Purpose
The purpose of this policy is to ensure that Genius Energy Lab conducts all of its business activities with honesty, integrity and transparency and complies with all applicable tax legislation.
Genius Energy Lab has a zero-tolerance approach to tax evasion and the criminal facilitation of tax evasion. The Company is committed to maintaining effective procedures to reduce the risk of tax evasion occurring within its business or by anyone acting on its behalf.
This policy supports the Company's commitment to ethical business practices and forms part of Genius Energy Lab's wider management system.
Scope
This policy applies to all directors, employees, contractors, consultants, suppliers and any other individuals or organisations acting on behalf of Genius Energy Lab.
All persons covered by this policy are expected to comply with its requirements and support the Company's commitment to preventing tax evasion and the criminal facilitation of tax evasion.
Company Commitment
Genius Energy Lab is committed to conducting business fairly, responsibly and in accordance with UK legislation.
The Company will:
- Maintain accurate and transparent financial records.
- Operate appropriate financial controls.
- Carry out reasonable checks before engaging employees, suppliers and subcontractors.
- Investigate any concerns relating to suspected tax evasion or financial misconduct.
- Take appropriate disciplinary or contractual action where breaches of this policy are identified.
- Report suspected criminal activity to the relevant authorities where required by law.
The Board of Directors and senior management are fully committed to preventing the criminal facilitation of tax evasion. The Company maintains a zero-tolerance approach and expects all persons acting on its behalf to comply with this policy and all applicable tax legislation.
Recruitment and Employee Responsibilities
The Company carries out appropriate checks before employing new members of staff.
As part of the employee onboarding process, Genius Energy Lab completes appropriate pre-employment checks, including verification of an individual's identity and Right to Work in the UK. Payroll and employment information is collected before employment commences, and qualifications or previous experience may be verified where appropriate.
All new employees are required to complete the Company's onboarding process. This includes reading the Company Handbook and all relevant company policies through the Atlas online training platform before confirming that they have understood and will comply with them.
Company policies are reviewed annually as part of the Company's management system. Employees are required to re-read and acknowledge all applicable policies through Atlas each year to ensure they remain aware of their responsibilities.
All employees receive information during induction and through the annual Atlas policy review process on the Company's zero-tolerance approach to tax evasion and the criminal facilitation of tax evasion. Employees are expected to understand the risks of tax evasion, comply with this policy, recognise indicators of suspected tax evasion or its facilitation, and report any concerns immediately through the reporting procedures set out in this policy.
All employees are expected to:
- Act honestly and with integrity.
- Follow company financial procedures.
- Report any concerns relating to suspected tax evasion or unethical conduct.
- Comply with this policy and all other relevant company policies.
Suppliers and Contractors
Genius Energy Lab carries out appropriate due diligence before approving new suppliers and subcontractors.
Although the Company makes limited use of subcontractors, all new suppliers and subcontractors are subject to the Company's approval process before they are added to the approved supplier list.
This process includes, where appropriate:
- Completion of a Supplier Onboarding Questionnaire.
- Completion of a Health & Safety Questionnaire.
- Verification of company details through Companies House.
- Verification of VAT registration where applicable.
- Review of the supplier's suitability for the goods or services being provided.
Approval of new suppliers requires authorisation by a Director together with the Sales Operations Manager.
These checks help ensure the Company only engages with legitimate organisations that operate in accordance with legal and ethical standards.
Financial Controls
Genius Energy Lab maintains financial controls designed to ensure that all transactions are accurate, transparent and appropriately authorised.
The Company uses Sage Accounting to maintain its financial records.
The Company has established the following financial controls to ensure appropriate authorisation, accountability and accurate financial reporting:
- Supplier invoices are authorised by the General Manager before payment.
- Purchase orders require approval from a Director or the General Manager before goods or services are ordered.
- Employee expense claims must be approved by the General Manager before reimbursement.
- Company payments are made only by the CEO or the General Manager through approved company banking arrangements.
- Accurate financial records are maintained for all business transactions.
These procedures help ensure appropriate oversight of financial activity and reduce the risk of fraud or financial misconduct.
Tax Compliance Arrangements
Genius Energy Lab is committed to meeting all of its UK tax obligations accurately and on time.
The Company maintains accurate financial records using Sage Accounting and appoints Hames Partnership Limited, an independent professional accountancy firm, to provide accounting and taxation services. Hames Partnership Limited prepares the Company's statutory accounts, advises on tax matters and supports the Company in meeting its obligations for Corporation Tax, VAT, PAYE and National Insurance.
The Company ensures that:
- all tax returns are submitted accurately and on time;
- taxes are paid in accordance with HMRC requirements;
- complete supporting records are maintained for all financial transactions;
- any tax advice received from Hames Partnership Limited is implemented where appropriate; and
- the Company fully cooperates with HMRC and other regulatory authorities where required.
The Company will never knowingly participate in, or facilitate, tax evasion or any arrangement intended to evade UK or overseas tax liabilities.
Risk Assessment and Proportionate Prevention Procedures
Genius Energy Lab has assessed the risk of the criminal facilitation of tax evasion within its business. Due to the nature and size of the Company, the risk is considered to be low.
The principal areas of risk include:
- payroll and PAYE administration;
- VAT and Corporation Tax compliance;
- supplier and subcontractor payments;
- employee expense claims; and
- procurement and purchasing activities.
To reduce these risks, the Company:
- uses Sage Accounting to maintain accurate financial records;
- appoints Hames Partnership Limited as its independent professional accountants;
- carries out due diligence on suppliers and subcontractors before engagement;
- requires approval of invoices, purchase orders and expenses;
- restricts authority for company payments to authorised personnel; and
- maintains clear records to support all financial transactions.
These procedures are considered proportionate to the Company's size, activities and level of tax risk and are reviewed annually as part of the Company's management system.
Reporting Concerns
Any employee, contractor, supplier or other stakeholder who becomes aware of, or suspects, tax evasion, the criminal facilitation of tax evasion or any other financial wrongdoing should report their concerns as soon as possible.
Concerns may be raised with:
- A Line Manager.
- The General Manager.
- A Director.
Alternatively, concerns may be reported in accordance with the Company's
Whistleblowing and Grievance Policy.
All reports will be treated confidentially and investigated appropriately. No individual who raises a genuine concern in good faith will suffer retaliation as a result of doing so.
Monitoring and Review
Overall responsibility for this policy rests with the Chief Executive Officer.
The effectiveness of this policy forms part of the Company's management system and is reviewed alongside other company policies as part of the annual policy review process.
Where changes to legislation, business activities or internal procedures occur, this policy will be updated as necessary to ensure it continues to reflect the Company's operations and legal obligations.
This policy has been developed having regard to HMRC guidance issued under the Criminal Finances Act 2017 and reflects the Company's commitment to maintaining reasonable prevention procedures appropriate to its size, activities and risk profile.
Related Documents
This policy should be read alongside the following company documents:
- Company Handbook
- Whistleblowing and Grievance Policy
- Anti-Bribery Policy
- Supplier Onboarding Questionnaire
- Supplier Health & Safety Questionnaire