David Lloyd Leisure Corporate Criminal Offence Policy

This policy:

1. Sets out David Lloyd Leisure’s approach to the Corporate Criminal Offence of the Failure to Prevent the Criminal Facilitation of Tax Evasion (“CCO”) legislation (Criminal Finances Act 2017, Part 3);
2. Is reviewed at least annually; and 
3. Is endorsed by the Deuce Midco Limited Board. The Deuce Midco Limited Board does not condone tax evasion and is responsible for creating a culture which supports compliance.

What is the purpose of the CCO Policy?

The purpose of this CCO Policy is to communicate that in accordance with the Criminal Finances Act 2017, David Lloyd Leisure does not engage in, or facilitate, tax evasion for any type of tax, in any country.

Tax evasion is where there is a deliberate attempt not to pay the tax which is due. Tax evasion is illegal.

Who does the CCO Policy apply to?

The CCO Policy applies to all Associated Persons of David Lloyd Leisure (as defined by Criminal Finances Act 2017, Part 3). An “Associated Person” is widely defined and includes all individual and corporates who represent, or provides a service for or on behalf of, David Lloyd Leisure. Examples of Associated Persons for David Lloyd Leisure include Directors, employees, contractors, agents, self-employed professionals, and sometimes external suppliers.

All Associated Persons are responsible for adherence to this CCO Policy.

What David Lloyd Leisure is doing

• David Lloyd Leisure has appropriate prevention procedures in place, including training, which support the implementation of this CCO Policy.
• David Lloyd Leisure complies with all relevant legislation.
• David Lloyd Leisure will report any known, or suspected, tax evasion to the relevant external parties

What you need to do as a David Lloyd Leisure team member

1. Complete your Corporate Criminal Offence Training.
2. Be conscious of potential tax evasion risks. If it sounds too good to be true, it probably is!
3. Follow David Lloyd Leisure’s procedures, e.g. supplier take on.
4. Report any known, or suspected, tax evasion to the David Lloyd Leisure’s Whistleblowing hotline. All reports will be treated confidentially.

If you facilitate tax evasion, or did not report known or suspected tax evasion, company disciplinary proceedings may treat your actions as gross misconduct. You may also be subject to criminal proceedings.

Policy Sponsor at the David Lloyd Leisure Board: Chief Financial Officer.