Anti-Facilitation of Tax Evasion, Fraud, and Financial Crime Policy

Document Control:

Policy Version:

2.0

Effective Date:

30 January 2026

Last Review Date:

30 January 2026

Next Review Due:

30 January 2027

(or sooner if significant change occurs)

Policy Owner:

Managing Director

Controlled Copy Location:

Company intranet / EHSQ Management System

Uncontrolled when printed


1.  Purpose

This policy outlines Greensport Trading Limited's t/a Inscapes commitment to preventing and combating the facilitation of tax evasion, fraud, and financial crime in compliance with applicable laws, including the Criminal Finances Act 2017 (UK) and other relevent regulations. It establishes standards for employees, contractors and business partners to ensure ethical conduct in all business activities.  

 

2.  Scope

This policy applies to:

·      All employees, officers, and directors of Greensport Trading Limited's t/a Inscapes. 

·         Contractors, consultants, suppliers, agents, and other third parties acting on behalf of Greensport Trading Limited's t/a Inscapes.

·         All jurisdictions in which Greensport Trading Limited's t/a Inscapes operates.

 

3.  Definitions

  • Tax Evasion

Ø  Tax Evasion: Illegal activities undertaken by individuals or businesses to deliberately misrepresent their financial affairs to reduce tax liability.

Ø  Facilitation of Tax Evasion: Knowingly assisting or enabling another party to commit tax evasion.

Ø  Fraud: Any act of deception intended for personal or financial gain or to cause loss to another party.

Ø  Financial Crime: Any crime involving the unlawful conversion or transfer of financial assets, including money laundering, bribery, and corruption.


4.  Policy Statement

  • The facilitation of tax evasion or fraud.
  • Participation in or facilitation of financial crime.
  • Any business dealings that may be complicit in unlawful activities.

 All employees and associated persons are required to: 

  • Comply with all applicable laws and regulations.
  •  Act with integrity and transparency in all financial and business transactions.
  • Report any suspected violations of this policy immediately.

 

5.  Responsibilities

Management Responsibilities 

  • Ensure that this policy is effectively communicated, implemented, and enforced.
  • Provide adequate resources for training and awareness programs.
  • Regularly review and update this policy to ensure compliance with legal and regulatory changes.

 

Employee Responsibilities 

  • Adhere to the principles of this policy and all applicable laws.
  • Avoid any activity that could be perceived as facilitating tax evasion or financial crime.
  • Complete mandatory training on anti-tax evasion and financial crime prevention.
  • Report any concerns or suspicions to the appropriate channels.
Third-Party Responsibilities
  • Ensure compliance with this policy when acting on behalf of Greensport Trading Limited's t/a Inscapes.
  • Cooperate with due diligence and audits conducted by other companies.

 

6.  Risk Management and Prevention Measures

Risk Assessment

Inscapes will regularly assess the risk of tax evasion and financial crime within its operations and supply chain.

Due Diligence

  • Conduct thorough due diligence on clients, suppliers and other third parties to identify and mitigate risks.
  • Monitor ongoing business relationships to ensure compliance with this policy.

Training

  • Provide regular training for employees on identifying and preventing tax evasion, fraud, and financial crime.
  • Ensure all employees understand their responsibilities and how to report concerns.

Controls and Audits

  • Implement robust financial controls to detect and prevent unlawful activity.
  • Conduct periodic internal audits to ensure compliance with this policy.

7. Ethical Training and Labour Standards

Greensport Trading Limited is committed to conducting all business activities in an honest, ethical, and responsible manner. We support fair labour practices, safe working conditions, and respect for the rights and dignitity of all individuals. We comply with all relevant labour, environmental and anti-savery laws, and expect the same high standards from our suppliers and business partners. We do not tolerate the use of forced, bonded or child labour in any part of our operations or supply chain. 

 

8. Reporting and Whistleblowing

Reporting 

Employees and third parties are encouraged to report any concerns or suspicions through:

Whistleblower Protections 

  •  Reports will be treated confidentially to the extent possible.
  • No employee will face retaliation or discrimination for reporting concerns in good faith.

Whistleblower Protections 

Violations of this policy may result in:

  • Disciplinary action, up to and including termination of employment.
  •  Termination of contracts with third parties.
  • Legal action, including civil or criminal proceedings.

 

9. Governance

  • This policy is approved by the Managing Director and will be reviewed annually or as required by changes in legislation.
  • Compliance with this policy will be monitored by the Quality Manager.

10. Related Policies

This policy should be read in conjunction with:

  • Anti-Bribery and Corruption Policy
  • Code of Conduct
  • WhistleblowingPolicy

ACCREDITATIONS