MSP Capital policies

Bribery can be defined as ‘giving someone a financial gain or other advantage to encourage them to perform their duties improperly or rewarding them for having done so.’

Corruption is similar to bribery but is different as it covers actions that include the abuse of a position of power or authority. This includes unlawful conduct of private and public officials at all levels, and under UK laws, applies to activities performed here in the UK and overseas.

We believe that it is just and fair to combat bribery and corruption because they are crimes that contribute towards economic and social instability, entrenches poverty, and attacks the principles of equality and universal human rights.

MSP Capital is committed to taking all reasonable steps to prevent bribery and corruption, and to reporting these activities to the appropriate law enforcement agencies where this is necessary. We have implemented policies, controls, and procedures to identify and manage these risks, and these are defined in our Anti Bribery and Corruption Policy.

They are applicable to all MSP Capital employees, and any other associated parties who are acting for and on behalf of MSP Capital. This includes subsidiaries or associated companies and includes, but is not limited to, directors, agency employees, contractors, consultants, agents, suppliers, and sponsors.

The non-payment, or under-payment, of import duties and taxation is a crime in the UK. The facilitation of tax evasion is also a crime. These measures were enhanced on 30^th September 2017, when new criminal legislation in the form of the UK Criminal Finances Act 2017 (“the CFA”) came into effect.

The CFA introduced two new corporate criminal offences of failing to prevent the facilitation of UK and foreign tax evasion, by any person associated with MSP Capital. This includes directors and employees of MSP Capital, and other parties working for and behalf of MSP Capital such as agency employees, contractors, consultants, agents, suppliers, and sponsors.

MSP Capital has taken all reasonable steps to prevent the company being used by criminals, and to mitigate the risk that any employee, associated party, or customer conducts tax crimes. These measures include:

• Conducting appropriate and risk-based due diligence checks to identify higher risk activity, transactions, and relationships.

• Providing documented policies, controls, and procedures to define the risks and to confirm how MSP Capital manages and mitigates tax crime risks.

• Promoting an awareness of the requirement to comply with UK and overseas tax laws and regulations.
• Performing ongoing monitoring and assurance checks to identify risks and to confirm compliance with applicable tax laws and financial crime regulations.
• Implementing reporting procedures for employees, customers, and associates that can be used to report knowledge or suspicion relating to tax offences.

From identity fraud to falsifying or misrepresenting your authority to act for a firm or receive new lending – we know how important it is to stay vigilant when it comes to fraud.

We are aware that fraud activity continues to pose a significant threat to our customers and to our business and we continue to be committed to managing and mitigating the risk of financial crimes.

We have in place systems and controls to assess and identify fraud activity and we will not hesitate to report these concerns to the UK law enforcement agencies so that they may be investigated and prosecuted.

Further support:

Further help and information in identifying these risks can be found at: Take Five – To Stop Fraud | To Stop Fraud (takefive-stopfraud.org.uk)

You can also find more about how to report your concerns to the UK national fraud agency ‘Action Fraud’ by following the link: Action Fraud

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.