internationally.
Legal Requirements¶
This policy ensures compliance with the Criminal Finances Act 2017, which creates corporate criminal offences where associated persons facilitate tax evasion. We also comply with all UK tax legislation including corporation tax, VAT, PAYE, and National Insurance requirements, plus any relevant foreign tax laws where we operate.
Policy Statement¶
We conduct all business honestly and ethically, taking a zero-tolerance approach to tax evasion and its facilitation. Tax evasion means deliberately and dishonestly cheating the public revenue or fraudulently evading tax, which differs from legitimate tax planning. The facilitation of tax evasion involves knowingly helping another person to evade tax through deliberate and dishonest actions. Under the Criminal Finances Act 2017, our company faces unlimited fines, exclusion from public contracts, and severe reputational damage if anyone associated with us facilitates tax evasion, even if we were unaware of their actions.
In our water services and grab operations, we recognize particular risks around cash payments, subcontractor arrangements, and cross-border transactions. We therefore maintain robust financial controls and clear payment procedures. All transactions must be properly documented with legitimate invoices, payments must go through approved channels, and we verify the tax status of contractors and suppliers. Our teams must immediately report any requests for unusual payment arrangements, such as offshore accounts without valid reason, cash payments to avoid tax, or invoicing to different entities than those receiving services.
Everyone working with us must actively prevent tax evasion facilitation. You must never engage in or facilitate tax evasion, aid others in evading tax, or fail to report suspicious requests or activities. Common warning signs include requests for cash payments, refusal to provide proper documentation, unusual invoicing arrangements, contractors wanting incorrect employment status, payments to different countries than where services are provided, or attempts to obscure the nature of services on invoices. If you encounter these red flags while working on water main installations, operating grab lorries, or in any other capacity, you must report them immediately to management.
Implementation and Monitoring¶
Our Directors oversee this policy's effectiveness through regular reviews of financial controls, contractor vetting procedures, and incident reports. Finance staff receive specific training on tax evasion risks and reporting procedures, while all employees learn about this policy during induction and annual refresher training. We communicate our zero-tolerance stance to all business partners at the start of relationships and maintain clear reporting channels for concerns, including our confidential whistleblowing procedure.
Responsibilities¶
The Directors hold overall responsibility for preventing tax evasion facilitation and ensuring adequate procedures are in place. Management must ensure all staff understand this policy, maintain proper financial controls, and investigate any concerns raised. All employees and associated persons must comply with this policy, avoid any activity that might facilitate tax evasion, report suspicious behavior immediately, and cooperate with any investigations. Breaches of this policy result in disciplinary action including potential dismissal, termination of contracts, and reporting to relevant authorities.
Review¶
This policy will be reviewed annually by the Directors to ensure it remains effective and continues to protect the company from criminal liability for tax evasion facilitation while reflecting current legislation and best practice.
Signed:
Aaron Mason Director A M Water Services Ltd 1st July 2025
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