Anti-Tax Evasion

1. Introduction

Paytia Limited (“Paytia”) has a zero-tolerance approach to all forms of tax evasion, whether under UK law or under the law of any foreign country. Employees and Associated Persons of the Company must not undertake any transactions which would cause the Company to commit a tax evasion offence or facilitate a tax evasion offence by a third party.

This document sets out Paytia's policy for compliance with the Criminal Finances Act 2017, which created a corporate criminal offence of failure to prevent the facilitation of tax evasion.

2. Purpose and Scope

The purpose of this policy is to:

• Set out Paytia's responsibilities, and the responsibilities of those working for and with Paytia, in observing and upholding the company's position on preventing the facilitation of tax evasion
• Provide information and guidance to those working for and with Paytia on how to recognise and avoid tax evasion
• Encourage the reporting of any suspicions of tax evasion facilitation

This policy applies to all persons working for Paytia or on its behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, business partners, and any other person associated with Paytia, wherever located.

3. What Is Tax Evasion?

Tax evasion is the illegal non-payment or under-payment of taxes, usually by deliberately making a false declaration or no declaration to tax authorities. This could include deliberately misrepresenting affairs to the tax authorities to reduce tax liability, or dishonestly omitting to declare income or gains that are subject to tax.

Tax evasion facilitation is being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax by another person, or aiding, abetting, counselling, or procuring the commission of tax evasion.

4. Corporate Offence of Failure to Prevent the Facilitation of Tax Evasion

Under the Criminal Finances Act 2017, a corporate criminal offence is committed where:

• There is criminal tax evasion by a taxpayer (either an individual or a legal entity) under either UK law or foreign law
• The tax evasion is facilitated by an associated person of the relevant body acting in that capacity
• The relevant body failed to prevent its associated person from facilitating the tax evasion

There is a defence where the relevant body has put in place reasonable prevention procedures to prevent the facilitation of tax evasion by associated persons. This policy forms part of those reasonable prevention procedures.

5. Prevention Procedures

Paytia has implemented the following procedures to prevent the facilitation of tax evasion:

1. Risk Assessment: Paytia will regularly assess and document the nature and extent of its exposure to the risk of associated persons engaging in activity that could facilitate tax evasion.
2. Proportionality of Procedures:Paytia will implement procedures that are proportionate to the risks identified and to the nature, scale, and complexity of Paytia's activities.
3. Top Level Commitment: The Board of Directors and senior management of Paytia are committed to preventing the facilitation of tax evasion and will foster a culture in which activity intended to facilitate tax evasion is never acceptable.
4. Due Diligence: Paytia will apply due diligence procedures in respect of persons who perform or will perform services on behalf of the company, in order to mitigate identified risks.
5. Communication: Paytia will ensure that this policy is communicated, embedded, and understood throughout the organisation through internal and external communication, including training that is proportionate to the risk.
6. Monitoring and Review: Paytia will monitor and review its preventative procedures and make improvements where necessary.

6. Your Responsibilities

You must ensure that you read, understand, and comply with this policy. The prevention, detection, and reporting of tax evasion and foreign tax evasion are the responsibility of all those working for us or under our control.

You must notify your manager or the Chief Financial Officer as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

7. How to Raise a Concern

You are encouraged to raise concerns about any issue or suspicion of tax evasion or its facilitation at the earliest possible stage. If you are unsure whether a particular act constitutes tax evasion or the facilitation of tax evasion, or if you have any other queries, these should be raised with your line manager or the Chief Financial Officer.

8. Protection

Individuals who raise concerns or report another's wrongdoing are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in tax evasion or the facilitation of tax evasion, or because of reporting in good faith their suspicion that an actual or potential tax evasion offence has taken place, or may take place in the future.

9. Monitoring and Review

The Board of Directors will monitor the effectiveness and review the implementation of this policy regularly, considering its suitability, adequacy, and effectiveness. Any improvements identified will be made as soon as possible.

This policy has been approved by the company's Board of Directors, who will review and update it annually.

If you have questions about our Anti-Tax Evasion Policy or would like to report concerns, please contact compliance@paytia.com.