Tax Compliance and Anti-Facilitation of Tax Evasion Policy

PURPOSE

The purpose of this Tax Compliance and Anti-Facilitation of Tax Evasion Policy is to set forth the commitments and responsibilities of BulkSMS and its employees, officers, contractors, and any third parties acting in BulkSMS’s name to prevent the facilitation of tax evasion in accordance with the Criminal Finances Act 2017 of the United Kingdom and the Tax Administration Act 2011 of South Africa. This policy outlines the procedures and guidelines established by BulkSMS to detect, prevent, and report any instances of tax evasion or the facilitation thereof.

POLICY STATEMENT

BulkSMS is committed to conducting its business dealings in a transparent, honest, and ethical manner. We have a zero-tolerance approach to tax evasion and the facilitation of tax evasion by any of our employees, officers, contractors, or any third parties acting on our behalf. We are dedicated to upholding all laws and regulations designed to combat tax evasion in all the jurisdictions in which we operate.

SCOPE

This policy applies to all individuals working for or on behalf of BulkSMS, across all offices and subsidiaries globally. This includes, but is not limited to, all employees (whether permanent, fixed-term, or temporary), directors, officers, contractors, consultants, and any other person or entity associated with BulkSMS (collectively referred to as "Associated Persons").

DEFINITIONS

Tax Evasion: The illegal non-payment or underpayment of taxes. Tax evasion is distinct from tax avoidance, which refers to legitimate and lawful minimization of tax liabilities.
Facilitation of Tax Evasion: The offence of aiding, abetting, or otherwise facilitating the commission of tax evasion by another person, including providing specific advice or services that enable another person to commit tax evasion.

RESPONSIBILITIES

Management: Ensure that this policy is communicated to all Associated Persons, that adequate training is provided to ensure understanding and compliance, that professional advice is sought where appropriate to monitor and address our tax compliance obligations and changes in regulatory requirements, that adequate management systems are in place to facilitate or automate tax compliance and that procedures are in place for the reporting of tax evasion or breaches of this policy.
Employees and Associated Persons: Comply with this policy and the relevant laws governing the prevention of tax evasion and the facilitation thereof. Report any concerns or suspicions of non-compliance in accordance with the reporting procedures outlined in this policy.
Compliance Officer, or duly appointed representative: Oversee the implementation of this policy, conduct regular risk assessments, and serve as a point of contact for any inquiries or reports related to tax evasion.

RISK ASSESSMENT

BulkSMS will conduct regular risk assessments to identify and mitigate risks associated with tax evasion and its facilitation within our operations and business relationships. Our risk assessment areas include, but are not limited to, risks associated with the general tax compliance obligations, including requirements to accurately classify transactions, to accurately calculate and report on tax returns, to make accurate payroll deductions, risks associated with independent contractors and personal service companies required to pay their own taxes for services paid for by BulkSMS and other identifiable risks that can be addressed or mitigated through the implementation of specific business processes and due diligence checks.

TRAINING AND COMMUNICATIONS

BulkSMS will provide training to all employees and Associated Persons on their responsibilities under this policy, the importance of adhering to anti-tax evasion measures and common red-flags that ought to be reported. This policy will be communicated to all Associated Persons upon its implementation and whenever significant updates are made.

REPORTING SUSPECTED TAX EVASION

BulkSMS encourages all Associated Persons to report any concerns or suspicions of tax evasion or the facilitation thereof. Reports can be made anonymously to the Compliance Officer or through BulkSMS's confidential reporting hotline. BulkSMS is committed to ensuring that no individual suffers any detrimental treatment as a result of reporting in good faith their suspicion that an actual or potential facilitation of tax evasion has taken place.

BREACHES OF THE POLICY

Non-compliance with this policy will be taken seriously and may result in disciplinary and other action, including termination of employment or contract, reporting matters to relevant authorities and other possible legal consequences.

REVIEW AND MONITORING

This policy will be reviewed annually and updated as necessary to ensure compliance with applicable laws and regulations and to reflect any changes in BulkSMS's operations or business practices.
This Tax Evasion Policy is a crucial component of BulkSMS's commitment to lawful and ethical conduct. All questions or concerns regarding this policy should be directed to the Compliance Officer, or duly appointed representative.

RESPONSIBILITIES FOR THE PROCESS

The responsibilities for the preparation, verification, issue, filing and up-dating of this policy and associated processes is the duty of the Director: Operations or duly appointed representative. The monitoring, measuring and continual improvement of the procedure or process is the responsibility of the Compliance Officer or duly appointed representative.