Tax Evasion Facilitation Policy

Tax Evasion Facilitation Policy

Last Reviewed: 25/09/2026

Next Review Date : 25/09/2029

Objective

Highway Data Systems Limited's objective is to conduct our business honestly and ethically. To achieve this, we have implemented a zero-tolerance approach to the facilitation of tax evasion. We will act professionally, impartially, and with integrity in all our business relations, dealings, and transactions, implementing and enforcing effective systems to prevent tax evasion facilitation. Failure to prevent tax evasion facilitation can result in criminal prosecution, including unlimited fines and damage to our reputation, which affects the company as a whole. 

Legality – Criminal Finances Act 2017

The Criminal Finances Act 2017 creates corporate offences of failing to prevent the criminal facilitation of UK tax evasion and, subject to additional legal conditions, foreign tax evasion.

Tax evasion involves deliberately and dishonestly evading tax. Tax evasion facilitation involves deliberately and dishonestly helping another person or organisation evade tax. References to tax in this policy include National Insurance contributions.

An associated person is an employee, agent or other person performing services for or on behalf of the Company, when acting in that capacity. This may include contractors, subcontractors and consultants.

The Company may be criminally liable where an associated person criminally facilitates another taxpayer’s tax evasion while acting for or on behalf of the Company, even if the Company’s management was unaware of the conduct.

The Company has a defence if it can demonstrate that it had reasonable prevention procedures in place, or that it was not reasonable in the circumstances to expect it to have such procedures.

Accidental or negligent assistance does not amount to criminal facilitation under these offences. However, concerns and mistakes must still be reported so that appropriate action can be taken.

Policy

This policy applies to the Director, all employees and other persons performing services for or on behalf of Highway Data Systems Limited.  It covers activities in the UK and overseas and should be read alongside the Company’s Bribery and Fraud Policy, Whistleblowing Policy and Disciplinary Procedure. 

Everyone covered by this policy must:

• Understand and comply with this policy.

• Never engage in tax evasion or deliberately help another person or organisation evade tax.

• Keep records, invoices, payments and expenses accurate and complete. Records must not be falsified, concealed or deliberately misdescribed to assist tax evasion.

• Promptly report suspected tax evasion, facilitation, requests to assist it or breaches of this policy.

• Cooperate with relevant training, checks and investigations.

The Director has overall oversight of this policy and the Company’s arrangements to prevent the facilitation of tax evasion. Senior managers are responsible for implementing these arrangements within their areas of responsibility, with appropriate professional support where needed. This includes:

• Assessing and recording the risks of people acting for or on the Company’s behalf facilitating tax evasion.

• Maintaining prevention measures proportionate to those risks, including appropriate financial controls and checks on relevant business relationships.

• Communicating the Company’s requirements to employees and relevant service providers and arranging guidance or training appropriate to their roles and risks.

• Monitoring the effectiveness of these arrangements, addressing identified weaknesses and keeping the Director informed.

Concerns should be reported promptly to a senior manager. If a concern involves that manager, or the person feels unable to approach them, they may raise it with another senior manager or the Director.

The Company will assess concerns promptly, arrange an appropriate investigation and seek professional advice where necessary. Information will be handled sensitively and shared only where necessary and lawful.

No person will be dismissed, threatened, bullied or otherwise disadvantaged for refusing to participate in tax evasion or its facilitation, or for raising a concern based on a reasonable belief, even if that concern is not substantiated.

Nothing in this policy prevents anyone from making a legally protected disclosure, reporting suspected wrongdoing to HMRC or another appropriate authority, or obtaining independent legal advice. Prior internal reporting or Company approval is not required for a legally protected disclosure.

Suspected breaches will be investigated fairly under the Company’s Disciplinary Procedure. Proven breaches may result in disciplinary action, up to and including dismissal. Serious deliberate breaches may amount to gross misconduct. The applicable rights to be accompanied and to appeal will apply. Relationships with external individuals or organisations may be terminated where appropriate, subject to contractual and legal requirements.

This policy will be reviewed three years or sooner if necessary.

Company Director Name :  Joe Charlesworth