Ethics & Professional Standards

1. Our Fundamental Ethical Principles

Both the ATT and ACCA Codes of Ethics are founded on five fundamental principles, which we are committed to upholding in all aspects of our work. These are not simply rules we follow — they reflect who we are as a firm.

2. Our Approach to Tax Planning

We are committed to helping our clients manage their tax affairs efficiently, lawfully and transparently. We support legitimate tax planning — making full use of allowances, reliefs and structures that Parliament has expressly made available.

We do not promote, facilitate or advise on aggressive tax avoidance schemes. We draw a clear distinction between:

• •Legitimate tax planning — using reliefs and allowances as Parliament intended, within the spirit as well as the letter of the law.
• •Tax avoidance — artificial arrangements designed to exploit loopholes or achieve a tax outcome that Parliament did not intend. We will not assist with this.
• •Tax evasion — the illegal non-payment or underpayment of tax. We will never assist with this under any circumstances and are legally obliged to report it.

If we are asked to assist with arrangements that we believe cross the line into avoidance or evasion, we will decline to act and, where required by law, make the appropriate disclosures to the relevant authorities.

We adhere fully to HMRC's standards for agents and will never make false or misleading representations on behalf of any client.

3. Conflicts of Interest

We take conflicts of interest seriously. Before accepting any new client engagement, we carry out conflict checks to identify any circumstances that could compromise our objectivity or our duty to an existing client.

Where a potential conflict is identified, we will:

• •Disclose the conflict to all affected parties.
• •Obtain informed consent from those parties if we are to continue to act for both.
• •Decline to act for one or more of the parties if the conflict cannot be appropriately managed.

We will never allow a personal interest — financial or otherwise — to influence the professional advice we give to our clients.

4. Confidentiality

All information we hold about our clients is treated as strictly confidential. We do not discuss client affairs with third parties without the client's prior consent, except where we are required or permitted to do so by law.

Circumstances in which we may be required to disclose confidential information without client consent include:

• •Compliance with our AML obligations, including making a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) where required.
• •Compliance with a legal order or regulatory requirement.
• •Responding to a legitimate enquiry from HMRC or another statutory authority.

In cases where we are required to make a disclosure under our AML obligations, we are legally prohibited from informing the client that a disclosure has been made (the "tipping off" prohibition under the Proceeds of Crime Act 2002).

All members of our team are trained on confidentiality requirements and are bound by confidentiality obligations as a condition of their engagement with the firm.

5. Anti-Money Laundering

We are supervised for AML purposes by the Association of Taxation Technicians (ATT) and comply fully with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended.

As part of our AML obligations, we:

• •Carry out client due diligence (CDD) on all clients, including verifying identity and, where applicable, the identity of beneficial owners.
• •Apply Enhanced Due Diligence (EDD) where required, including for higher risk clients and Politically Exposed Persons (PEPs).
• •Maintain records of all CDD and transactions for a minimum of five years.
• •Provide regular AML training to all members of our team.
• •Report suspicions of money laundering or terrorist financing to the NCA as required by law.

We will not act for any client where we have reasonable grounds to suspect involvement in money laundering, terrorist financing or any other financial crime.

6. Professional Competence & Continuing Development

We are committed to maintaining and developing the professional knowledge and skills of everyone in our firm. All qualified members of our team comply with the CPD requirements of their respective professional bodies (ATT and ACCA).

This includes keeping up to date with:

• •Changes in tax legislation and HMRC guidance.
• •Developments in accountancy standards and practice.
• •Updates to AML regulations and guidance from the ATT and HMRC.
• •Changes to Companies House requirements and company law.
• •Developments in cloud accounting software and digital tools.

We will not take on work that falls outside our area of competence. Where a client's needs require specialist expertise beyond our scope, we will say so and assist in signposting them to an appropriate specialist.

7. Complaints Procedure

We are committed to providing a high quality service to all our clients. If something goes wrong, or you are unhappy with any aspect of our service, we want to hear about it so that we can put things right. The following sets out our formal complaints procedure.

Step 1 — Raise Your Concern

In the first instance, please raise your concern directly with the team member responsible for your work. Many issues can be resolved quickly and informally at this stage. You may do this verbally or in writing.

Step 2 — Formal Written Complaint

If your concern is not resolved to your satisfaction at Step 1, or if you prefer to raise a formal complaint from the outset, please write to our Complaints Handler:

Your formal complaint should include:

• •Your full name and contact details.
• •A clear description of your complaint and the circumstances giving rise to it.
• •The dates and details of any relevant communications.
• •What outcome you are seeking.

Our Response Timeline

• •Acknowledgement — we will acknowledge receipt of your formal complaint within 5 business days.
• •Investigation — we will investigate your complaint thoroughly and impartially. We may contact you for further information during this stage.
• •Full Response — we will provide a full written response within 28 days of receiving your complaint. If we are unable to respond fully within this period, we will write to you explaining why and giving a revised timescale.
• •Resolution — our response will set out our findings, any proposed remedy, and any steps we are taking to prevent recurrence.

Step 3 — Escalation to Professional Body

If you remain dissatisfied following our full response, you have the right to escalate your complaint to our professional bodies:

Please note that the ATT and ACCA will generally expect you to have exhausted our internal complaints procedure before they will investigate.

8. Raising Concerns (Whistleblowing)

We encourage anyone — including clients, staff and third parties — who has a genuine concern about unethical conduct, financial irregularities or any breach of professional standards by our firm or its personnel to raise that concern with us.

Concerns may be raised confidentially by contacting George Isaacs at george@isaacs-co.com or in writing to our registered address.

All concerns raised in good faith will be taken seriously, investigated impartially and treated with the utmost discretion. No one who raises a genuine concern in good faith will be subject to any detriment as a result.

9. Review of This Policy

This Ethics & Professional Standards policy is reviewed annually and updated as necessary to reflect changes in legislation, professional guidance or our firm's practices. The most current version will always be available on our website at www.isaacs-co.com.

Any questions regarding this policy should be directed to George Isaacs at george@isaacs-co.com.