Corporate Criminal Offence Policy

1. Policy statement

Echo-9 Shared Services Ltd ('Echo-9') is committed to conducting its business with the highest standards of integrity and ethics. We have a zero-tolerance approach to tax evasion and the facilitation of tax evasion. This policy applies to EchoDesk and our other shared services.

In line with the UK Criminal Finances Act 2017, Echo-9 will not tolerate any person associated with the company — including employees, agents, consultants or contractors — deliberately helping a third party to evade taxes in the UK or abroad.

Zero tolerance: Any breach of this policy will be treated as a matter of gross misconduct for employees and a material breach of contract for third parties.

2. Scope and application

This policy applies to all individuals working at all levels of Echo-9, including:

• Senior managers, officers and directors
• Employees (permanent, fixed-term or temporary)
• Consultants, contractors and agency staff
• Any other person associated with us, providing services for or on behalf of Echo-9

3. Definitions

Tax evasion: The illegal non-payment or underpayment of taxes. It involves a person or entity deliberately misrepresenting their affairs to the tax authorities to reduce their tax liability.

Facilitation of tax evasion: Being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax by another person. Under the Act, this is a corporate criminal offence for the company if an associated person helps a third party evade tax.

4. Our prevention procedures

To mitigate the risk of facilitating tax evasion, Echo-9 implements the following reasonable procedures:

4.1 Risk assessment

We perform regular assessments of our business activities to identify areas where there is a risk of an associated person facilitating tax evasion. This includes reviewing our financial controls, payment processes and supplier onboarding.

4.2 Due diligence

We perform appropriate due diligence on all third parties before entering into contracts. This includes verifying the legitimacy of the entity and ensuring they have their own compliance standards in place.

4.3 Training and communication

All staff are briefed on this policy as part of their induction. Regular updates are provided to those working in high-risk areas such as Finance, Procurement and Sales.

5. Prohibited conduct

It is strictly prohibited for any person associated with Echo-9 to:

• Engage in any form of facilitation of tax evasion
• Aid, abet, counsel or procure the commission of a tax evasion offence by another person
• Fail to report any request or demand from a third party to facilitate tax evasion
• Make payments to third parties in cash or to offshore accounts without verified business justification and management approval

6. Reporting concerns

If you become aware of any suspicious activity or believe that an act of tax evasion facilitation has occurred or may occur, you must report it immediately.

Reports should be made to the Compliance Officer or through Echo-9's established whistleblowing procedure. Echo-9 guarantees that no individual will suffer any detrimental treatment as a result of reporting a concern in good faith.

7. Governance and review

The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations. This policy will be reviewed annually to ensure it remains effective and reflects current legal requirements.

© 2026 Echo-9 Shared Services Ltd.