Our position
We do not evade tax, we do not help anyone else to evade tax, and we do not commit fraud or help others to commit it. This applies to our own business and to the way we build, configure and support the Service, which agencies use to pay workers and invoice their clients.
Facilitating tax evasion: the law
Part 3 of the Criminal Finances Act 2017 created two corporate offences. A company commits an offence if a person associated with it, such as an employee, contractor or agent, criminally facilitates tax evasion while acting for it. Section 45 covers the evasion of UK tax. Section 46 covers, in certain circumstances, the evasion of tax in other countries.
These offences apply to companies of every size, including Templace. The company does not have to know about the facilitation. Its defence is to show that it had reasonable prevention procedures in place, or that it was not reasonable to expect it to have them. The penalty is an unlimited fine.
Failure to prevent fraud: the law
The Economic Crime and Corporate Transparency Act 2023 created a further offence of failure to prevent fraud, in force since 1 September 2025. An organisation commits it if a person associated with it commits a specified fraud offence, such as fraud by false representation or false accounting, intending to benefit the organisation or its clients, and the organisation did not have reasonable fraud prevention procedures.
This offence applies only to large organisations: those that meet at least two of these three conditions: more than 250 employees, more than £36 million turnover, and more than £18 million in total assets. Templace is not a large organisation, so the offence does not apply to us.
We adopt the same reasonable procedures anyway. The risks are the same whatever our size, and agencies rely on the records the Service keeps.
Where the risks are
We have looked at where these risks could arise in our business. The main ones are:
- an agency asking us to configure or change the Service to hide or misdescribe pay, for example to present earnings as expenses, treat employees as self-employed, or keep payments out of the records;
- someone asking us to alter, back-date or delete records, invoices or timesheets after the event;
- our own invoicing and accounts, including VAT;
- a supplier or contractor asking to be paid in a way that avoids tax, such as in cash or into an account in someone else's name;
- bank detail fraud, where someone poses as a supplier or customer to divert a payment.
Our prevention procedures
Our procedures follow the principles in HMRC's guidance on the Criminal Finances Act 2017 and the government's guidance on failure to prevent fraud: top-level commitment, risk assessment, proportionate procedures, due diligence, communication and training, and monitoring and review. In practice:
- The Director owns this policy and reviews our risk assessment at least once a year.
- We do not build, configure or support any feature whose purpose is to hide income from HMRC or to misstate pay, tax or VAT. Agencies remain responsible for their own pay and tax decisions.
- Every change in the Service is recorded in an audit trail the agency can see, so records cannot be quietly rewritten.
- We check suppliers and contractors before we engage them, pay them only into an account in their own business name, and confirm any change of bank details through a contact route we already know.
- Our own invoices are issued monthly and paid by bank transfer only. We do not take cash.
- Everyone who works for us reads this policy when they start and whenever it changes.
Reporting a concern
If you suspect that anyone, inside or outside Templace, is evading tax, helping someone else to evade it, or committing fraud, tell the Director at terry@hilliernet.co.uk or on 07789 938284 within 2 working days. Do not raise your suspicion with the person concerned.
You can also use our whistleblowing policy, or report directly to HM Revenue and Customs, which is a prescribed person for tax matters, or to the Serious Fraud Office for serious or complex fraud.
If an agency asks us to do something we believe would facilitate tax evasion or fraud, we will refuse, explain why in writing, and may end the contract under our terms.
Breaches and review
Anyone who works for us and facilitates tax evasion or fraud will have their contract ended or, if we employ them, face disciplinary action, and we will report the matter to the authorities. The Director reviews this policy at least once a year and whenever the law changes.
Preventing fraud and the facilitation of tax evasion · version 1.0 · approved 27/10/2026 · next review 27/10/2027. Templace is a trading name of TWH Holdings Limited, company number 10663539, Meadway, Mill Road, Writhlington, Radstock, BA3 5TY.