T&L Sugars Limited (“TLS”) Tax Policy 2017

TLS acts with integrity and transparency in the management of its tax matters. We understand that collecting and paying tax is an important contribution to the UK economy. Our approach is to fully comply with the letter and spirit of UK tax law. TLS makes timely and accurate returns that reflect its fiscal obligations to Government.

TLS policy is not to enter into any transaction that has as its main purpose the gaining a tax advantage and not to interpret tax law in a manner opposed to its original spirit.

TLS does not use artificial tax avoidance schemes or tax havens to reduce tax liabilities. All subsidiary companies, including those located outside the UK, are maintained for wholly commercial reasons.

Relationship with HM Revenue & Customs (“HMRC”)

TLS values its strong relationship with HMRC and views this as an important part of its wider tax strategy. We strive to be transparent with HMRC and, in cases of interpretation or complexity, work with them on a real time basis to determine the correct outcome. We work hard to maintain and develop a strong, proactive working relationship with HMRC.

This work in developing and maintaining an open and productive relationship has culminated in HMRC awarding “low risk status” to TLS, which we value greatly.

Financial performance

Minimising tax liabilities by recognising appropriate legislative concessions and reliefs is of benefit to our key stakeholders. The intention of Government by introducing these concessions and reliefs is to help UK businesses to grow which, in turn, aids growth in the UK economy.

TLS seeks to make use of such reliefs where appropriate in order to control tax costs. Whilst seeking to minimise tax liabilities for the benefit of customers and stakeholders, TLS policy is not to take an aggressive interpretation of tax legislation or use artificial tax avoidance schemes. We do not utilise tax incentives or opportunities where these carry significant reputational risk or significant risk of damaging our relationship with HMRC.

Tax governance

Tax is part of the Finance function of TLS and is the ultimate responsibility of the EU Finance Director who is responsible for TLS tax strategy and policies.

As TLS is part of the wider ASR Group, the ultimate decision-making authority resides with the ASR Group Board of Directors in the USA.

Tax strategy and policies are reviewed on an on-going basis by TLS and ASR Group. Tax strategy and policy issues are assessed on a case by case basis by the EU Finance Director in conjunction with ASR Group’s senior Finance team.

Day-to-day tax matters are managed by appropriately qualified in-house specialists, with external advice sought where appropriate.