Preventing the Facilitation of Tax Evasion

1. Our position

Vyce has zero tolerance for tax evasion and the facilitation of tax evasion, in compliance with the Criminal Finances Act 2017.

This policy applies to all employees, workers, agents, contractors and any third party providing services on our behalf. Together these are "associated persons" under the legislation.

2. The law

Sections 45 and 46 of the Criminal Finances Act 2017 created two corporate criminal offences: failure to prevent the facilitation of UK tax evasion, and failure to prevent the facilitation of foreign tax evasion.

If an associated person criminally facilitates tax evasion and we can't show we had reasonable prevention procedures in place, Vyce may be criminally liable. There's no need to show that senior management knew. The only defence is reasonable prevention procedures. This policy forms part of ours.

3. What this means

Tax evasion is the deliberate and dishonest avoidance of tax properly due.

Facilitation is knowingly and dishonestly helping someone else to evade tax. Examples include manipulating invoices to misstate VAT, making payments into undeclared overseas accounts, and falsifying records to understate taxable revenue.

4. Our approach

Everyone covered by this policy must:

• Refuse to take part in anything that could facilitate tax evasion
• Question transactions that look irregular
• Report concerns to hello@vyce.io
• Complete due diligence before engaging third parties
• Keep accurate records

We'll end relationships with anyone found in breach.

5. Warning signs

Report any of these immediately:

• A supplier asks for payment into an account different from the one on the invoice
• Pressure to approve an invoice that doesn't follow normal practice
• A third party offers a discount in return for avoiding VAT
• A request to adjust or manipulate invoice amounts
• An organisation won't provide tax registration documents
• Contractual structures that appear designed to obscure taxable transactions
• Anyone describing a tax "loophole" or shortcut

It isn't your job to decide whether a concern is well founded before reporting it.

6. Reporting

• hello@vyce.io
• Confidential reporting line: 0203 868 6303

Anyone reporting in good faith won't face retaliation. We investigate confidentially and accept anonymous reports.

7. Training and review

We provide training on identifying tax evasion risks and reporting obligations, and we cooperate fully with HMRC and law enforcement. This policy is reviewed annually.