Safetykleen Group Tax Policy

Safetykleen Group Services Limited

Tax Policy for 2024-25

Introduction

About Safetykleen
Safetykleen Group Services Limited, as the management company for the Safetykleen group of companies (Safetykleen or the Group), is the World’s leading provider of surface treatment & chemical application services offering a wide range of solutions to address the needs of our diverse customer base. Through it various subsidiaries the Group offers its services throughout Europe and as well as in Brazil and Hong Kong.

Introduction
The Tax Policy sets out the Group’s approach in conducting its tax affairs and dealing with tax risk. The policy supports the Group business strategy and is adopted and followed consistently across the Group, ensuring all local obligations are fully complied with and taxes are reported, paid when due and relationships with the local authorities are managed. The Group maintains a conservative stance to tax risk, aiming to fully comply with the applicable tax regimes, giving due consideration to its corporate and social responsibilities.

SCOPE^[1]

This document has been formally approved by the Safetykleen Board and sets out the Group’s policy and approach in conducting its tax affairs and dealing with tax risk and is made available to all Safetykleen’s stakeholders. Cognisant of evolving tax laws, the Safetykleen Board continues to monitor the Group’s tax policy to ensure this document evolves with that of the tax environment.

The Group tax function works closely with the Group’s businesses to ensure that the tax policy supports the Group business strategy and is adopted and followed consistently across the Group, ensuring all obligations are fully complied with and taxes are managed.

Whilst the Group tax function manages the day-to-day tax risks and adherence to the Group tax policy and strategy, the ultimate responsibility for this lies with the Safetykleen Board.

Group Tax Policy

Safetykleen recognises and seeks to meet the legitimate expectations of its many stakeholders.

We are committed to:

• act with integrity and transparency regarding all our tax compliance and reporting duties;
• control and manage tax risks through regular reviews of our practices and systems;
• ensure our tax policy is consistent with our group strategy and group core values;
• maintain a collaborative and open relationship with HM Revenue & Customs (HMRC) in the UK and with the tax authorities in the countries in which we operate;
• obtain pre-clearance from HMRC in areas of complexity and uncertainty; and,
• give due consideration to the group’s corporate and social responsibilities, reputation and the intention of the relevant tax legislation when considering tax reliefs.

Group code of conduct

The Safetykleen tax code of conduct sets out the principles under which its staff are expected to operate with respect to tax matters in support of the Group tax policy, including adherence to the regulations laid down in the Corporate Criminal Offences act (also refer to the Safetykleen ‘Corporate Criminal Offence Policy’)

Group Tax Compliance
The Group is committed to observe all applicable laws, rules, regulations, and reporting disclosure requirements. A dedicated tax function collaborates with the Group’s businesses to provide the advice and guidance necessary to ensure the Group remains fully compliant. The status of the Group’s tax position is reported annually to the Audit Committee and on a regular basis to the Board. The status of the Group’s tax position is subject to an annual review by the Group’s external audit firm.

Tax Risk Management
Tax is an integral part of the Finance function of the Safetykleen Group. The tax function, members of which have the necessary experience and skill set, observes all applicable laws, rules, regulations, and disclosure requirements in effectively managing tax risk.

Tax risk is managed through strong compliance procedures which are continuously monitored and improved. This ensures transparent financial reporting, accurate and complete tax returns and creates a strong working relationship with HMRC. The Group tax function works closely with the business to identify and track all tax risks that may impact the Group.

The members of the Group tax function keep the Board and relevant staff appraised of all significant changes in tax legislation affecting the business of the Group and are the source of information for any tax related matters.

While the Group aims for certainty on all tax positions it adopts, in areas of tax uncertainty and complexity, the Group will seek specialist advice from an appropriate professional external adviser. Where necessary the Group will consult with the relevant tax authority to gain clarity. The final course of action will be approved by the Group Finance Director with Chief Executive and Board of Director approval being sought where appropriate.

Consistency with Group strategy
The Group tax function, senior management and Board of Directors seek to ensure that the Group’s tax policy is consistent with the Group’s overall strategy and complements the wider governance policy and corporate values. The Group tax function considers relationships with key stakeholders and is cognisant of the wider reputation as a responsible taxpayer when managing the Group’s tax affairs.

Attitude toward tax planning
The Group tax policy aims to support the corporate goals of Safetykleen whilst maintaining its corporate reputation as a responsible taxpayer. All decisions in relation to tax are undertaken in this context. In this context any transaction undertaken must have a primary business purpose that is not tax driven. While the Group will seek to use available reliefs where possible, it is not the intention of the Group to pursue tax planning proposals that are deemed aggressive, carry significant reputational risk from a corporate perspective and/or would negatively impact our relationship with the tax authorities.

Relationships with Tax Authorities
Consistent with the Group’s tax policy is maintaining and developing of a strong working relationship with HMRC in the UK. This includes ensuring that the Group maintains its low risk profile with HMRC. The Group is committed to pay its fair share of tax, including liabilities arising from Stamp Duty Land Tax, Employment Taxes, VAT, Income Tax and Corporation Tax. Openness, honesty, and transparency are strived for in all dealings with the tax authorities.

[1] The policy is compliant with the UK tax strategy publication requirement set out in Part 2 of Schedule 19 FA 2016 and is effective from 31 December 2020