INVESTOR RELATIONS

The corporate criminal offences of failure to prevent the facilitation of tax evasion come into force on 30 September 2017. These offences attribute criminal liability to the business for the criminal acts of its employees, agents or those that provide services for or on its behalf. It applies to all businesses, wherever located, in respect of the facilitation of UK tax evasion and furthermore it applies to businesses with a UK connection in respect of the facilitation of non-UK tax evasion.

There are three stages to the offences: the criminal tax evasion by a taxpayer; the criminal facilitation of the tax evasion by an 'associated person' of the business; and the business failed to prevent its representative from committing the criminal facilitation. There is a presumption of guilt.

However there is a defence if the business has put in place 'reasonable prevention procedures'. In establishing such procedures, each STM Group operating entity will:

• Assess the nature and extent of its exposure to the risk, of those who act for or on its behalf, engaging during the course of business, to criminally facilitate tax evasion. This will involve a risk assessment by senior management of each business unit.
• Put in place procedures that will be proportionate to the risk each business unit faces of persons associated with it committing tax evasion facilitation offences. This will depend on the nature, scale and complexity of each business unit's activities.
• Issue a top level statement that it is committed to preventing persons associated with it from engaging in criminal facilitation of tax evasion. It will endeavour to foster a culture in which activity intended to facilitate tax evasion is never acceptable. This would cover, amongst others, the disciplinary action taken against those breaching this and its commitment to whistleblowing processes.
• Consider its due diligence procedures, taking an appropriate and risk based approach, in respect of persons who perform or will perform services on behalf of the business units, in order to mitigate risks.
• Seek to ensure that its prevention policies and procedures are communicated, embedded and understood throughout the Company, through internal communication (including training) and external communication (to partner organisations, particularly those to or from whom clients are referred).
• Monitor and review its prevention procedures and make improvements where necessary.

The STM Group Board confirms zero tolerance of tax evasion within STM Group Plc and by any of its associates.