Our overall mission is to be the trusted guardians of our customers’ information and assets, working with them to manage the complexity and risks of today and tomorrow by understanding, protecting and transforming what matters most. Our vision for tax is to act as a trusted and responsible corporate citizen, ensuring compliance with all regulatory and legal obligations. This vision will be achieved by adhering to the following strategic tax objectives:
Operate with accountability and commitment to ensure effective tax risk management and governance (Tax Governance & Risk Appetite):
We are committed to operating an effective tax control framework, focusing on having the right control environment and open communication channels with all relevant stakeholders to support our culture and core values. Our Board has ultimate oversight of internal controls and compliance with legal requirements and ethical standards operating directly or through a designated committee. Our Risk and Safety Committee review and monitor material risk management strategies, systems, policies and processes. Our risk management policy includes prescriptive levels of acceptable risk and the group has a low risk appetite in relation to Tax. Material tax issues are clearly documented and escalated by the Senior Tax Manager – Europe, and VP - Global Tax. Together with our SAO process, this ensures we are proactively identifying, monitoring, assessing and mitigating key risks facing our business.
Through organisation and culture, maximise shareholder value in pursuit of our overall business strategy (Attitude towards tax planning):
We acknowledge that our obligation as a responsible corporate citizen is to pay the correct tax due in line with tax legislation. We therefore do not engage in any tax planning that would compromise our operations or stakeholders. We will seek tax efficiencies where government reliefs and incentives allow and will also seek external advice where the tax legislation is unclear. Our transactions are conducted on an arm’s length basis and in line with OECD principles. As a pro-active business partner we will ensure that we only enter into transactions which are commercial, sustainable and with sound technical support.
Operate with integrity and honesty in dealings with all stakeholders, including tax authorities (Relationship with HMRC):
We are committed to maintaining transparent and constructive working relationships with tax authorities, including HMRC. One of our implicit values is candour – we communicate in an open and truthful way that is constructive and respectful, which applies to our cooperative and timely interactions with tax authorities. Where any enquiries arise, we will assist tax authorities with open and honest disclosure of information, to reach an early resolution. External tax advisers are engaged to assist with the interpretation of tax legislation where this is unclear or open to interpretation, to ensure we minimise the possibility of dispute in relation to our tax position.
Work in agile teams to accomplish far more together than we could as individuals (Business Partnering):
Our goal is to drive value, provide leadership and develop our people. Through teamwork, we ensure that the business is provided with agile and sufficient support in relation to tax. The tax team engage in regular dialogue with local finance teams, and are made aware of any significant transactions prior to their execution. The tax team regularly keep up to date with changes in legislation, and engage with external advisers where appropriate to ensure tax impacts upon the business are understood and escalated internally.