Criminal Finance Act Statement

POLICY STATEMENT

The Luxury Travel Group is committed to preventing the facilitation of tax evasion by associated individuals or businesses (‘Associated Person’) anywhere within its operations. The statement governs all our business dealings and the conduct of all persons or organizations who are appointed to act on our behalf.

We conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to facilitating tax evasion, whether under UK law or under the law of any foreign country. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate; and to implementing and enforcing effective systems to counter tax evasion facilitation. We will uphold all laws relevant to countering tax evasion, including the Criminal Finances Act 2017, in all the jurisdictions in which we operate. The Luxury Travel Group Ltd and its subsidiary’s do not and will not knowingly work with others who do not share their commitment to preventing the facilitation of tax evasion.

ACCOUNTABILITY & GOVERNANCE

This statement and the commitment to our responsibilities under the criminal finance act has been approved by the risk and audit committee. Mark Woodall as the Chief Financial Officer is responsible for monitoring compliance as part of the senior management team, ultimately overseen by Sonia Davies, CEO.

This policy statement will be published on Scott Dunn Limited website as a public statement of the Groups commitment to CFA principles and our full policy will be communicated to all staff and reviewed annually.

EMPLOYEE RESPONSIBILITY

Our code of conduct sets the standards of behaviour we expect all employees to adhere to. Any actions that breach the Criminal Finances Act and the tax laws of wherever we operate will not be tolerated.

Any employee who has any concerns relating to any potential breach of this policy must immediately follow our whistleblowing policy and report the matter without delay.

TRAINING AND COMMUNICATION

All employees will take part in internal prevention of tax evasion training to familiarise themselves and ensure they have the appropriate level of knowledge for their specific roles. All employees must consider tax evasion-focused communications from senior management and be aware of the latest internal information regarding prevention of tax evasion.

RISK ASSESSMENT

An internal risk assessment has taken place which covers the categories of business we are involved in where there is a risk of tax evasion. This has been reviewed by the Risk and Audit committee and used to assess our prevention procedures and put in place mitigation.

OUR COMITMENT

• Our business is carried out fairly, honestly, and openly in every part of our work.
• We will never knowingly buy or sell any product or services where we know or suspect that any aspect of the transaction is being misused, abused or otherwise corrupted for the purposes of tax evasion.
• We will immediately terminate any agreement or business relationship as soon as our company learns of or suspects tax evasion may be taking place.
• Our policy, risk assessment and statement will be reviewed on an annual basis by our senior management team to ensure our due diligence.
• Our staff will receive annual training to ensure our prevention procedures are understood and embedded throughout the organization.