Anti-Facilitation of Tax Evasion

AlphaTheta EMEA Limited (“ATE”) is committed to the highest standards of ethics and honesty and we operate a zero-tolerance approach to tax evasion and the facilitation of tax evasion.


Tax evasion occurs when individuals or businesses deliberately omit, conceal or misrepresent information to reduce their tax liabilities. Organisations can be used by associated individuals or businesses to facilitate taxpayer evasion in the UK or overseas.

ATE is committed to preventing the facilitation of tax evasion by associated individuals or businesses anywhere within its operations. We do this through the development of reasonable prevention procedures, carrying out regular due diligence and risk assessments of our activities and creating awareness and a culture of compliance throughout ATE.

About this policy

This policy sets out the expected standards of conduct for all agents, intermediaries, consultants, contractors, suppliers, service providers, dealers, distributors, sub-contractors and any other third party who works for, or on behalf of, ATE anywhere in the world (“Business Partners”).

ATE does not tolerate any form of tax evasion and expects its Business Partners to adhere to the same standards. We recognise that market practice varies across the territories in which ATE does business and therefore what is normal and accepted in one place may not be accepted in another. However, we are fully committed to complying with our obligations under all applicable legislation including the UK Criminal Finances Act 2017 and any other applicable law, rule or regulation of similar purpose and effect applicable to either our Business Partners of ATE (“Anti Tax Evasion Laws”) and ensuring that there is no facilitation of tax evasion by anyone acting on behalf of ATE, anywhere in the world.

Reporting concerns

If you are ever in doubt about a situation you find yourself in and are concerned about a possible breach of this policy or any other form of tax evasion connected with ATE, you must immediately let us know by reporting to your contact at ATE and the ATE Company Secretary (details below).


You must comply with the Anti Tax Evasion Laws and this policy at all times when acting on behalf of ATE.

We may ask that you provide ATE with the appropriate policies and guidelines applicable to your business and supply chain to prevent the facilitation of the evasion of tax. Your policies and management must demonstrate good governance and effective management.

In particular we ask that your policies relating to this matter are clear and communicated to your staff and your supply chain.

What happens if you don’t comply?

Failure to comply with this policy may result in criminal prosecution or a financial penalties under the Anti Tax Evasion Laws. Any breach of this policy may also lead to a termination of your business relationship with ATE.

Our expectations

ATE expects its Business Partners to conduct themselves with integrity, impartiality and honesty at all times when conducting business with, or on behalf of, ATE.

Eliminating the opportunities to facilitate tax evasion effectively requires us to work together to create awareness and have policies and procedures in place for improved traceability, increased transparency and collaboration between ATE and its business partners.

We thank you for your continued support and compliance with this policy.


If you have any queries, relating to this Policy, please contact the Company Secretary at ATE:

AlphaTheta EMEA Limited
Company Secretary
Unit 39, Tileyard Studios,
Tileyard Road, London, N7 9AH, UK
Telephone +44(0)203 761 7220