Anti-Facilitation Policy

Our position on tax evasion, money laundering and financial crime.

Statement

Meredith International Limited has a zero-tolerance approach to the facilitation of tax evasion, whether by our staff, our suppliers, our suppliers’ customers, or any other party connected with our services.

We commit to acting professionally, fairly and with integrity in all our business dealings, and to implementing and enforcing effective systems to counter the facilitation of tax evasion.

Scope

This policy applies to:

• all Meredith staff (employees, directors, contractors)
• all suppliers using the Meredith platform
• all customers paying invoices through Meredith
• all third parties acting on Meredith’s behalf

It covers tax evasion under the laws of any jurisdiction in which Meredith operates or in which our suppliers or their customers operate.

What Is Tax Evasion

Tax evasion is the illegal underpayment of tax due to a tax authority. It includes:

• failing to declare income or output VAT
• under-declaring income or output VAT
• claiming relief or input VAT to which the taxpayer is not entitled
• providing false information to a tax authority
• structuring transactions for the dominant purpose of evading tax

Tax evasion is distinct from tax avoidance (the lawful arrangement of affairs to reduce tax liability) and from tax planning. Meredith does not engage in or facilitate evasion. Meredith does not provide advice on avoidance or planning.

What Is Facilitation

Facilitation of tax evasion is helping another person to commit tax evasion, with knowledge or wilful blindness as to the underlying evasion. It does not require active intent — wilful blindness is sufficient under UK law (Criminal Finances Act 2017) and equivalent regimes elsewhere.

For Meredith specifically, facilitation could include:

• knowingly issuing invoices that omit VAT a supplier should have charged
• structuring invoices on a supplier’s instruction to avoid hitting a registration threshold
• ignoring obvious signals of tax evasion by a supplier
• failing to act on credible information of evasion

Our Controls

Meredith operates a documented set of preventive controls including:

• mandatory VAT registration validation at onboarding
• periodic re-validation of all registered suppliers
• threshold monitoring for unregistered suppliers approaching local registration thresholds
• cross-jurisdiction pattern monitoring
• supplier confirmation prompts on large invoices
• suspicious pattern detection on invoice content and supplier behaviour
• a designated Money Laundering Reporting Officer (MLRO) with responsibility for tax-facilitation matters
• the express right to suspend supplier accounts on reasonable suspicion
• staff training on recognition of evasion signals and escalation procedures
• annual review of all controls with external counsel
• comprehensive audit logging

The detailed control specification is held internally and is shared with regulators or partner banks on request.

Supplier Obligations

Suppliers using Meredith warrant that they will:

• provide accurate and complete information about their VAT registration status, jurisdiction and number
• update their status promptly on any change
• not use Meredith to issue invoices that misrepresent the VAT treatment that should apply
• not request Meredith to structure invoices for the purpose of evading any tax
• comply with all applicable tax laws in their own and their customers’ jurisdictions

These obligations are reflected in the Commercial Agent Agreement.

Consequences Of Breach

Where Meredith reasonably suspects that a supplier or other party is attempting to use the platform to facilitate tax evasion, Meredith will:

• immediately suspend the supplier’s account pending investigation
• retain (but not forfeit) any funds already collected on the supplier’s behalf
• investigate the matter, including requesting information from the supplier
• report the matter to the relevant Financial Intelligence Unit (NCA in the UK; equivalent elsewhere) where required
• terminate the supplier agreement where evasion is established
• cooperate fully with any tax authority or law enforcement investigation

Meredith will not return funds collected from customers to a supplier where to do so would itself facilitate evasion. Funds in such cases are held pending lawful direction.

Reporting Suspected Evasion

Meredith staff are required to report any suspected facilitation or evasion to the MLRO immediately.

External parties (suppliers, customers, members of the public) suspecting evasion involving Meredith may report it confidentially to mlro@meredithint.com.

Reports made in good faith will not result in detriment to the reporter.

Cooperation With Authorities

Meredith cooperates fully with tax authorities and law enforcement in any investigation into suspected evasion or facilitation.

Meredith complies with all lawful information requests from competent authorities and reserves the right to disclose information about supplier activity where required by law or where Meredith reasonably believes disclosure is necessary to prevent or detect crime.

Governance

This policy is owned by the Meredith board.

It is reviewed annually and after any material regulatory change.

The MLRO is responsible for day-to-day implementation.

Material breaches and remediation actions are reported to the board at each meeting.

Contact

mlro@meredithint.com

Meredith International Limited
13/1 Line Wall Road
Gibraltar GX11 1AA