Anti-Money Laundering & Tax Evasion Policy

In the light of Criminal Finances Act 2017, AES has adopted a statement of our corporate value on anti-facilitation of money laundering and tax evasion. It is our policy to conduct all our business dealings in an honest and ethical manner. The value statement governs all our business dealings and the conduct of all persons or organisations who are appointed to act on our behalf. We request all who have, or seek to have, a business relationship with AES, to familiarise themselves with our anti- money laundering & tax evasion value statement and to act at all times in a way which is consistent with our anti-tax evasion value statement.

Anti-Money Laundering & Tax Evasion Value Statement

AES (the “Company”) has a zero-tolerance approach to all forms of money laundering & tax evasion, whether under UK law or under the law of any foreign country. Employees of the Company must not undertake any transactions which:

1. cause the Company to commit a money laundering or tax evasion offence; or
2. facilitate a money laundering or tax evasion offence by a third party who is not an associate of the Company.

We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter tax evasion facilitation.

At all times, business should be conducted in a manner such that the opportunity for, and incidence of, money laundering or tax evasion is prevented.

Who Must Comply with This Policy?

This policy applies to all persons working for the Company or any other company on our behalf in any capacity, including employees at all levels, directors, officers and Associates (as defined below), including but not limited to agency workers, seconded workers, volunteers, interns, contractors, external consultants, third-party representatives and business partners, sponsors or any other person associated with us, wherever located.

Who Is Responsible for This Policy?

The Managing Director has overall responsibility for ensuring that this policy complies with our legal obligations, and our employees and associates comply with it. This policy is adopted by the Company. It may be varied or withdrawn at any time, in the Company’s absolute discretion. The Managing Director is responsible for ensuring those reporting to him understand and comply with this policy and are given adequate and regular training on it.

What Is the Facilitation of Tax Evasion?

Tax Evasion means an offence of cheating the public revenue or fraudulently evading UK tax, and is a criminal offence. The offence requires an element of fraud, which means there must be deliberate action, or omission with dishonest intent.

Tax Evasion Facilitation means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of UK tax, or aiding, abetting, counselling, or procuring the commission of that offence. Tax evasion facilitation is a criminal offence, where it is done deliberately and dishonestly.

Tax evasion is not the same as tax avoidance or tax planning. Tax evasion involves deliberate and dishonest conduct. Tax avoidance is not illegal and involves taking steps, within the law, to minimise tax payable (or maximise tax reliefs).

Tax means all forms of UK taxation, including but not limited to corporation tax, income tax, value added tax, stamp duty, stamp duty land tax, national insurance contributions and includes duty and any other form of taxation (however described).

What is the Facilitation of Money Laundering?

Money laundering is defined as “the process by which the proceeds of crime are converted into assets which appear to have a legitimate origin, so that they can be retained permanently or recycled into further criminal enterprises”.

Money laundering can be broken down into two categories:

Those who commit offences and then launder the proceeds of those criminal offences. The criminal offences are referred to as “predicate offences”.

Those whose only criminal involvement is to launder the proceeds of crime committed by others.

Company Responsibilities

The Company is responsible for offering employees appropriate training to understand money laundering and tax evasion, and actions to take to prevent them.

What Employees Must Not Do

Employees must always adhere to the AES anti- money laundering and tax evasion value statement and must ensure that they read, understand, and comply with this policy.

It is not acceptable for employees to:

1. Engage in any form of facilitating of Money Laundering or Tax Evasion
2. Aid, abet, counsel, or procure the commission of a Money Laundering or Tax Evasion offence by another person
3. Fail to promptly report any request or demand from any third party to facilitate the fraudulent Evasion of Tax by another person, in accordance with this policy; or
4. Engage in any other activity that might lead to a breach of this policy; or
5. Threaten or retaliate against another individual who has refused to commit a Money Laundering or Tax Evasion offence or who has raised concerns under this policy
6. An offence under the law of any part of the UK consisting of being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax.

How to Raise a Concern

Our employees have a responsibility to take reasonable action to prevent harm to AES and we hold our employees accountable for their actions and omissions. Any actions that breach the Criminal Finances Act and the tax laws of wherever we operate brings harm to AES and will not be tolerated.

Employees are responsible for properly following The AES policies and procedures. These should generally ensure that all taxes are properly paid. If you are ever asked by anyone either inside or outside our company to go outside our standard procedures, this should be reported without delay, as someone may be attempting to evade tax.