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STATEMENT OF COMPLIANCE – CRIMINAL FINANCES ACT 2017

Introduction

 

This statement is published in accordance with the Criminal Finances Act 2017 (the "Act”), and is a summary of our Corporate Criminal Offences (“CCO”) Policy that has been approved by the Board of Directors. 

This statement sets out the commitment of Fircroft Engineering Services Holdings Limited (“ Fircroft”) and its global subsidiaries (“We”, the "Fircroft Group”) to preventing Associated Persons (including employees) as defined by the Act, from engaging in the criminal facilitation of tax evasion in the UK or in a foreign country.

 

Overarching approach

 

The Fircroft Group does not condone any form of tax evasion, whether in the UK or overseas. At all times, business is to be conducted in a manner such that the opportunity for, and incidence of, tax evasion is prevented. Furthermore, all employees and other Associated Persons must not undertake any transactions which:
• causes Fircroft and/or its subsidiaries to commit a tax evasion offence; or
• facilitate tax evasion offence by a third party, who is not an Associated Person of the Company or one of the global subsidiaries.
We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. We will implement and enforce effective policies and procedures to counter the facilitation of any tax evading activities.

 

Risk assessment

 

We have a Risk Management Policy in place which provides the framework for the Group approach towards identifying and mitigating CCO-related risks. We undertake internal auditing of business processes with due consideration of all our compliance obligations, including those relating to the Criminal Finance Act 2017, to ensure that the policies and procedures in force are effective in mitigating tax evasion and any facilitation activities.
Training and awareness
To support employees in their understanding of tax evasion and identifying when and how it might occur, as a minimum, employees are required to complete basic CCO training initially when they start working for any of the Fircroft Group companies and annually each year after that. Further tailored training is provided depending on an employee’s position within the Group and the day-to-day job role they perform.

 

Declaration


The Fircroft Group is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever Fircroft and its subsidiaries operate. We will implement and enforce effective policies and procedures to counter the facilitation of any tax evading activities.

 

Fircroft Board of Directors

 

 

 

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