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Modern slavery and human trafficking in all their various forms and guises are a crime in the UK and much of the world. They are a violation of fundamental human rights.
The company will not tolerate or condone slavery or human trafficking in any part of our organisation. We have a zero-tolerance approach to modern slavery and human trafficking and are totally committed to acting ethically and with integrity in all activities and business relationships and we expect our supply chain, contractors, employees and all other business partners to commit to the same.
1.1 Imported goods from sources outside the UK and EU are potentially more at
risk of slavery and human trafficking issues therefore the level of
management control required for these sources should be continually monitored.
1.2 The company will not knowingly support or deal with any business involved in
slavery or human trafficking.
The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all persons working for us or on our behalf in any capacity.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.
As part of the Company’s due diligence processes into modern slavery and human trafficking the supplier approval procedure incorporates a review of the controls undertaken by them. The Company also conducts premises visits as deemed necessary to overseas suppliers to ensure due diligence is observed.
Our Policy Statement is available to all employees and all employees are expected to read and understand it. This policy must be clearly and prominently displayed on the Notice Board at all business locations.
The Directors and senior management team will review the Company’s statement in response to any major business, organisational or legislative changes or as a result of any breach or concern regarding modern slavery.
Approved by Steve Westbrook
Effective 22/11/19
Tax Strategy 2019
This strategy applies to Newbury Investments (UK) Ltd and its subsidiaries in accordance with paragraphs 19 and 25 of Schedule 19 to the Finance Act 2016.
This strategy applies from the date of publication until it is superseded.
Newbury Investments (UK) Ltd and its subsidiaries (together “the group”) are committed to full compliance with all statutory obligations and full disclosure to tax authorities. In addition, the group is committed to maintaining an open and transparent relationship with the tax authorities and the high standards of governance expected of our businesses.
Ultimate responsibility for the group’s tax strategy and compliance rests with the Board of Directors. Day to day management of the group’s tax affairs is delegated to the Finance Director and the Finance Department. Together with the group’s Internal Audit Department, the integrity of the group’s financial reporting system, internal controls and risk management framework, expressly those elements relating to taxation, is monitored closely. Any deficiencies are reported directly to the Directors.
The group seeks to minimise the level of tax risk as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with tax obligations.
The group has a low appetite to tax risk and believes that the primary driver for making business decisions should not be based on tax. As such, the group’s key performance metrics are not designed to encourage artificial tax avoidance behaviour. In addition, the group does not engage in tax avoidance schemes.
Management has put in place a strong controls environment and appropriate monitoring processes to ensure that compliance to tax obligations are met at all times. The controls environment is also reviewed regularly.
To ensure that the group remains alert of tax developments and maintains its continued compliance, the group ensures that appropriate training is carried out for staff who manage or process matters which have tax implications and advice is sought from external advisers where appropriate.
Where the group is in doubt as to the tax implications of particulars activities, clarification is sought from HMRC prior to engaging in such activities. The group would only proceed on such matters if it was satisfied that such actions would not result in non-compliance with its tax obligations.
Attitude towards tax planning and level of risk
The group manages risks to ensure compliance with legal requirements and tax obligations in a manner which ensures payment and reporting of all taxes due.
The group seeks to achieve this through:
The group does not engage in tax planning or tax avoidance schemes that are artificially designed to reduce tax payments.
Furthermore, none of the group’s performance metrics are based on the level of tax it pays.
Overall, the group has a low tolerance for tax risk.
Relationship with HMRC
The group seeks to have a transparent and open relationship with HMRC through regular updates and communication with its Client Relationship Manager (CRM).
The group ensures its CRM is kept aware of significant transactions and changes in the business and seeks to discuss any tax issues arising at an early stage.
Where the group is uncertain of the tax treatment of certain activities, it would seek the advice of its CRM prior to engaging in such activity.
Any tax issues identified are communicated to HMRC as soon as reasonable practicable after they are identified.
Overall, the group is proud of its low risk rating as determined by HMRC’s Business Risk Review process.