Modern Slavery Act Statement
This statement and our commitments hereunder are made in accordance with section 54 of the UK Modern Slavery Act 2015 (“The Act”). We commit to undertake suitable due diligence when considering our relationships with clients, service providers, contractors, employees and business partners in order to meet the requirements of The Act.
Although GCAL is incorporated in England and Wales and based in the UK, GCAL will from time to time work with suppliers, contractors and clients (“parties) based outside of the UK. Owing to our global operations, we recognise that some parties may present a higher risk and through our due diligence processes and terms of engagement with these parties, we will put in place measures to reduce risk and in circumstances of breach of The Act, we will terminate those relationships as part of our zero tolerance principles.
The UK Bribery Act 2010
Bribery can be defined as ‘giving someone a financial gain or other advantage to encourage them to perform their duties improperly or reward them for having done so’ and we are committed to preventing bribery through our Anti Bribery and Corruption policies and procedures. Bribery is a crime and it contributes towards economic and social instability, entrenches poverty and attacks the principles of equality and universal human rights.
Our policies and procedures are applied to to all GCAL employees, including any of those connected with our subsidiaries or associated companies. We also have policies and procedures in place that apply to individuals or corporate entity(s) associated with GCAL or those who perform services in relation to or on behalf of GCAL including, but not limited to, directors, agency employees, contractors, consultants, agents, suppliers and sponsors (“associated parties”). All employees and associated parties are expected to comply with our relevant Anti Bribery policies and procedures.
Policies are in place to:
ensure we comply with applicable laws and regulations in the UK and any other country within which the GCAL is carrying out business
ensure an effective reporting regime and framework is in place with regard to suspected breaches of applicable laws and also to ensure all requirements of our policies are properly communicated to all employees and associated parties
ensure all employees and associated parties understand the risks associated with bribery and are provided with suitable guidance on how to recognise, prevent and report any suspected breaches of applicable policies and laws
Criminal Finances Act 2017
The UK Criminal Finances Act 2017 (“CFA”) came into effect from 30 September 2017 and is intended to strengthen previous provisions within the Proceeds of Crime Act 2002, in particular, areas of Tax Evasion and criminal facilitation of Tax Evasion in circumstances of client and associated person relationships. Where GCAL already commits to prevent and not engage in any form of Tax Evasion in our commitments to comply with relevant laws on reporting of financial results and commercial relationships with associated persons and employees, we feel, given the nature of our business, the services we provide and the relationships we have with various associated parties, it is appropriate for us to make a specific statement of our commitments under CFA.
CFA incorporates two new corporate criminal offences of failure to prevent the facilitation of UK, and foreign tax evasion, by a person associated with a relevant body. A relevant body is a legal entity such as a company or partnership that can commit and offence.
The act seeks to widen the scope as to who can be held accountable for tax evasion and facilitation of tax evasion so that corporates can be held criminally liable for the acts of their associated persons who facilitate tax evasion.
GCAL commits not to facilitate or participate in any activities that would result in tax evasion either in the UK or outside of the UK and will ensure compliance with CFA and other relevant legislation by:
- Conducting due diligence on all associated parties to include screening for any pending or concluded cases of tax evasion;
- Ensure associated persons are able to contract with GCAL and that, in doing so, are as a consequence of any contractual agreements are able to meet the tax requirements of the relevant jurisdiction, whether UK or foreign jurisdiction;
- Ensuring all employees and associated parties are aware of GCAL’s relevant reporting procedure(s) in regard to suspicion of tax evasion or other tax related criminal behaviour;
- Putting in place an ongoing monitoring regime to monitor compliance with applicable laws of all associated parties and relevant persons on a periodic basis;