Anti-Tax Evasion Policy - ISO - SEC - HELLENIC DEPARTMENT

This Anti-Tax Evasion and Anti-Facilitation of Tax Evasion Policy, designed to give employees and external partners guidance on preventing tax evasion. It may also assist an employer in meeting the "reasonable prevention procedures" defense to the corporate offences of failure to prevent the facilitation of tax evasion.

Is the avoidance to apply a procedure that its result will apply much higher taxes than the laws of the country for a specific transaction.

In example, recently we informed that in a specific European country we cooperate, if a freelance professional issue an invoice to our company which is abroad, he will pay double tax than to issue the same invoice in a local company.

In such a case, it is fair to issue to a local company, instead to a company abroad. But he/she MUST issue an invoice, or he/she have SOLELY the responsibility of tax evasion.

Tax evasion is when our Group avoided to issue an invoice at all and this is against the law! But to issue an invoice, we need to receive directly the specific payment and not our external partner.

Facilitation of tax evasion is when we allow procedures of our partners abroad, that using the Group, in order to avoid Taxation for the profit they have from the cooperation with our Group and this is ALSO against the law. For example, if a partner/facilitator/other from abroad ask us to issue an invoice directly to a student, we can do so ONLY if the EXACT amount is paid in a Bank account that belongs to a company of our Group. By issuing an invoice that we didn't receive the payment, it is possible to facilitate tax evasion and this from today 8th of June 2019 it is prohibited, after the decision of the Presidency of the Group.

ISO-SEC and all other companies of the Group (the “Group”) has a zero-tolerance approach to all forms of tax evasion, whether under Swiss law or under the law of any foreign country.

Employees, Associates/External Partners/Facilitators of the Group, must NOT undertake any transactions which:

(a) cause the Group to commit a tax evasion offence; or

(b) facilitate a tax evasion offence by a third party who is not an official/legal part of the Group (i.e. Organizers/Facilitators/Etc.).

We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter tax evasion facilitation.

At all times, business should be conducted in a manner such that the opportunity for, and incidence of, tax evasion is prevented.

This policy applies to all persons working for the Group or any subsidiary Group or on our behalf in any capacity, including employees at all levels, directors, officers and Associates/Organizers/Facilitators (as defined below), including but not limited to agency workers, seconded workers, volunteers, interns, contractors, external consultants, third-party representatives and business partners, sponsors or any other person associated with us, wherever located.

For Swiss transactions SOLELY RESPONSIBLE is the President of the Group (and not other CEOs and Directors). For transactions that taking place abroad, SOLELY RESPONSIBLE are the Directors and Managers of the Group, who are external partners and they live abroad, in the specific country.

This is 100% applicable, because no matter if they are employees of the Group or External Partners, they have overall responsibility for ensuring that this policy complies with our and their legal obligations, and our employees and Associates/External Partners/Facilitators in their country comply with it.

This policy is adopted by the Group SINCE ITS FOUNDATION, and today 8th of June 2019 it is uploaded to our official websites and be known to all. It may be varied or withdrawn at any time, in the Group’s absolute discretion. Partners in leadership positions are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.

For the purposes of this policy:

Associates includes Group’s contractors or an agent/external partner of the Group (other than a contractor) who is acting in the capacity of an agent, or any person who performs services for and on behalf of the Group who is acting in the capacity of a person or business performing such services.

Tax Evasion means an offence of cheating the public revenue or fraudulently evading UK tax, and is a criminal offence. The offence 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 the conduct is an offence in that country and would be a criminal offence if committed in Switzerland. 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 (whether Swiss tax or tax in a foreign country by another person, or aiding, abetting, counselling or procuring the commission of that offence. Tax evasion facilitation is a criminal offence, where it is done deliberately and dishonestly.

Tax evasion is not the same as tax avoidance or tax planning. Tax evasion involves deliberate and dishonest conduct. Tax avoidance is not illegal and involves taking steps, within the law, to minimize tax payable (or maximize tax reliefs).

Tax means all forms of Swiss taxation, including but not limited to corporation tax, income tax, value added tax, stamp duty, stamp duty land tax, national insurance contributions (and their equivalents in any non-Swiss jurisdiction) and includes duty and any other form of taxation (however described).

As it is well known, ISO-SEC (and also all other companies of the Group) does NOT make directly business in foreign countries.

The business we make so far is under/via External Partners and even if we want to control them (also in order to protect the interests of our Group’s profit/commissions), we aren’t able to make sure that all financial transactions are official and traceable, as payments can take place “hand-to-hand”, because students/clients does not have the ability to make a money transfer to them or to us via a Bank or via PayPal, or the students asking our partners to pay in cash, because they don't want to pay the Bank or the PayPal expenses.

As you understand, our Group it isn't able to control what the Directors and Managers of the Group of each country (no matter if are employees of the Group or External Partners) agreed in "face-to-face" agreements with the students and therefor they have SOLELY the responsibility for ensuring that this policy complies with our and their legal obligations, and our employees and Associates/External Partners/Facilitators comply with it. This is policy that adopted by the Group with NO EXCEPTIONS.

It may be varied or withdrawn at any time, in the Group’s absolute discretion.

Representatives of the Group around the world in leadership positions are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.

The Group has completed a risk assessment and has established procedures governing certain transactions with third parties designed to prevent specific areas of possible tax evasion by a third party, whenever/wherever this is possible to be controlled by the Group. Specific guidance you can find below.

The Group under the specific policy offers employees and partners appropriate training to understand tax evasion, and actions to take to prevent tax evasion.

Employees and Associates/External Partners/Facilitators must at all times adhere to this anti-tax evasion value statement and must ensure that they read, understand and comply with this policy.

It is not acceptable for team members and Associates/External Partners/Facilitators to:

a) Engage in any form of facilitating Tax Evasion or Foreign Tax Evasion

b) Aid, abet, counsel or procure the commission of a Tax Evasion offence or Foreign Tax Evasion offence by another person;

c) Fail to promptly report any request or demand from any third party to facilitate the fraudulent Evasion of Tax by another person, in accordance with this policy; or

d) Engage in any other activity that might lead to a breach of this policy; or

e) Threaten or retaliate against another individual who has refused to commit a Tax Evasion offence or a Foreign Tax Evasion offence or who has raised concerns under this policy

f) An offence under the law of Switzerland or under the law of a foreign country consisting of being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax.

g) The cooperation contract with any External Partner or Employee of the Group who will support or commit Tax Evasion offence or Foreign Tax Evasion offence, automatically will be cancelled.

There is not an exhaustive list of Tax Evasion opportunities. At a more general level, the best defense against Tax Evasion and facilitation of Tax Evasion remains the vigilance of our employees and Associates/External Partners/Facilitators and the adoption of a common-sense approach supported by our clear whistleblowing procedure. In applying common sense, team members must be aware of the following:

• Is there anything unusual about the manner in which an Associate of the Group is conducting their relationship with the Group or the third party (usually a student)?

• Is there anything unusual about the External Partners’ or Associate’s conduct or behavior in your dealings with them?

• Are there unusual payment methods, or even students "free of charge"?

Unusual payment methods and unusual conduct of third parties with Group Associates/External Partners/Facilitators can be indicative that a transaction may not be as it seems.

Our fame is fame of us as an all. This means that if the reputation of ISO-SEC gets destroyed because one or more of our Facilitators or Teachers arrested for Tax evasion, no matter if they are external partners, YOUR reputation as a teacher will be destroyed and as a student the certificate you paid will lose a serious part of its value.

All our employees and External Partners as (but not limited to) Organizers/Facilitators/Teachers/Others, have a responsibility to take reasonable action to prevent harm to ISO-SEC and to other companies of our Group and we hold our partners accountable for their actions and omissions. Any actions that breach the Criminal Finances Act of Switzerland and of their country and the tax laws of wherever we operate brings harm to our Group and will not be tolerated.

You are responsible for properly following the Group’s policies and procedures.

These should generally ensure that all taxes are properly paid. If you are ever asked by anyone either inside or outside our Group to go outside our standard procedures, this should be reported without delay, as someone may be attempting to evade tax.

This should never happen. If there is any suspicion of any intention to evade tax and the transaction if nevertheless finalized, the Group can be criminally prosecuted, subject to a large fine and be publicly named and shamed.

All payments to ISO-SEC and to other companies of the Group, can take place only under 2 ways:

1. Via the Bank Account of our company named “Kingston International Group GmbH”, or

2. Via PayPal (payment that take place via our websites and not via other vocal or written in an email, even if this email is official email of our Group. You pay us only if you pay via our websites ONLY. In ANY OTHER WAY, it is very possible you to pay someone else and, in this case, ask us via a “contact us” page of our websites).

If a student or other client of the Group, pays any person or company that its name it isn’t INTERNATIONAL SECURITY ORGANIZATION – ISO KLG (ISO-SEC) or KINGSTON INTERNATIONAL GROUP GmbH (both are based in Switzerland), then it is sure that he/she doesn’t pay our Group.

This it doesn’t mean that is against our willing and without our approval, as we have official partners in many countries who they are our Franchisees, but if what do you know is that by paying the specific company/person, you pay our Swiss Group of Companies, then we strongly recommend you to contact us and ask us if this is approved by us.

All above are written and uploaded by the Mr. President of our Group (by the title "Mr." President, we mean the only male CEO & President of our Group), and here is his final statement: