Corporate Criminal Offence (CCO) Policy
1. Policy Statement
Red Door Recruitment Ltd is committed to conducting business with honesty, integrity and in full compliance with UK tax laws.
The Company has a zero-tolerance approach to tax evasion and the facilitation of tax evasion. We will not knowingly assist, encourage or enable any employee, client, candidate, contractor, supplier or third party to evade tax obligations.
This policy is intended to support compliance with the Criminal Finances Act 2017 and applies to all directors, employees, temporary workers and any person acting on behalf of the Company.
2. Purpose
The purpose of this policy is to:
Prevent the criminal facilitation of tax evasion.
Ensure employees understand their responsibilities.
Protect the reputation of the Company.
Demonstrate that the Company has reasonable procedures in place to prevent tax evasion facilitation.
3. What is Tax Evasion?
Tax evasion is the illegal non-payment or underpayment of taxes.
Examples include:
Deliberately concealing income from HMRC.
Submitting false expense claims.
Failing to declare taxable earnings.
Creating false records to reduce tax liabilities.
Tax avoidance, which uses legal methods to manage tax liabilities, is different from tax evasion.
4. Facilitation of Tax Evasion
Facilitation of tax evasion occurs when a person deliberately and dishonestly assists another person to evade tax.
Examples might include:
Helping someone hide taxable income.
Creating false documentation.
Knowingly paying workers in a way designed to avoid tax obligations.
Ignoring clear evidence that someone is attempting to evade tax.
5. Responsibilities
Directors
The directors are responsible for:
Promoting a culture of compliance.
Ensuring appropriate controls are in place.
Reviewing risks periodically.
Employees
All employees must:
Act honestly and ethically.
Follow Company procedures.
Raise concerns where they suspect tax evasion or its facilitation.
Complete any training provided.
6. Recruitment-Specific Risks
As a recruitment business, areas of potential risk may include:
Engagement of temporary workers.
Use of umbrella companies.
Contractor arrangements.
Payroll processing.
Payments to self-employed individuals.
Client requests relating to worker payment arrangements.
Employees must not participate in any arrangement that appears intended to evade tax obligations.
7. Due Diligence
The Company will undertake reasonable checks on:
Clients.
Contractors.
Umbrella companies.
Payroll providers.
Other key suppliers where appropriate.
Any concerns identified must be reported to management.
8. Reporting Concerns
Employees who suspect tax evasion or its facilitation must report concerns immediately to a Director.
Reports will be treated seriously and confidentially wherever possible.
No employee will suffer detriment for raising a genuine concern in good faith.
9. Breaches
Any breach of this policy may result in:
Disciplinary action.
Termination of employment or engagement.
Reporting to relevant authorities where appropriate.
10. Monitoring and Review
This policy will be reviewed annually and updated as necessary to reflect changes in legislation, Company operations and identified risks.