WorldFirst Policy

On 30 September 2017 the United Kingdom government brought into force the Corporate Criminal Offence (CCO) as part of the Criminal Finances Act 2017. The CCO subjects companies to criminal liability if they fail to prevent those who act for them, or on their behalf, from criminally facilitating tax evasion. Importantly for WorldFirst, this liability extends to any activity conducted on behalf of our clients.

The legislation has an extra-territorial effect meaning that it applies globally in cases where any underlying tax is owed to HM Revenue and Customs (HMRC). It is also applicable to instances where non-UK taxes are owed by a company incorporated in the UK, has a place of business in the UK or has had any aspect of the offence occur in the UK. As a UK regulated financial institution, WorldFirst Group is fully in scope for the CCO.

WorldFirst maintains a zero tolerance to all forms of tax evasion, whether under UK law or under the law of any foreign country. It is our policy to conduct all of our business dealings, both those directly related to WorldFirst itself and those of our clients, in an honest and highly ethical manner.

As such, any employee, contractor, associate or representative of WorldFirst must not undertake any transactions which:

1. Cause WorldFirst to commit a tax evasion offence; or,

2. Facilitate a tax evasion offence by any third-party that is not an associate of the company, including its clients

WorldFirst is committed to the following principles with regards to the risk of tax evasion by its clients:

• WorldFirst’s relationship with its clients are built on honesty, integrity, mutual trust and a commitment to professionalism.

• WorldFirst clients expect the company to give the best possible advice and work in their best possible interest.

• WorldFirst firmly believes that any action which would breach tax laws or the Criminal Finances Act is not in the best interest of its clients.

• Neither the company nor any person associated with the business will give advice to a client that would result in a breach of the Criminal Finances Act, either for WorldFirst or its client.

• WorldFirst will not support or work with clients who seek to criminally evade taxes, wherever in the world the tax is owed.