CTH CCO Policy



Consolidated Timber Holdings Group


Corporate Criminal Offence (CCO) Policy


Applicable to all Consolidated Timber Holdings Group Employees




1. Corporate Criminal Offence (CCO)

1.1 What is Corporate Criminal Offence (CCO)?

1.2 What is tax evasion?

1.3 Who is covered by this policy?

2. Underlying principles

3. Details of the Policy

4. Responsibilities

5. What to look out for

6. Ongoing Monitoring

Introduction and Background

Consolidated Timber Holdings Group Limited and it’s subsidiaries, (the Group) takes a zero tolerance approach to all forms of tax evasion and the facilitation of tax evasion by its employees, members and associates, whether the tax evasion occurs in the UK or elsewhere. The Group takes active steps in seeking to eliminate the risk, and all employees, members and associates should adhere to the principles and procedures set out in this policy.

The Criminal Finances Act came into effect in the UK in 2017. It introduced the specific Corporate Criminal Offences (CCO) for the failure to prevent the facilitation of tax evasion by persons associated with corporate entities.

This policy applies to all employees, agents, contractors and any third party who provides services on behalf of the business (defined as “associated persons” under the legislation) of Consolidated Timber Holdings Group Limited and its subsidiaries, herein referred to as the Group.

1. Corporate Criminal Offence (CCO)

1.1 What is Corporate Criminal Offence (CCO)?

The CCO rules make it a specific criminal offence for companies and partnerships to fail to prevent those acting for or on their behalf to facilitate tax evasion, whether this involves UK taxes or those of a non-UK jurisdiction. Broadly, if a person acting in the capacity of an “associated person” with the Group facilitates criminal tax evasion, the Group could be liable to prosecution and face an unlimited fine and serious reputational damage. “Associated persons” include employees, members, associates and suppliers who perform services for or on behalf of the Group.

1.2 What is Tax Evasion?

Tax evasion involves the deliberate and dishonest use of illegal practices in order not to pay the right amount of tax. This could include not reporting all of your income, deliberately not filing an accurate tax return, hiding beneficial ownership and taxable assets from HMRC or diverting funds to hide income from local taxation authorities.

Foreign tax evasion means evading tax in a foreign country, provided that conduct is an offence in that country and would be a criminal offence if committed in the UK. As with tax evasion, the element of fraud means there must be deliberate action, or omission with dishonest intent.

1.3 Who is covered by this policy?

This policy applies to all employees, including leadership, senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, casual workers and agency staff, agents or any other person associated with CTH or any of its subsidiaries.

In this policy, an associated person is defined as a person who performs services for or on behalf of the Group. This can be an individual or an incorporated or unincorporated body. Typically this includes suppliers, agency workers, outsources service providers, contractors etc.

2. Underlying Principles


CTH is committed to operating legally and ethically, complying with all applicable legislation and guidance. Therefore, the purpose of this policy is to set out clearly how the Group can prevent, as far as is practicably possible, the facilitation of tax evasion. The Policy also explains the role of all its employees, members, associated persons, and other parties in ensuring compliance with the Policy.

3. Details of the Policy


Tax evasion is the illegal non-payment or underpayment of tax, through cheating the public revenue or fraudulently evading tax in the UK and other jurisdictions; it is a criminal offence. The offence requires an element of fraud, which means there must be deliberate action, or omission, with dishonest intent. This Policy and the appropriate legislation cover tax evasion both in the UK and abroad.

To comply with the Criminal Finances Act and other associated legislation and regulation, employees, members or associated persons of the Group must not:

· engage in any form of facilitating tax evasion in the UK or abroad;

· aid, abet, or procure the commission of a tax evasion offence either in the UK or abroad;

· fail to report any request or demand from any party to facilitate tax evasion or suspected fraudulent activity pursuant to the evasion of tax by any other party;

· engage in any activity that might lead to a breach of this Policy;

· threaten or otherwise retaliate against someone who has refused to commit a tax evasion offence in the UK or abroad or who has raised concerns under this Policy; or

· engage in any offence under the law consisting of being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax.

4. Responsibilities

All employees, members and associated persons have a responsibility to ensure that they have read, understood, and will comply with this Policy. Employees must notify their line manager or report under our Whistleblowing Policy, as soon as possible if they believe or suspect a breach of this Policy has occurred.

For example, if you receive a request for assistance in circumstances where you know or suspect that another party intends to use that assistance to enable them to evade tax fraudulently, you should resist responding to the request immediately, and state that you will need to consult your line manager and then report as above as soon as possible.

Employees or members who breach this Policy will face disciplinary action that could result in dismissal for gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Employees or members who refuse to be complicit in tax evasion, or those who raise concerns or report another party’s wrongdoing, might worry about possible repercussions. CTH is committed to ensuring that no one suffers any detrimental treatment because of refusing to take part in illegal tax evasion or corruption, or because of reporting in good faith their suspicion about a potential breach of this Policy. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. Employees or member who believe that they have suffered any such treatment should inform their HR representative or another appropriate member of management.

5. What to look out for


Below are examples of risk areas and red flags that could arise during the course of your everyday working and which should raise a concern under this Policy. The list of examples is not intended to be an exhaustive list, nor are they set out as definitive indicators of tax evasion or the facilitation of such an offence. These suggestions are intended to act as indicators of actions that should prompt further due diligence or consideration of the steps you are being asked to take or parties you are engaging with.

  • You become aware, in the course of your work, that another party:
  • has made or intends to make a false statement relating to tax;
  • has failed to disclose income or gains to, or to register with, HMRC (or the equivalent authority in any relevant non-UK jurisdiction);
  • has delivered or intends to provide a false document relating to tax; or
  • has set up or intends to set up a structure to try to hide income, gains or assets from a tax authority.
  • You become aware, in the course of your work, that another party has deliberately failed to register for VAT (or the equivalent tax in any relevant non-UK jurisdiction), or has failed to account for VAT.
  • Another party requests payment in cash rather than through an account with a recognised bank or refuses to sign a formal commission or fee agreement or refused to provide a proper invoice or receipt for a payment made.
  • You become aware, in the course of your work, that someone working for the Group as an employee asks to be treated as a self-employed contractor, but without any material changes to their working conditions, or a family member or friend requests this treatment without adequate support to that treatment.
  • Another party requests that payment is made to a country or geographic location different from where the party resides or conducts business.
  • A party to whom the Group has provided goods, requests for an invoice to be addressed to a different entity where the Group did not provide services to that entity.
  • You receive an invoice from another party that appears to be non-standard or customised.
  • Another party refuses to put terms in writing or asks for contracts and other documentation to be backdated.
  • You notice that someone at work (for example an employee or contractor) is claiming illegitimate expenses.
  • Any requests to maintain the secrecy of a transaction, beyond the usual confidentiality associated with business arrangements.


6. Ongoing Monitoring


We will maintain an effective system for monitoring compliance procedure to ensure we remain committed to our zero tolerance to facilitation of tax evasion. This includes training (both fact-to-face and online as appropriate) and forms part of the induction process for all new employees.

All existing employees receive regular, relevant training on how to adhere to this policy. Our zero-tolerance approach to facilitation of tax evasion must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.