WARGAMING’S ANTI-FACILITATION OF TAX EVASION POLICY
WARGAMING’S ANTI-FACILITATION OF TAX EVASION POLICY
Current Version
1. Policy Statement
We are committed to conducting all our business in an honest and ethical manner. We adopt a zero-tolerance policy towards tax evasion, regardless of whether it violates the laws of Cyprus, the UK, the US, or any other applicable country. As an employer, we recognize that if we fail to prevent our employees, workers, agents, or service providers from facilitating tax evasion, we may face severe consequences, including unlimited fines and damage to our reputation. Therefore, we take our legal responsibilities very seriously. To fulfil these responsibilities and mitigate risks, we require all Wargaming employees and business partners to comply with this policy.
2. Applicability
This policy applies to all persons working for Wargaming in any capacity, including all employees, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.
3. Description
3.1 What is Tax Evasion and Tax Evasion Facilitation?
• Tax evasion means the offense of cheating the public revenue or fraudulently evading taxes and is a criminal offense. The offense requires an element of fraud, which means there must be deliberate action, or omission with dishonest intent.
• Foreign tax evasion means evading tax in a foreign country, provided that conduct is an offense in that country and could therefore also be a criminal offense if committed in Cyprus. As with tax evasion, the element of fraud means there must be deliberate action, or omission with dishonest intent.
• Tax evasion facilitation means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax in any country by another person, or aiding, abetting, counselling or procuring the commission of that offense. Tax evasion facilitation is a criminal offense, where it is done deliberately and dishonestly.
• Tax evasion is not the same as tax avoidance which refer to acts of using legal methods to minimize tax liability, or tax planning which refers to processes of analysing one’s financial situation in the most efficient manner. There is no minimum value threshold to tax evasion.
3.2 It is not acceptable for you (or someone on your behalf) to:
• Engage in any form of facilitating tax evasion or foreign tax evasion.
• Aid, abet, counsel or procure the commission of a tax evasion offense or foreign tax evasion offense
by another person.
• Fail to promptly report any request or demand from any third party to facilitate the fraudulent evasion of tax (whether Cyprus tax or tax in a foreign country), or any suspected fraudulent evasion of tax (whether Cyprus tax or tax in a foreign country) by another person, in accordance with this policy.
• Threaten or retaliate against another individual who has refused to commit a tax evasion offense or a
foreign tax evasion offense or who has raised concerns under this policy.
4. Responsibilities
All employees and associates of Wargaming are required to actively prevent, detect, and report any instances of tax evasion, including foreign tax evasion. It is our collective duty to uphold these standards.
You must refrain from engaging in any activities that could lead to or suggest a violation of this policy. If you believe or suspect that a breach of this policy has occurred or may occur in the future, you must report the incident to your manager, the Head of Global Compliance, or the Head of the Tax & Oversight function, as soon as possible.
Here are some "red flags" that may indicate potential incidents of tax or foreign tax evasion:
· If you learn that a third party has made or plans to make a false tax statement, failed to report income to the Cyprus Tax Authorities (or relevant local tax authority), delivered or intends to deliver false tax documents, or set up a structure to hide income or assets from a tax authority, please take note.
· you become aware that a third party has deliberately failed to register for VAT (or the equivalent tax in any relevant jurisdiction) or failed to account for VAT.
· a third-party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made .
· you become aware that an employee asks to be treated as a self-employed contractor, but without any material changes to their working conditions.
· a supplier or other subcontractor is paid gross when they should have been paid net,
· a third party requests that payment is made to a country or geographic location different from where the third-party resides or conducts business.
· a third party to whom we have provided services requests that their invoice is addressed to a different entity, where we did not provide services to such entity directly
· a third party to whom we have provided services asks us to change the description of services rendered on an invoice in a way that seems designed to obscure the nature of the services provided.
Please keep in mind that this list is for illustrative purposes only and is not comprehensive.
5. Report an incident
How to Raise a Concern about Tax Evasion
You are encouraged to raise concerns about any issue or suspicion of tax evasion or foreign tax evasion at the earliest possible stage.
If you become aware of any fraudulent evasion of tax in the course of your work, or you are asked to assist another person in their fraudulent evasion of tax (whether directly or indirectly), or if you believe or suspect that any fraudulent evasion of tax has occurred or may occur, please raise a concern with:
• Your direct manager
• Head of Compliance
• Head of Tax and Oversight Function
A corporate offense is committed when an individual intentionally and dishonestly aids tax evasion or foreign tax evasion. It is crucial to report any suspected tax evasion, as failing to do so or ignoring suspicious activity constitutes criminal facilitation of tax evasion.
Wargaming has established confidential and anonymous reporting channels, adhering to whistleblowing practices in our Code of Conduct. This allows employees and partners to report any concerns regarding tax evasion without fear of retaliation.
1. Policy Statement
We are committed to conducting all our business in an honest and ethical manner. We adopt a zero-tolerance policy towards tax evasion, regardless of whether it violates the laws of Cyprus, the UK, the US, or any other applicable country. As an employer, we recognize that if we fail to prevent our employees, workers, agents, or service providers from facilitating tax evasion, we may face severe consequences, including unlimited fines and damage to our reputation. Therefore, we take our legal responsibilities very seriously. To fulfil these responsibilities and mitigate risks, we require all Wargaming employees and business partners to comply with this policy.
2. Applicability
This policy applies to all persons working for Wargaming in any capacity, including all employees, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.
3. Description
3.1 What is Tax Evasion and Tax Evasion Facilitation?
• Tax evasion means the offense of cheating the public revenue or fraudulently evading taxes and is a criminal offense. The offense requires an element of fraud, which means there must be deliberate action, or omission with dishonest intent.
• Foreign tax evasion means evading tax in a foreign country, provided that conduct is an offense in that country and could therefore also be a criminal offense if committed in Cyprus. As with tax evasion, the element of fraud means there must be deliberate action, or omission with dishonest intent.
• Tax evasion facilitation means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax in any country by another person, or aiding, abetting, counselling or procuring the commission of that offense. Tax evasion facilitation is a criminal offense, where it is done deliberately and dishonestly.
• Tax evasion is not the same as tax avoidance which refer to acts of using legal methods to minimize tax liability, or tax planning which refers to processes of analysing one’s financial situation in the most efficient manner. There is no minimum value threshold to tax evasion.
3.2 It is not acceptable for you (or someone on your behalf) to:
• Engage in any form of facilitating tax evasion or foreign tax evasion.
• Aid, abet, counsel or procure the commission of a tax evasion offense or foreign tax evasion offense
by another person.
• Fail to promptly report any request or demand from any third party to facilitate the fraudulent evasion of tax (whether Cyprus tax or tax in a foreign country), or any suspected fraudulent evasion of tax (whether Cyprus tax or tax in a foreign country) by another person, in accordance with this policy.
• Threaten or retaliate against another individual who has refused to commit a tax evasion offense or a
foreign tax evasion offense or who has raised concerns under this policy.
4. Responsibilities
All employees and associates of Wargaming are required to actively prevent, detect, and report any instances of tax evasion, including foreign tax evasion. It is our collective duty to uphold these standards.
You must refrain from engaging in any activities that could lead to or suggest a violation of this policy. If you believe or suspect that a breach of this policy has occurred or may occur in the future, you must report the incident to your manager, the Head of Global Compliance, or the Head of the Tax & Oversight function, as soon as possible.
Here are some "red flags" that may indicate potential incidents of tax or foreign tax evasion:
· If you learn that a third party has made or plans to make a false tax statement, failed to report income to the Cyprus Tax Authorities (or relevant local tax authority), delivered or intends to deliver false tax documents, or set up a structure to hide income or assets from a tax authority, please take note.
· you become aware that a third party has deliberately failed to register for VAT (or the equivalent tax in any relevant jurisdiction) or failed to account for VAT.
· a third-party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made .
· you become aware that an employee asks to be treated as a self-employed contractor, but without any material changes to their working conditions.
· a supplier or other subcontractor is paid gross when they should have been paid net,
· a third party requests that payment is made to a country or geographic location different from where the third-party resides or conducts business.
· a third party to whom we have provided services requests that their invoice is addressed to a different entity, where we did not provide services to such entity directly
· a third party to whom we have provided services asks us to change the description of services rendered on an invoice in a way that seems designed to obscure the nature of the services provided.
Please keep in mind that this list is for illustrative purposes only and is not comprehensive.
5. Report an incident
How to Raise a Concern about Tax Evasion
You are encouraged to raise concerns about any issue or suspicion of tax evasion or foreign tax evasion at the earliest possible stage.
If you become aware of any fraudulent evasion of tax in the course of your work, or you are asked to assist another person in their fraudulent evasion of tax (whether directly or indirectly), or if you believe or suspect that any fraudulent evasion of tax has occurred or may occur, please raise a concern with:
• Your direct manager
• Head of Compliance
• Head of Tax and Oversight Function
A corporate offense is committed when an individual intentionally and dishonestly aids tax evasion or foreign tax evasion. It is crucial to report any suspected tax evasion, as failing to do so or ignoring suspicious activity constitutes criminal facilitation of tax evasion.
Wargaming has established confidential and anonymous reporting channels, adhering to whistleblowing practices in our Code of Conduct. This allows employees and partners to report any concerns regarding tax evasion without fear of retaliation.
