Kero Tax Compliance & Anti-Facilitation of Tax Evasion Policy

1. Purpose

This policy establishes commitments for Kero and its personnel to prevent tax evasion facilitation under the Criminal Finances Act 2017 (UK) and Tax Administration Act 2011 (South Africa). It outlines procedures to detect, prevent, and report tax evasion instances.

2. Policy Statement

Kero conducts business with transparency and ethics, maintaining zero-tolerance for tax evasion or its facilitation by employees, officers, contractors, or third parties. The organization upholds all applicable anti-tax evasion laws across its operating jurisdictions.

3. Definitions

Tax Evasion: Illegal non-payment or underpayment of taxes, distinguished from lawful tax avoidance.

Facilitation of Tax Evasion: Aiding, abetting, or enabling tax evasion by another person, including providing advice or services that assist commission of tax evasion.

4. Responsibilities

Management shall communicate this policy to Associated Persons, provide compliance training, seek professional advice on tax obligations, implement management systems for tax compliance, and establish reporting procedures.

Employees and Associated Persons must comply with this policy and relevant tax evasion prevention laws, reporting any non-compliance concerns per established procedures.

The Compliance Officer oversees implementation, conducts risk assessments, and serves as contact point for tax evasion inquiries or reports.

5. Risk Assessment

Kero conducts regular risk assessments identifying mitigation strategies. Assessment areas include: general tax compliance obligations, accurate transaction classification, correct tax calculation and reporting, accurate payroll deductions, independent contractor and personal service company taxation, and other addressable risks through business processes and due diligence.

6. Training and Communications

Kero provides training to employees and Associated Persons on policy responsibilities, anti-tax evasion importance, and reportable red flags. This policy is communicated upon implementation and after significant updates.

7. Reporting Suspected Tax Evasion

Kero encourages reporting tax evasion or facilitation suspicions anonymously to the Compliance Officer or confidential hotline. The organization ensures no detrimental treatment occurs for good-faith reporting of actual or potential tax evasion facilitation.

8. Breaches of the Policy

Non-compliance is taken seriously and may result in disciplinary action, employment or contract termination, authority reporting, and legal consequences.

9. Review and Monitoring

This policy undergoes annual review and updates to maintain legal compliance and reflect operational or business practice changes.

The policy represents Kero's commitment to lawful and ethical conduct. Inquiries should be directed to the Compliance Officer or appointed representative.

10. Responsibilities for the Process

The Director: Operations or appointed representative holds responsibility for policy preparation, verification, issuance, filing, and updates. The Compliance Officer or appointed representative monitors, measures, and continuously improves the procedure.