UK TAX STRATEGY UK MODERN SLAVERY STATEMENT
UK Tax Strategy for the UK subsidiaries of The HAVI Group LP
HAVI is a global, privately owned company focused on innovating, optimizing and managing the supply chains of leading brands. Offering services in marketing analytics, packaging, supply chain management and logistics, HAVI partners with companies to address challenges big and small across the supply chain, from commodity to customer.
This strategy applies to the UK subsidiaries1 of The HAVI Group LP in respect of the financial year ending 31 December 2022. The publication of this UK tax strategy statement is regarded as satisfying the UK statutory obligation under Paragraph 19(2), Schedule 19, Finance Act 2016.
Our approach to tax risk management and governance
The HAVI Group LP is committed to observing all applicable laws, rules, and regulations in meeting our tax compliance and reporting responsibilities in all countries we operate.
Accountability for the UK tax strategy rests with the UK Board along with the overall stewardship of our UK risk management systems and internal control environment. The Director of Global Tax is responsible for the management of the tax affairs of the Group and is fully supported in this duty by Senior Management.
The Group manages tax risk by proactively seeking to identify, evaluate, manage, and monitor tax risks to ensure they remain in line with the Group's tax policies.
Our attitude towards tax planning
In structuring our commercial activities, we will consider tax laws (amongst many items) with a view of maximizing the value for our shareholders with careful consideration of potential financial, operational and reputational risks.
This tax policy is aligned with the overall Group's ethics policy and is approved by Senior Management.
Professional opinions are sought as required from reputable independent external advisors particularly in relation to complex tax law or where areas of uncertainty arise in the interpretation of tax laws.
The level of tax risk we are prepared to accept
The UK entities do not have defined levels of acceptable tax risk, but as with other risks, tax is managed within the overall risk framework and risk appetite of the Group. This framework is structured to deliver a level of governance and oversight which is consistent with our risk appetite.
We seek to balance shareholders’ interests for sustained economic value creation with ensuring that any arrangements comply with current tax legislation.
Our approach to dealings with HMRC
We shall be open and transparent with HMRC about our tax affairs and provide all relevant information that is necessary in a timely manner.
1 The UK subsidiaries of the HAVI Group LP include: HAVI Global Solutions Europe Ltd, The Marketing Store Worldwide (Europe) Limited and S.T.I. (U.K.) Limited.
1The UK subsidiaries of the HAVI Group LP include: HAVI Global Solutions Europe Ltd, The Marketing Store Worldwide (Europe) Limited and S.T.I. (U.K.) Limited.
The HAV IGroup LP
3500 Lacey Road , Suite 600 Downers Grove, IL 60515(630) 353-4200
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HAVI Global Solutions Europe Ltd - Modern Slavery Statement 2022
HAVI is a global, privately owned company focused on innovating, optimizing and managing the supply chains of leading brands. Offering services in marketing analytics, packaging, supply chain management and logistics, HAVI partners with companies to address challenges big and small across the supply chain, from commodity to customer. Founded in 1974, HAVI employs more than 10,000 people and serves customers in more than 100 countries.
Main Principles for Suppliers
We are fully aware of the responsibility we bear towards our customers, shareholders, employees and the communities in which we work. Thus, we have given ourselves a strict set of ethical values to guide us in our business dealings which reflects our commitment to respecting all human rights.
We also expect all our suppliers, i.e., all companies who do business with any HAVI company, to adhere to the same ethical and sustainability principles. For this purpose, HAVI has drawn up a Supplier Code of Conduct, which sets the standards for doing business with any HAVI company.
Laws and Ethical Standards
The supplier shall comply with all laws applicable to its business. The supplier should support the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the 1998 International Labour Organization Declaration on Fundamental Principles and Rights at Work in accordance with national law and practice. In the UK, this specifically includes following the letter and spirit of the Modern Slavery Act 2015. This especially applies to:
• Child Labour
The supplier shall comply with laws concerning the minimum age of employees and not employ any individuals who are underage. Where laws permit the performance of light work by minors, the supplier shall only permit a minor to carry out such work where it would not hinder their completion of compulsory schooling or training or would not otherwise be harmful to their health or development. [Reference: ILO Conventions C138 (minimum ages) and C182 (child labour)].
• Forced Labour
The supplier shall make no use of slave, forced, bonded, indentured or compulsory labour and should not retain any employees’ government-issued identification, passports or work permits as a condition of employment.
• Employment Status
Suppliers shall employ workers who are legally authorized to work in their location and facility and are responsible for validating employees’ eligibility to work status through appropriate documentation.
• Compensation and Working Hours
The supplier shall comply with the respective national laws and regulations regarding working hours, wages and benefits.
The supplier shall provide equal employment opportunities to all people in all aspects of employer-employee relations without discrimination based on race, colour, national origin, sex, age, religion, disability, sexual orientation, or any other characteristic protected by law.
Health & Safety
We expect our suppliers to strive to implement the standards of occupational health and safety at a high level.
The supplier complies with applicable occupational health and safety regulations and provides a work environment that is safe and conducive to good health, to preserve the health of employees and prevent accidents, injuries and work-related illnesses.
Business Continuity Planning
The supplier shall be prepared for any disruptions of its business (e.g., natural disasters, terrorism, software viruses, illness, pandemic, infectious diseases).
This preparedness especially includes disaster plans to protect both employees as well as the environment as far as possible from the effects of possible disasters that arise within the domain of operations.
The supplier shall comply with international anti-bribery standards as stated in the United Nations Global Compact as well as local anti-corruption and bribery laws. The supplier may not offer services, gifts or benefits to HAVI employees to influence employee conduct in representing HAVI.
The supplier shall comply with all applicable environmental laws, regulations and standards as well as implement an effective system to identify and eliminate potential hazards to the environment.
We expect our business partners to strive to support HAVI’s climate protection goals through the products and services they deliver (e.g. by providing relevant data on climate protection). In this regard, we also expect our suppliers to take climate protection appropriately into account in their own operations, e.g. by setting climate protection goals for themselves and achieving them or by making the most efficient use of resources and whenever possible use renewable or recyclable resources.
Business Partner Dialog
The supplier shall communicate the principles stated in the Code and detailed above to its subcontractors and other business partners who are involved in supplying the products and services described in the main contract. The supplier shall motivate such parties to adhere to the same standards.
Auditing & Compliance with the Supplier Code of Conduct
HAVI conducts audits or expects supplier compliance in four main areas:
- Supplier Workplace Accountability programme.
- Sedex Members Ethical Trade Audits (SMETA).
- Ethical Trading Initiative (ETI) Base Code.
- Global Quality Safety Requirements (GQSR) compliance programme.
This statement was approved by Douglas Moody-Stuart on August 31, 2022:
Senior Vice President
HAVI Global Solutions Europe Ltd.