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It sets out the commitment of the ���Ｇ of London to preventing persons associated with the ���Ｇ and its subsidiaries from engaging in the criminal facilitation of tax evasion.

���Ｇ Statement on Commitment to the Prevention of Facilitation of Tax Evasion

Introduction

Tax evasion is when individuals or businesses deliberately omit, conceal, or misrepresent information to reduce their tax liabilities. Organisations can be used by associated individuals or businesses to facilitate taxpayer evasion in the UK or overseas.

The ���Ｇ of London is committed to preventing the facilitation of tax evasion by associated individuals or businesses anywhere within its operations. We do this through the development of reasonable prevention procedures, carrying out regular due diligence and risk assessments of our activities and creating awareness and a culture of compliance throughout the ���Ｇ. We also use our strategic planning processes to identify possible risks for future activity, possible changes in legislation and through efficient and effective contract management.

1.0 The ���Ｇ of London

The ���Ｇ of London is a federation of 17 independent member institutions of outstanding reputation, and several highly acclaimed central academic bodies and activities. Since our foundation in 1836, we have built a distinctive approach to learning, teaching, and research, have provided high-quality and innovative services and have maintained an extensive portfolio of property located primarily in Bloomsbury, the heart of London’s Education Quarter. We collaborate to deliver world-leading services including the Senate House Library, the Careers Group and CoSector; and, through our ���Ｇ of London distance learning programmes, we reach out to thousands of students across 190 countries globally.

This statement covers the activities of the ���Ｇ of London itself and its trading subsidiaries. The academic portfolio covers the ���Ｇ of London distance learning programmes; the School of Advanced Study (SAS) and its constituent Institutes; Senate House Library (SHL); the ���Ｇ of London Institute in Paris (ULIP) and the Careers Group. Beyond that, the ���Ｇ also provides a suite of innovative, high-quality academic support and professional services, and manages a valuable property portfolio providing teaching and learning space, student halls of residence and conference facilities. The active trading subsidiaries, all wholly owned by the ���Ｇ are CoSector Limited, Senate House Services One Limited, and Senate House Worldwide Limited.

2.0 Risk Assessment and Implementation of Prevention Procedures

The ���Ｇ is committed to embedding processes which will help eliminate the opportunities for the criminal facilitation of tax evasion.

The ���Ｇ undertakes risk assessments of all operations to determine the nature and extent of exposure to the risk of any “associated persons” engaging in activity that could criminally facilitate tax evasion. Reasonable prevention procedures proportionate to the size, complexity and risk are implemented.

The ���Ｇ maintains a register of possible risks of the facilitation of tax evasion by its staff and associates, as well as listing controls to mitigate those risks, and any actions required to improve those controls. This register is regularly reviewed and updated, as and when required in relation to the nature of the specific risks.

3.0 Due Diligence

Due diligence on both customers and suppliers is undertaken to ensure that the risk of potential interactions with the ���Ｇ or its subsidiaries being used by associated persons to engage in the criminal facilitation of tax evasion is clearly identified before any transactions take place. This due diligence will be proportionate to the identified risk.

4.0 Raising Awareness & Collaboration

As the strategic knowledge base for Tax at the ���Ｇ of London, the Finance Department is committed to staying aware of developments, legislation, and case studies regarding the prevention of the criminal facilitation of tax evasion. Eliminating the opportunities to facilitate tax evasion effectively requires improved traceability, increased transparency and collaboration between statutory agencies, civil society organisations and both public and private sector business.

• The ���Ｇ has nominated a key officer responsible for information and queries on CFA2017 within our organisation – the Key Officer for CFA 2017 is Rita Akushie, Pro Vice-Chancellor (Finance and Operations).
• The ���Ｇ’s Organisational & Staff Development Team are incorporating training on CFA2017 into the ���Ｇ’s required Training Programme.
• The ���Ｇ has nominated the following officers responsible for information and queries on CFA2017 within the areas that they support:
  • Finance: Director of Finance
  • Distance Education: Executive Director, Worldwide
  • General: Head of Tax
• We will work in collaboration with other universities and external bodies such as Office for Student, BUFDG, HMRC and LUPC, to share and develop best practice in due diligence, prevention procedures and the elimination of the criminal facilitation of tax evasion.
• The ���Ｇ’s Finance Director is responsible for supply chain management transparency and initiatives.

���Ｇ staff are encouraged to speak to any of the nominated officers listed above if they have any questions or concerns about tax evasion. If any individual suspects that any person associated with the ���Ｇ and its subsidiaries is engaging in the criminal facilitation of tax evasion, it must be disclosed as soon as possible to one of the Key Officers named above. In cases where a member of staff believes that informing the Key Officers would be inappropriate, they should consult the ���Ｇ Secretary and/or follow the procedures outlined in Ordinance 23 (Public Interest Disclosure which sets out the ���Ｇ’s ‘whistleblowing’ procedure).

5.0 Consequences for any associated person breaching the ���Ｇ’s commitment to zero tolerance towards the criminal facilitation of tax evasion.

Any staff member who fails to meet the ���Ｇ’s commitment to zero tolerance towards the criminal facilitation of tax evasion, may be subject to disciplinary action under the ���Ｇ’s Disciplinary Procedure (21 August 2018) including potential summary dismissal. The staff member may also be personally liable to criminal prosecution in the UK under existing tax evasion laws.

We use our best endeavours to challenge customers and suppliers that do not meet our standards regarding prevention of the criminal facilitation of tax evasion. Such customers or suppliers may also be liable to prosecution under the provisions of the Criminal Finance Act 2017.

In the supplier selection phase of the ���Ｇ’s Procurement Process, we may remove from competition suppliers that do not agree with the ���Ｇ’s policies or who have poor supply chain practices in place. In contract management, contracted suppliers will be required to take the necessary action to improve their service delivery and we will work with them to address any concerns. If the supplier does not improve the ���Ｇ may terminate the business relationship.