Summary

This Policy summarises the procedures of Purpose Planet to ensure all Purpose Planet “associated persons”, including employees and those acting on our behalf, do not facilitate Tax Evasion.

Statement

Purpose Planet is committed to conducting business honestly, professionally and with integrity. As such Purpose Planet takes a zero-tolerance approach to Tax Evasion or the facilitation of Tax Evasion, whether under UK law or the law of any foreign country. Purpose Planet will uphold all laws relevant to countering tax evasion, including the UK Criminal Finances Act.

Purpose & Scope

The purpose of this Policy is to set out the expectations about our employees and third parties acting for or on Purpose Planet’s behalf and to provide guidance on how to recognise and avoid helping others evade tax. Breach of laws relevant to countering tax evasion can lead to criminal liability, including the prosecution of individuals, imprisonment, unlimited fines and reputational damage. This policy is only intended to familiarise you with Purpose Planet’s expectations and some of the legal issues relevant to compliance with laws relevant to countering tax evasion, including the UK Criminal Finances Act. Questions concerning specific transactions, scenarios or payments should be directed to the Finance & Operations Director.

What are the roles and responsibilities?

This Policy applies to all directors, officers, employees, secondees and agency staff (whether temporary, contract or permanent) (the "employees") of any Purpose Planet company, entity, business unit, or branch). Purpose Planet expects that anyone doing business or performing services for or on behalf of Purpose Planet in any capacity (including, but not limited to, agents, consultants, contractors, sub-contractors, representatives, advisors, suppliers, and distributors) wherever located (collectively referred to as "Third Parties"), will conduct themselves by laws relevant to countering tax evasion and the principles of this Policy. Behaviour which breaches or runs counter to the principles in this Policy may lead to prosecution, severe penalties and termination of contracts and relationships with Purpose Planet. Each employee is held accountable for full compliance with this Policy. Non-compliance will result in termination, disciplinary or other actions against employees as appropriate by relevant laws and/or Purpose Planet's internal policies and regulations. When necessary, specialised training will be provided to Employees with significant compliance responsibilities or in high-risk functions. Notwithstanding such training, it is the responsibility of each Employee to review and ensure they understand the principles of this Policy.

What is Tax Evasion

Tax evasion means deliberately or dishonestly cheating the public revenue or fraudulently evading UK or overseas tax.

What is the Facilitation of Tax Evasion?

Tax evasion facilitation means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax (whether UK tax in a foreign country) by another person, or aiding, abetting, counselling or procuring the commission of that evasion. Tax Evasion facilitation is a criminal offence. Purpose Planet will be liable under the new offence of failing to prevent the individual or entity, who was acting for or on behalf of Purpose Planet at the time, from committing the facilitating of Tax Evasion unless it can demonstrate that it had reasonable prevention procedures in place. Purpose Planet does not have to have deliberately or dishonestly facilitated the Tax Evasion itself, the fact that an ‘associated person’ has done so creates the liability for Purpose Planet.

Our Commitment

Purpose Planet is committed to the following principles:

• We will never buy any product or service from any supplier where it is known or suspected that any aspect of the transaction is being misused, abused or otherwise corrupted for Tax Evasion.
• To immediately terminate any agreement or business relationship as soon as the company learns of, or suspects Tax Evasion may be taking place.
• To not progress any business opportunity where there is any suspicion that any aspect of it may involve Tax Evasion.
• To avoid doing business with others who do not also commit to holding these same standards in respect of preventing Tax Evasion.

Responsibilities of all Employees and other Associated Persons of Purpose Planet

No Employee or Third Party when acting for or on behalf of Purpose Planet may either evade tax, facilitate tax evasion by another person (including another Purpose Planet entity, or aid anyone who they know, or suspect is engaged in tax evasion. The principle applies regardless of what the tax is, extending to all direct and indirect taxes. It also applies irrespective of the location of the Employee or Third Party or the other person and notwithstanding that the person may not succeed in evading tax. This Policy and Purpose Planet’s zero-tolerance approach to tax evasion must be communicated to all third parties at the outset of the business relationship and as appropriate after that.

Prevention Through Vigilance

There is not an exhaustive list of Tax Evasion opportunities. At a more general level, the best defence against Tax Evasion and facilitation of Tax Evasion remains the vigilance of our employees and associated persons and the adoption of a common-sense approach supported by our clear whistleblowing procedure. In applying common sense, employees must be aware of the following:

• Is there anything unusual about the way an associated person of Purpose Planet is conducting their relationship with the Company or the third party?
• Is there anything unusual about the customer’s or associated persons conduct or behaviour in your dealings with them?
• Are there unusual payment methods? Employees and Third Parties should be alert to any signs (or “red flags”) that third parties are looking to or are evading tax in their dealings with Purpose Planet.
• If you have cause to suspect this or encounter any of these red flags, you must report them promptly using the process described in the section How To Raise A Concern.

Examples of potential “red flags” that may indicate potential Tax Evasion and the potential facilitation of Tax Evasion are set out in Appendix 1 below. This list is not intended to be exhaustive.

How To Raise A Concern

Any employee who has any concerns or suspicions of any intention that another employee or associated person is attempting to, or you are asked to assist another person, facilitate or commit Tax Evasion (whether UK tax or tax in a foreign country), should raise any question or concern at the earliest possible opportunity with their line manager or the Finance & Operations Director.

All matters raised will be dealt with in strict confidence and you will not suffer any adverse consequence for refusing to engage in the facilitation of Tax Evasion or for reporting, in good faith, instances in which you suspect that this Policy has been breached, even if this may result in Purpose Planet losing business.

If you are an associated person of Purpose Planet but not an employee, you are asked to raise the issue by contacting the company’s office telephone line.

Risk Assessment

Purpose Planet has conducted a review of its risks and associated processes and procedures to ensure that all appropriate steps are taken to prevent the facilitation of Tax Evasion. It maintains a register of possible risks of the facilitation of Tax Evasion by employees and associated persons, as well as listing controls to mitigate those risks, and any actions required to improve those controls. This register will be regularly reviewed and updated, as and when required.

Publication of Guidance

The company regularly reviews guidance, legislation and the operation of this Policy to ensure it is suitable, adequate and effective to address the risk of facilitation of Tax Evasion and may make changes to this Policy from time to time to address any risks identified or any concerns reported to it. Within that review, it will consider appropriate training for all employees.

Disclaimer

This Policy and procedures set out above are not contractually binding. Purpose Planet reserves the right to amend this Policy at any time.