Tax Strategy – UK Group of Companies

Scope

In compliance with section 161, paragraph 19(2) of Schedule 19 Finance Act 2016, the UK Group of Companies (“UK Group”), whose ultimate parent company is GraceKennedy Limited, are publishing their tax strategy for the year ending December 31, 2023 and onwards.

The GraceKennedy Group’s (“The Group”) ‘Code of Ethics and Guidelines for Business Conduct’ dictates that the Group must comply with the laws in the jurisdictions in which it operates. Consequently, the UK Group is committed to the compliance with the relevant laws in the UK and aims to promote strong governance around the tax function and strategy.

Objectives

The strategic tax objectives are noted below:

• Ensure compliance with applicable tax laws, rules, regulations and reporting requirements relevant to the jurisdictions in which it operates.
• Keep abreast of tax laws, their interpretation, and their application, to ensure that business decisions are taken with a complete understanding of the tax perspective.
• Ensure identifiable and foreseeable risks, inherent in our business strategy and operations are actively identified, analysed, mitigated, monitored and reported on. Tax compliance is essential to safeguarding the reputation of the UK Group and is closely assessed by the risk function.
• Establish robust systems and processes, including maintenance of adequate internal controls that will facilitate the accurate calculation of tax liabilities, and payments within respective due dates.
• Foster a transparent and open relationship with HMRC.

Tax Governance, Structure and Organisation

Tax strategy and the tax risk management process are integral parts of the governance framework established by the Board of Directors at the GraceKennedy Group level. The Group Audit Committee evaluates the effectiveness of the Group’s risk management processes and activities. There is a robust compliance culture that is at the heart of the Group’s operations.

All significant tax matters are reported to the Group Audit Committee through the Group tax function and to the UK Board of Directors through the UK Chief Financial Officer. The Group tax function reports into the Group Chief Financial Officer, and the UK Chief Financial Officer reports to the Managing Director of the UK Group.

The Group tax function and other finance personnel keep abreast of tax developments locally and internationally through regular attendance at professional seminars and research. The Group seeks the advice of external consultants for complex tax matters or where clarity is required on any tax matter.

The UK Group liaises with the Group tax function to ensure tax matters are considered from a group perspective and consults on complex tax matters as required. There is open and regular communication with the Group tax function. The UK Group also engages professional external advisers for general tax compliance matters and for the interpretation and application of complex tax matters.

Relationship with HMRC

The UK Group has a good working relationship with HMRC. Embedded in the Group’s core values are the tenets of Honesty, Integrity and Trust which permeates our discourse with the tax authorities.

We aim to:

• Maintain open and respectful communication with HMRC;
• Respond promptly and effectively to any queries raised by HMRC;
• Fully comply with the tax rules and ensure our reporting is accurate and completed in a timely manner;
• Be pre-emptive of any material tax related matters and discuss same with HMRC in advance; and
• Voluntarily disclose any inadvertent errors identified on historic tax returns promptly and completely, with a view to rectifying within the shortest possible time.