Statement from the Bolster Group Board: Anti-Facilitation of Tax Evasion
At Bolster Group, we uphold the highest standards of integrity, transparency, and compliance in every aspect of our operations. We recognize that tax evasion is a serious crime that undermines social and economic systems. We are unequivocally committed to preventing the facilitation of tax evasion by our employees, partners, clients, or any associated persons.
This statement outlines our zero-tolerance approach to tax evasion and our commitment to compliance with all applicable laws, including the UK Criminal Finances Act 2017, and similar legislation in other jurisdictions where we operate.
Our Commitment
- Zero Tolerance
Bolster Group does not tolerate tax evasion or the facilitation of tax evasion in any form. We are dedicated to fostering a culture of ethical behavior and compliance throughout our organization. - Compliance with the Law
We are committed to complying with the tax laws and regulations in all jurisdictions where we operate. This includes identifying and mitigating any risks related to tax evasion and ensuring that our employees and partners act in full compliance with these laws. - Accountability and Leadership
The Board of Directors takes full accountability for implementing and maintaining effective systems and controls to prevent tax evasion facilitation. This commitment cascades through all levels of our organization.
Our Approach
To ensure compliance and prevent the facilitation of tax evasion, Bolster Group has implemented a robust framework based on the following pillars:
1. Policies and Procedures
We have established and continuously update clear policies and procedures to identify and mitigate risks associated with tax evasion. These include:
- A comprehensive Anti-Facilitation of Tax Evasion Policy.
- Strict guidelines for employees, contractors, and associated persons.
- Incorporation of tax compliance requirements into all contracts and agreements.
2. Risk Assessment
We conduct regular risk assessments to identify potential exposure to tax evasion facilitation across our operations and supply chains. These assessments focus on:
- High-risk jurisdictions and industries.
- Transactions involving complex tax arrangements.
- Relationships with third-party suppliers, contractors, and clients.
3. Due Diligence
We perform thorough due diligence on all counterparties, including clients, suppliers, and intermediaries. This ensures that our business relationships align with our commitment to compliance and ethical practices.
4. Training and Awareness
We provide regular training to employees, ensuring they understand:
- The importance of compliance with tax laws.
- How to identify red flags for tax evasion.
- Their obligation to report concerns about unethical or illegal practices.
5. Reporting and Whistleblowing
Bolster Group encourages the reporting of any suspicions or concerns related to tax evasion through our Whistleblowing Policy. Reports can be made confidentially and without fear of retaliation. All reported concerns are investigated thoroughly and acted upon promptly.
6. Monitoring and Review
We continuously monitor and review our systems, policies, and procedures to ensure they remain effective in addressing emerging risks. Independent audits and assessments are conducted periodically to verify compliance and effectiveness.
Responsibilities of Employees and Partners
Employees
Every employee has a duty to:
- Act in accordance with Bolster Group’s policies and procedures.
- Avoid engaging in or facilitating any form of tax evasion.
- Report any suspected tax evasion or related misconduct.
Partners and Third Parties
We expect all partners, contractors, and associated persons to:
- Adhere to Bolster Group’s Anti-Facilitation of Tax Evasion Policy.
- Maintain transparent and lawful tax practices.
- Cooperate fully in any investigations or audits related to tax compliance.
Consequences of Non-Compliance
Non-compliance with Bolster Group’s Anti-Facilitation of Tax Evasion Policy, or any applicable laws, will result in:
- Immediate disciplinary action, up to and including termination of employment or contracts.
- Reporting of unlawful activity to relevant authorities.
- Termination of relationships with non-compliant third parties.
Looking Ahead
Bolster Group is committed to setting a benchmark for ethical business practices in the global consultancy sector. We will continue to enhance our policies, training, and due diligence to adapt to evolving tax regulations and compliance challenges. By upholding our zero-tolerance stance, we aim to build a culture of integrity that safeguards our clients, employees, and stakeholders.
Contact Us
If you have any questions about our Anti-Facilitation of Tax Evasion Policy or wish to report a concern, please contact us at:
Email: legal@bolster-group.com
Phone: +971 4 589 4111
This statement has been approved by the Bolster Group Board of Directors and will be reviewed annually to ensure ongoing compliance with all applicable laws and regulations.
Bolster Group
Date: 17 January 2023
Email: legal@bolster-group.com
Phone: +971 4 589 4111
Address: Floor 20, Boulevard Plaza, Downtown, Dubai, P.O.Box: 413628
