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and
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“relevant obligations”, in relation to a company, means the company's obligations under—
(a) this Act, where a failure to comply with any such obligation would (were it to occur) be—
(i) a category 1 offence or a category 2 offence; or
(ii) a serious Market Abuse offence or a serious Prospectus offence;
and
(b) tax law;
And failure to produce the compliance policy statement seems to leave them open to a category 3 offence.
The word material is used in the Act so you need to figure out what your gang consider material.
Am guessing you are an entity with US connections so you had better figure out what HO regard as material as if you get in the manure business what HO thinks is material is what is important and not what local Joe thinks.
{been there with similar, especially if they seek a stick to beat you with}
Against that background and the option to rely on outside advice, 2k seems good value.
In addition, I expect the external auditors to be all over this so maybe start with them