The Norths Group Ltd
- Purpose
The Norths Group Ltd (“the Company”) is committed to conducting its business with the highest standards of integrity and in compliance with all applicable laws and regulations, including the Criminal Finances Act 2017.
This policy sets out our zero-tolerance approach to tax evasion and the facilitation of tax evasion, money laundering, bribery, or any other form of financial crime.
- Scope
This policy applies to:
- All employees (permanent, temporary, or contract);
- Directors and officers of the Company;
- Consultants, agency workers, and any other individuals engaged by the Company;
- All business partners, suppliers, clients, and third parties acting on the Company’s behalf.
- Policy Statement
The Norths Group Ltd will:
- Never knowingly engage in or facilitate tax evasion, fraud, or money laundering;
- Take reasonable steps to prevent associated persons from facilitating such offences;
- Maintain appropriate procedures to detect and prevent financial crime;
- Promote a culture of honesty, openness, and accountability in all business dealings.
We take a zero-tolerance stance towards any form of criminal financial activity. Any breach of this policy may result in disciplinary action (including dismissal) and may lead to criminal prosecution.
- Legal Background
Under the Criminal Finances Act 2017, it is a criminal offence for a company to fail to prevent the facilitation of tax evasion by an associated person.
This applies both to UK tax evasion and to foreign tax evasion where there is a UK connection.
- Responsibilities
- Directors and Senior Management are responsible for implementing and enforcing this policy.
- Managers and Supervisors must ensure that employees understand and comply with this policy.
- All Staff and Associated Persons must:
- Read and understand this policy;
- Report any concerns or suspicions immediately;
- Refrain from any activity that could lead to or suggest facilitation of tax evasion or financial crime.
- Risk Areas
Specific risks for a recruitment agency may include:
- Paying temporary workers or contractors through unverified or non-compliant payment intermediaries;
- Engaging umbrella companies or payroll providers that operate tax avoidance schemes;
- Accepting payments or commissions from unverified sources;
- International placements where cross-border tax obligations apply.
- Prevention and Due Diligence
The Norths Group Ltd will:
- Conduct due diligence on all clients, candidates, and suppliers before engagement;
- Verify the legitimacy of payment arrangements and tax compliance status;
- Keep clear records of all financial transactions;
- Provide training to staff on recognising and reporting financial crime risks.
- Reporting Concerns
If you suspect any breach of this policy or any instance of financial crime:
- Report it immediately to your line manager or the Compliance Officer;
- Reports can be made confidentially and without fear of retaliation;
- The Company will investigate all concerns thoroughly and take appropriate action.
- Training and Communication
All employees and relevant third parties will receive regular training and updates on:
- The Criminal Finances Act 2017 and related legislation;
- Identifying and reporting red flags;
- The Company’s internal procedures for compliance.
- Monitoring and Review
The Norths Group Ltd will regularly review this policy and its related controls to ensure ongoing effectiveness and compliance with legislation.
- Breaches of This Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. The Company may also terminate relationships with other associated persons or organisations that breach this policy.
Dan Carter
Managing Director
The Norths Group Ltd
