Ethical working policy

1. Why this policy exists

This policy explains MIO’s approach to preventing tax evasion. We are committed to meeting high standards of legal and ethical compliance.

UK law (the Criminal Finances Act 2017) makes organisations criminally liable if they fail to prevent someone acting on their behalf from helping another person evade tax. This policy is maintained to support compliance obligations requested by clients and partners.

2. Who this policy applies to

This policy applies to:

  • All employees and directors

  • Freelancers, contractors, and consultants

  • Anyone acting for or representing MIO (for example, agents or partners)

3. Our commitment

We have zero tolerance for:

  • Tax evasion

  • Helping someone else evade tax

We are committed to:

  • Acting with integrity and transparency

  • Keeping our finances accurate and complete

  • Meeting our legal and tax obligations

4. What is tax evasion?

Tax evasion is deliberately and dishonestly:

  • Not paying tax that is legally due

  • Under-reporting income

  • Providing false or misleading information to HMRC

It is different from legitimate tax planning, which must always be lawful and transparent.

5. What does ‘facilitation’ mean?

Facilitation means knowingly or dishonestly helping someone else to evade tax. This could include:

  • Creating or approving false invoices

  • Paying someone “off the books” to avoid tax

  • Misrepresenting payments or expenses

  • Turning a blind eye to suspicious financial activity

6. Your responsibilities

All staff and everyone associated with MIO must:

  • Act honestly in all financial and administrative work

  • Follow agreed processes for payments, expenses, and invoicing

  • Never assist or encourage tax evasion

  • Raise concerns if something does not feel right

You are not expected to be a tax expert, but you are expected to speak up if you notice something unusual or concerning.

7. How we reduce risk (reasonable prevention procedures)

Given our size, we use proportionate and practical controls, including:

  • Clear separation between creating, approving, and paying invoices where possible

  • Use of qualified accountants or payroll providers

  • Written agreements with freelancers and contractors

  • Keeping clear and accurate financial records

  • Reviewing financial activity regularly

8. Reporting concerns

If you are worried about possible tax evasion or dishonest financial behaviour, you should report it as soon as possible to:

  • The CEO or Director of Operations, or

  • Our external accountant, if appropriate

Concerns will be taken seriously, handled confidentially, and investigated fairly. No one will suffer retaliation for raising a genuine concern.

9. Consequences of breaches

Breaching this policy may lead to:

  • Disciplinary action

  • Termination of contracts

  • Potential civil or criminal consequences

10. Client and third-party assurance

We recognise that clients may require assurance that appropriate policies and controls are in place. This policy may be shared with clients or partners as evidence of our commitment to compliance, integrity, and lawful conduct.

11. Review and approval

This policy is reviewed regularly and updated when needed, including where client or regulatory requirements change.

Approved by: Melanie Sanders

Role: Director of Operations

Date: 17 December 2025