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Useful information relating to Eversheds Sutherland (International) LLP

Carbon Reduction Plan

In 2019, the UK Government passed legislation amending the Climate Change Act 2008 to set a ‘net zero target’ for carbon emissions by 2050.

Consequently, from 30 September 2021, suppliers bidding for Central Government contracts (over £5 million per annum) in the UK must have a Carbon Reduction Plan (CRP), displaying their public commitment to reducing their carbon emissions and helping the government achieve its 2050 Net Zero Target.

As required, our plan includes details of the firm’s UK greenhouse gas emissions, a commitment to being Net Zero by 2050 at the latest, information on sustainability management measures currently in place, and information about Scope 1 and 2, and selected Scope 3 emissions.

The plan will be reviewed at least once a year and receive sign off from the Chief Executive of Eversheds Sutherland (International) LLP.

Download our Carbon Reduction Plan

For any questions, please contact Paul Dunn, Chief Property, H&S and Sustainability Officer;

Money laundering

The law requires us in most cases to ask for evidence of identity.

Please note that we are subject to Money Laundering Regulations and as such we undertake a variety of checks to ‘verify’ our clients. Whilst we endeavour to keep these to a minimum there will be occasions where we are required to request personal documents such as Passports, Driving Licences and/or utility bills. In such circumstances we will discuss those requirements with you as soon as possible.

Our confidentiality obligations, as set out above, are subject to a statutory exception: recent legislation on money laundering and terrorist financing has placed solicitors under a legal duty in certain circumstances to disclose information to the National Crime Agency. Where a solicitor knows or suspects that a transaction on behalf of a client involves money laundering or terrorist financing, the solicitor may be required to make a money laundering disclosure. If, while we are acting for you, it becomes necessary to make a money laundering disclosure, we may not be able to inform you that a disclosure has been made or of the reasons for it because the law prohibits 'tipping-off'. Where the law permits us, we will tell you about any potential money laundering problem and explain what action may need to be taken.

Cyber Essentials scheme

The Cyber Essentials scheme identifies some fundamental technical security controls that an organisation needs to have in place to help defend against Internet-borne threats.

Selected by industry experts, the technical controls within the scheme reflect those covered in well-established standards, such as the ISO/IEC 27000 series, the Information Security Forum’s Standard of Good Practice for Information Security and the Standard for Information Assurance for Small and Medium Sized Enterprises.

Download Eversheds Sutherland (International) LLP Cyber Essentials certificate

Confidentiality undertakings to ensure your information is kept confidential and only processed in accordance with our instructions.

We will normally disclose to you all information material to your affairs and business regardless of the source of that information. However, we will not pass on to you any confidential information about the affairs of any other client.

Insurance distribution and other financial services

Eversheds Sutherland (International) LLP is not authorised by the Financial Conduct Authorit. However, it is included on the register maintained by the Financial Conduct Authority so that it can carry on insurance distribution activity, which is broadly the advising on, selling and administration of insurance contracts. This part of our business, including arrangements for complaints or redress if something goes wrong, is regulated by the Solicitors Regulation Authority. The register can be accessed via the Financial Conduct Authority website at .

The provision of our legal services may also involve other regulated activities in relation to investments within the meaning of the Financial Services and Markets Act 2000 (“FSMA”). Although Eversheds Sutherland (International) LLP is not authorised by the Financial Conduct Authority under the Act for those regulated activities, pursuant to Part 20 of FSMA we may undertake activities such as arranging and advising which are incidental to our legal services or which may reasonably be regarded as a necessary part of our legal services. In doing so we are regulated by the Solicitors Regulation Authority. We cannot provide advice on the merits of financial products but can assist you to execute decisions which you may have made in relation to financial products.

The Law Society is a designated professional body for the purposes of FSMA but responsibility for regulation and complaints handling has been separated from the Law Society's representative functions. The Solicitors Regulation Authority is the independent regulatory body of the Law Society and the Legal Ombudsman is the independent complaints handling body of the Law Society. Any complaints or redress if something goes wrong should be made to the Solicitors Regulation Authority or Legal Ombudsman.

Inside information

If you are a traded company and are subject to the Disclosure and Transparency Rules issued by the United Kingdom's FCA (Financial Conduct Authority) or the EU Market Abuse Regulation (“MAR”), you agree to inform us, when you provide us with any information in relation to your company which you reasonably consider to be inside information, that it is inside information for the purposes of the Disclosure and Transparency Rules and the MAR.

Where requested to do so by you, we will make effective arrangement, having regard to any FCA guidance and the requirements of the MAR, to draw up and maintain an insider list in relation to your company and will provide you with a copy of such insider list as soon as possible on request. We will take such measures as are necessary to ensure that every person whose name is on the insider list acknowledges the legal and regulatory duties in relation to inside information (including dealing restrictions in relation to shares or other financial instruments of your company) and is aware of the sanctions for the misuse or improper circulation of inside information. If, during the course of acting for you, we engage a foreign law firm or another third party to act on your behalf or on your account, we will use our reasonable endeavours to ensure where necessary that the relevant third party agrees, in relation to inside information, substantially the same terms as are set out in this paragraph. In relation to third parties acting for you whom we have not engaged, we will assume that you have secured the necessary agreements in relation to inside information.

We reserve the right to charge you for these additional requirements in accordance with the normal arrangements we have with you.

Financial Services Compensation Scheme

The Financial Services Compensation Scheme (the "FSCS") aims to provide eligible claimants, including individuals and small companies who deposit monies with an authorised deposit taking institution with some protection in the event that that institution collapses. Generally speaking larger businesses are excluded assistance by the FSCS although there are some limited exceptions to this.

The maximum level of compensation that can be awarded is £85,000 (EIGHTY FIVE THOUSAND POUNDS) but it is important to be aware that the £85,000 compensation limit applies to each depositor for the total of their deposits with the institution, regardless of how many accounts are held or whether the depositor is a single or joint account holder. This means that any personal monies held by depositor will be aggregated with any monies already deposited by us in the same institution on their behalf.

Please be aware that some deposit taking institutions may trade under several brands meaning that monies may in fact only be deposited with only one institution despite the use of various names. More information can be obtained from the deposit taking institution, the FSA or a financial advisor.

Should a deposit taking institution collapse we will contact that FSCS and provide them with details of all clients for whom money is held in the relevant account. In order to do this we will be required to obtain our clients consent and we will arrange to obtain this should it become necessary.

The FSCS is an independent body, set up under the Financial Services and Markets Act 2000 (FSMA). For further details please visit the Financial Services Compensation Scheme at .

Where do we hold client monies?

Funds held in connection with matters transacted by Eversheds Sutherland (International) LLP UK offices are held with those clearing banks who are members of the Cheque and Credit Clearing Company Limited unless we are instructed otherwise. A list of its current members can be found on the Cheque and Credit Clearing Company's website .

The Cheque and Credit Clearing Company Limited is an independent body and Eversheds Sutherland (International) LLP does not make any recommendation as to the suitability of any of the financial institutions listed. For further details please visit .

Approach to bribery and corruption

Eversheds Sutherland (International) LLP’s approach to bribery and corruption is one of zero tolerance. All people within Eversheds Sutherland (International) LLP are required to act honestly and with integrity at all times and must not offer or receive gifts and hospitality that could improperly influence, or be perceived to influence, business decision making. We will not directly or indirectly engage in bribery or corruption in any form.

Everyone in Eversheds Sutherland (International) LLP is required to comply with relevant anti-bribery laws and regulations, together with Eversheds Sutherland (International) LLP’s own Anti-Corruption and Gifts and Hospitality Policies. They contain clear guidelines and strict procedures for the prevention of bribery and corruption. We expect all our business partners to have similar policies which apply to all matters involving Eversheds Sutherland (International) LLP or its clients.

Please contact our Director of Risk and Financial Crime and Anti-Bribery Officer, Nic Poole , if there is any suspicion that there has been a breach of our policies.

Eversheds Sutherland (International) Criminal Finances Act 2017 Statement

At Eversheds Sutherland (International) (ESI), we are committed to operating to the highest ethical standards and acting with integrity in all our business dealings and relationships. We take a zero tolerance approach to tax evasion and the criminal facilitation of tax evasion.

Tax evasion is a criminal offence across all countries in which ESI and its clients operate. The Criminal Finances Act 2017 (the CFA) makes it a criminal offence for Eversheds Sutherland (wherever it is situated in the world) to fail to prevent an associated person from deliberately and dishonestly taking action to facilitate UK or foreign tax evasion by a tax payer. In addition to complying with the CFA and any applicable tax evasion laws in the jurisdictions in which we operate, all ESI partners, members and employees (ESI staff) and third parties (which includes any suppliers, intermediaries, foreign law firms or other third parties acting for or on behalf of ESI) have a personal responsibility to ensure that they do not facilitate tax evasion.

We have developed an anti-tax evasion programme following a firm-wide risk assessment of ESI’s business, the territories and sectors in which we operate, the types of individuals and entities with whom we engage, the advice and services we provide and the various tax, firm and retainer risks. This programme includes a CFA policy and associated guidance, the purpose of which is to remind ESI staff (and third parties) of what tax evasion is, why compliance with the provisions of the CFA and the policy is so important, what the consequences are of committing an offence under the CFA, what reasonable prevention measures the firm has implemented and where to get help with any queries, concerns or a suspicion that someone is deliberately facilitating tax evasion. ESI staff are expected to strictly comply with all relevant policies, procedures, processes and controls that the firm has put in place to prevent the criminal facilitation of tax evasion by ESI, our staff or third parties and to complete any training promptly. Any failure to comply with the CFA policy is treated as a serious matter.

The overall effectiveness of our anti-tax evasion programme will be reviewed periodically.

Eversheds Sutherland tax strategy

This strategy sets out the UK tax strategy employed by Eversheds Sutherland (International) LLP, its subsidiary companies and its controlled overseas entities (Eversheds Sutherland). It is published in ccordance with UK law and the requirements of Schedule 19 of the Finance Act 2016.

The Eversheds Sutherland Tax Strategy has been approved by the Executive as being an accurate representation of the tax strategy of Eversheds Sutherland. This strategy is periodically reviewed to ensure its continued accuracy and applies to the year ended 30 April 2023.

30 April 2023

Tax risk management

Eversheds Sutherland’s tax affairs are managed on a day-to-day basis by our Partner Services and Tax Team. The team manages, maintains and routinely reviews internal systems, processes and controls to deliver compliance in line with our UK tax obligations. The team also advises on important, strategic tax issues in other jurisdictions and where there are international implications across Eversheds Sutherland.

It also engages leading tax consultants to support the team in considering tax matters in relation to structural changes and overseeing expansion and compliance with developments in UK and overseas tax regimes, as well as providing expert review on certain tax filings.


The Executive of Eversheds Sutherland has control over and approves tax matters associated with international expansion and the group’s structure and is advised of important tax risks and issues. Governance of Eversheds Sutherland’s UK tax affairs is under the day-to-day management of our Partner Services and Tax Team. This team reports directly to the Finance Director, who forms part of the Executive of Eversheds Sutherland.

Tax planning

Eversheds Sutherland has experienced sustained international growth over recent years, resulting in a more complex business structure. It engages with tax consultants locally to understand structuring options

when extending its operations into a new territory. Structural decision making is primarily commercially driven with a view to maintaining tax efficiency and avoiding unnecessary costs, such as double taxation.

However, such decisions are made in the context of a variety of factors such as regulatory requirements, governance and ability to share profits amongst partners appropriately. Eversheds Sutherland will not

put in place any arrangements which are contrived, artificial, inconsistent with the intention of any applicable legislation or contrary to anti-avoidance legislation.

Eversheds Sutherland expects its partners to behave responsibly in respect of their own tax affairs and to abide by the ethical guidelines set out by its regulators.

Working with HMRC

Eversheds Sutherland is committed to compliance within tax law and practice and has systems, controls and a team in place to manage this. That means paying the right amount of tax in the right place and at the right time. Eversheds Sutherland maintains an open and transparent relationship with HMRC, built on full and honest disclosure and compliance with statutory filing obligations.

Eversheds Sutherland values HMRC’s commitment to the Customer Compliance Manager (CCM) process and has met with its CCM on an annual basis for over 10 years. From our experience this promotes meaningful dialogue between both parties. Regular communication between Eversheds Sutherland and HMRC allows us to deal with tax issues as they arise and to keep HMRC well-informed of any tax matters which arise and to resolve any uncertainties or differences.

Download our Eversheds Sutherland Tax strategy document.