Tax Evasion Prevention Policy

Purpose and Commitment

ScaleOps Search Ltd adopts a zero-tolerance approach to tax evasion and the criminal facilitation of tax evasion in its business and supply chain. This policy sets out proportionate procedures to prevent any associated person from facilitating tax evasion while performing services for or on behalf of ScaleOps.

 

Scope

 

This policy applies to the owner/Managing Director and any contractors or agents engaged by ScaleOps, covering all services connected to candidate sourcing, screening, placement, fees and invoicing.

 

Legal Framework

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Under the Criminal Finances Act 2017, there are two strict-liability corporate offences: failure to prevent the criminal facilitation of UK tax evasion and foreign tax evasion. The only defense is to have reasonable prevention procedures in place.

 

Our Controls

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ScaleOps implements top-level commitment, risk assessment, proportionate procedures, due diligence, communication and training, and monitoring and review as per HMRC guidance.

 

Risk Assessment

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ScaleOps maintains a risk-based register evaluating counterparties, transactions, and geographies/sectors for exposure to tax evasion risk.

 

Due Diligence

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Checks include verifying client identity, payment routes, and tax compliance; ensuring no misdescription of services or split invoicing; and confirming suppliers have anti-facilitation clauses.

 

Communication & Training

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Owner refreshes awareness annually using HMRC guidance and communicates expectations to clients and suppliers in writing.

 

Monitoring & Reporting

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Quarterly review of invoices and payment instructions for red flags; any suspicion is recorded, engagement paused, and external advice sought.

 

Red Flags

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Examples include requests to misdescribe services, split invoices, route payments via unrelated third parties, or refusal to provide company identifiers.

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Contractual Safeguards

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Client/supplier terms include anti-facilitation warranty, compliance undertakings, payment controls, and audit/termination rights.

 

Record-Keeping

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ScaleOps retains risk assessments, onboarding checks, invoices, payment instructions, logs, training notes, and will keep policy reviews for at least six years.

 

Review

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Our policy is reviewed annually and after any material legal or guidance updates.

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Version: 1.0 | Effective from: 18th July 2025 | Approved by: Owner / Managing Director (Amie Capron)