Direct Wines Ethical Policy
"Ever since my father first bought wine from Bordeaux back in 1969, working in the right way and treating people well has been central to our success. We remain a proudly independent, family-owned wine merchant, always going the extra mile for our wine and also for our extended family of winemakers, other suppliers, colleagues and customers. From the beginning this business has been based on genuine, respectful partnerships with a focus on long-term sustainable success rather than short-term profit. These are the values of the Laithwaite family-my parents and my brothers - and they continue to characterise our business more than 50 years later."
Tom Laithwaite, Co-Chairman
Introduction and purpose
As a wholly family-owned business we passionately believe that strong ethics are critical to commercial success. We value long-term relationships over short-term return and recognise the responsibility that we share with our suppliers to ensure that our products are sourced and delivered in an ethical and sustainable manner. Our ambition, and that of our founders, the Laithwaite Family, has always been to do business in the right way.
This Ethical Policy describes how our values determine the ways we engage practically with our stakeholders. It is also a commitment to look after our customers, colleagues and partners and to buy and sell our products responsibly. We call this "doing things beautifully" - it means that we take a rounded approach to our strategy and decision-making, looking beyond the short term, and asking honestly whether we are treating our stakeholders fairly.
Our stakeholders
In setting out our ethical commitments, we consider the following groups of stakeholders:
- Our employees
- Our customers
- Our suppliers and their workers
- Industry bodies, charities and the local community
- The natural environment
- Regulators, tax authorities and similar bodies
The steps we take to ensure that we are behaving ethically with respect to these stakeholder groups are set out below.
1. Our employees
We want our customers to be confident that the people who work with and in our business and make our products are always treated fairly, are never exploited, and are never exposed to unsafe working conditions.
Human Rights
Direct Wines respects and supports the dignity, wellbeing and human rights of our employees, the workers within our supply chain and the communities in which they live. We are committed to respecting human rights in line with the UN Guiding Principles on Business and Human Rights.
We comply with the requirements of the UK's Modern Slavery Act. All staff who have relevant roles (including the Board of Directors) are required to complete comprehensive, wine industry specific training on the requirements of the Modern Slavery Act.
Equal Opportunities
We are committed to equality of opportunity for all employees and our employment practices, policies and procedures reflect this commitment. We go beyond our legal obligations in the treatment of our colleagues, offering flexible working, career progression, comprehensive HR benefits, generous discounts on product and excellent working environments.
To support employees who have recently become parents, our Maternity Leave and Paternity Leave policies include enhanced pay for all employees with at least a year's continuous service.
Our Gender Pay Reporting sets out our commitment to pay equality as a critical goal. We operate defined pay scales for approximately 75% of our UK employees and all salaries are always defined by the specific role regardless of gender, race, age or any other variables.
We believe it is in the Company's interest and good business practice to create an environment that supports the diversity of the people within the organisation, recognising their talents and ensuring that all these talents and resources are utilised to the full. To this end we have established employee- led focus groups to promote inclusion and have held events to celebrate diversity and increase awareness of related issues such as unconscious bias.
The company is committed to the promotion of equal opportunities and is opposed to any form of behaviour that treats individuals less favourably, in either a direct or indirect way, on the grounds of race, religious beliefs, disability, creed, colour, ethnic origin, nationality, marital or civil partnership, parental status, sex, sexual orientation, gender reassignment, age or trade union membership, or any other protected characteristic. This is set out in our Equality, Diversity and Inclusion Policy.
The company recognises its responsibilities under the Equality Act 2010 and the spirit and intent of the related Codes of Practice as set out below, but which we consider to be non-exhaustive:
- For the elimination of discrimination on grounds of sex, marital status and or civil partnership status and the promotion of equality in employment.
- For the elimination of racial discrimination and the promotion of equal opportunity in employment.
- For the promotion of equal employment rights for disabled people and individuals who have had a disability.
- For the elimination of discrimination relating to sexual orientation or religious belief and the promotion of equal opportunity in employment.
This policy applies to all aspects of employment with the company, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment. Where we work with agencies who provide temporary or contract staff, we ensure that these agencies adhere to the same high standards and that all workers are verified as eligible to work in the UK.
Direct Wines has a duty to act in accordance with this policy, and therefore for our people to treat colleagues with dignity at all times, and not to discriminate against or harass other members of staff, whether junior or senior to them. The Company does not tolerate any discriminatory practices or behaviour.
Employee benefits and training
In addition to their regular salary and benefits, across all businesses, every permanently employed member of our team participates in a company-wide annual bonus scheme which provides the opportunity to personally share in the success of the business.
In 2019, as part of our 50th anniversary celebrations, we increased our standard annual holiday allowance for all staff by an additional day. Staff who were employed at the time and those who have joined more recently both continue to benefit from the increased allowance.
We support ongoing training and development for members of staff at all stages of their careers, including through Apprenticeships, a Management Training Programme, Personal Development Reviews and supporting staff in gaining professional qualifications and maintaining membership of those professional bodies.
We are proud that our efforts to create a supportive professional environment in which employees can thrive has been recognised by the Great Place To Work Institute, a global authority on workplace culture. We have been accredited in the categories of Large Business, Wellbeing, and Best Workplaces for Women.
2. Our customers
We focus on developing long-term customer relationships and always endeavour to "go the extra mile" to ensure we deliver for our customers - our "no questions asked" Money Back Guarantee is just one example of this commitment. We measure ourselves against the strictest benchmarks to ensure that we continue to achieve the high standards to which we aspire. We are delighted to have been awarded a Distinction in ServiceMark accreditation by the Institute of Customer Service, and to maintain an Excellent rating from Trustpilot, These assessments from both industry bodies and our customers reflect our success in achieving this demanding goal.
We want customers to know that when dealing with us, they can do so with confidence that they remain in control of their data. Direct Wines is committed to compliance with data protection legislation, including but not limited to the UK General Data Protection Regulation and the Data Protection Act 2018. We hold all personal data securely and will only use it as set out in our Privacy Policy. Customers can control the types of communications they receive from us either through our online preference centre or through our Customer Service team. Our Privacy Policy sets out the basis upon which we process our customers' data and how long we retain it.
3. Our suppliers and their workers
Our suppliers include wine suppliers and suppliers of distribution and other services.
Our dealings with suppliers are conducted on a basis of openness, trust and with proportionate benefits for both parties. Like us, many of our wine suppliers are family-owned businesses who understand and share our ethical outlook. The Laithwaite, family and these suppliers have built personal friendships as well as strong business partnerships across successive generations of ownership based on these common values. These are more than just financial relationships. In publishing our supplier payment statistics, we also review our performance against national averages to ensure that our payment policies remain industry-leading.
Because we make wine as well as selling it, we understand the challenges faced by our wine suppliers. We follow ethical principles in the production of our own wines and expect that our suppliers will adopt a correspondingly ethical approach. We expect all of our suppliers to have ethical processes and policies in place throughout their supply chain.
We make our suppliers and partners with whom we have direct contracts aware of our commitment to respect Human Rights and expect that they share our values and align their activities with our commitments. We are compliant with the UK's Modern Slavery Act and all relevant international legislation in this respect. We expect that all of our suppliers, from winemakers to office supplies, are also compliant. Although no specific concern has ever been raised in respect of one of our suppliers, we have occasionally made appropriate enquiries of them when slavery or human rights concerns have been raised in particular wine-growing regions. Whenever this has been necessary, our suppliers have always responded positively and comprehensively.
Direct Wines expects that its business partners adhere to values and principles consistent with its own, including that:
- Business is conducted lawfully and with integrity.
- Work is conducted on the basis of freely agreed terms of employment.
- All workers are treated equally and with respect and dignity.
- All workers are of an appropriate age.
- All workers are paid a fair wage.Working hours are reasonable.
- All workers are free to exercise their right to form and/or join trade unions or to refrain from doing so and to bargain collectively.
- Workers' health and safety are protected. Suppliers are expected to take responsibility for labour and environmental conditions under which products are made and services provided. Direct Wines will seek alternative sources where the conduct of suppliers violates basic human rights and where there is no willingness to resolve any highlighted problems.
These requirements are in addition to all applicable legislation and industry practice, including but not limited to regulations around child labour, working hours and minimum/living wages, and are in addition to our standard requirements for products supplied to be safe, legal and of good quality.
As part of our Supplier Take On procedures, we document that consideration has been given to compliance with relevant policies including our Modern Slavery policy, Anti-Financial Crime and Malpractice Policy and this Ethical Policy. Our contractual terms with suppliers include terms regarding compliance with related laws and regulations.
4. Industry bodies, charities and the local community
We understand that as a wine maker and alcohol retailer we have a responsibility to make customers aware of the need to drink in a responsible fashion. We give our support, both financial and in terms of time and expertise, to relevant initiatives that help and guide consumers to choose the best ways to enjoy our products, such as Drinkaware in the UK. We also take an active role in trade associations such as the WSTA to ensure that we play our part in the way that the drinks trade addresses such issues.
We believe that an ethical business should play a greater part in its local community than purely its role as an employer. To this end, every two years each office selects a local charity (following a nomination process open to all employees) for which the office raises funds directly. This includes a funding scheme in which the business will match donations made by employees to these local charities. We also have a long-standing partnership with a local SEN school in Reading in which they recycle and repurpose our packaging materials to create products for sale. This raises funds for the school and supports the educational development of its pupils in a way which also benefits the environment. For several years we have been pleased to provide financial support to support the development of grassroots rugby in Gloucester, the home of our UK Distribution Centre.
We offer all of our UK-based employees the opportunity to take advantage of a Payroll Giving arrangement - a flexible, tax efficient method by which individuals may opt to make regular donations to a UK-registered charity or recognised good cause of their choice.
5. The natural environment
Environmental Sustainability (Carbon, Water, Waste and Biodiversity)
We have established a specialist sustainability function within our business and have agreed our Environmental Sustainability Strategy.
This is built on our vision of a "Climate-Safe Future", which guides our actions, focussed on five key priority areas:
- The reduction of emissions
- The storage of Carbon
- Improving climate resilience
- Enhancing biodiversity
- Creating other climate leaders
We have set specific and measurable targets to guide action within these priority areas - these reflect our commitment to sustainability and our appreciation that a collaborative approach across our business and wider supply chain is required.
How we will achieve our targets in Carbon:
To reduce operational emissions, we will:
- Continue the process of switching to renewable-sourced electricity
- Further explore opportunities for use of green (biogenic) gas and HVO biofuel
- Increase our use of electric vehicles
- Encourage the uptake of Solar Photovoltaics
- Seek to minimize waste-to-landfill
- Seek to reduce staff commuting
- Ensure no unnecessary business travel
To reduce product emissions, we will:
- Reduce emissions from home deliveries (through increased uptake of electric vehicles and alternative fuels such as HVO).
- Further increase the use of bulk freight and use of low-carbon formats (such as Bag-in-Box, Tetra Pak, and lighter glass bottles).
- Encourage the uptake of renewable energy sources, improved energy and water efficiency, and waste minimisation in our supply chains.
- Support our suppliers with measurement of their emissions, through developing a bespoke wine sector Carbon Calculator (the use of which will be offered to our suppliers at no charge). We will ensure that all top suppliers, representing around 80% of volume, are measuring their Carbon Footprints by 2023/24, at least annually.
How we will achieve our targets in Ecological Care & Regeneration:
We have adopted and communicated a zero-tolerance approach to deforestation, ensuring that (from 1 January 2023) Direct Wines will not source wine from vineyards which have been established through new deforestation. This is in line with our intention to submit Science Based Targets, inclusive of FLAG (Forestry, Land use and Agriculture).
We will partner with local ecologists tasked to survey habitats and create Biodiversity Action Plans for a selection of archetypical vineyards. We will facilitate knowledge sharing so that other vineyard owners can benefit from these surveys and emulate biodiversity-positive actions. We will promote methods (such as regenerative viticulture) which enhance biodiversity, not harm it. To measure our success in achieving these targets, we will measure and track the % of supplier vineyards available as habitat in support of local biodiversity, with the aim of increasing this over time.
Promoting Environmental Sustainability through our supply chain:
We will frequently engage suppliers on various aspects of Environmental Sustainability. This will include our annual Supplier Sustainability Workshops, as well as (approximately quarterly) engagements aiming to create awareness around themes such as:
- Basics of Carbon Footprinting in the wine sector
- Science Based Targets: what are they and how to get started
- Local recycling challenges and opportunities in key wine regions
- Biodiversity Action Plans for vineyards
- Climate Change Adaptation Plans for vineyards
- Carbon sequestration on vineyards
6. Regulators, tax authorities and similar bodies
Direct Wines is committed to meeting all its regulatory and compliance obligations, to maintaining the highest standards and to the promotion of good practice in the prevention of bribery, corruption and malpractice (including criminal Tax Evasion).
All Direct Wines staff and all agents, contractors, joint venture and consortia/franchise partners and other third parties who perform services in association with or on Direct Wines' behalf ("Associated Third Parties") are expected to conduct business lawfully, ethically and with the highest levels of integrity.
Bribery or corruption of any kind in any jurisdiction, regardless of local custom or practice, is strictly prohibited. We ensure that staff have appropriate training in this area and have a confidential whistle blowing process to support the reporting of any potential transgressions. Reports on whistle-blowing activity and bribery are included in the monthly reporting to the board (including nil reports).
We have published our Tax Strategy, describing our approach of prioritising tax compliance over tax planning. We are aware that HMRC has a particular focus on reducing the cost of Duty Fraud to the Exchequer. We recognise our obligation to ensure that all the alcohol we sell is fully traceable and that all relevant taxes have been paid. We are proud to be recognised by HMRC as a business with a low risk in relation to UK taxation.
Board Approval
This policy was formally approved by the Board of Directors on 25 May 2023.
Slavery and Human Trafficking Statement
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 (the Act) and sets out the steps that Direct Wines Holdings Ltd (“Direct Wines”) has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within its business or supply chain. Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Direct Wines is committed to acting ethically and with integrity and transparency in all business dealings.
Our Business
This Slavery and Human Trafficking Statement applies to Direct Wines and its subsidiaries Direct Wines Limited (trading as Laithwaites), a family-owned international wine merchant operating in the UK, USA and Australia, and Averys of Bristol Limited. The UK Group employs around 622 people. There have been no major changes to business or operational structures in the last 12 months which affect our Modern Slavery compliance.
Direct Wines’ business comprises the areas set out below.
- Wine and sourcing: We source wines from a mix of owned and third-party vineyards.
- Wine production: Direct Wines owns or leases wine production and packaging facilities in the UK, USA, France and Australia.
- Marketing and distribution: We market and distribute wines to customers and businesses principally in the UK, although we have a small number of international wholesale customers. The principal brands are Laithwaites, Sunday Times Wine Club and Averys of Bristol.
As part of Direct Wines’ commitment to ensuring that there is no modern slavery or trafficking in its supply chains, it has the following internal policies to ensure that it is conducting business in an ethical and transparent manner:
- Recruitment
Direct Wines conducts robust checks on any new employee including eligibility to work in the UK to safeguard against human trafficking or individuals being forced to work against their will. Where we engage contractors, for example via an agency or a personal services company, the manager responsible for the engagement is required to confirm that the terms of the engagement are in accordance with our Modern Slavery Statement and our Ethical Policy. The Human Resources Department has overall responsibility for overseeing our process for engaging contractors. - Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, we provide appropriate training to our staff. Our Board of Directors completed anti-slavery training in 2019 to demonstrate their commitment to upholding the rights of workers. Training is mandatory for all members of the Wine Buying team who visit vineyards and wineries across the world, and for selected senior members of our operations team who supervise our warehouse, customer contact centre and outsourced mail houses (areas of our business in which there may be greater reliance on agency workers, especially at peak periods of activity). Day to day responsibility for our Modern Slavery compliance sits with our Group Compliance Director, who reports to a Board member. Training is refreshed as appropriate on a regular basis. - Employee Engagement
All employees have an obligation to familiarise themselves with our Slavery and Human Trafficking Statement. This statement is included in the Employee handbook forming part of their contract of employment, and is available at all times via our intranet and website. - Ethical Policy
We publish our Ethical Policy, which sets out our own values and principles in respect of workers’ rights in areas such as:- Freely agreed terms of employment
- The equal treatment of all workers, with respect and dignity
- All workers being of an appropriate age
- All workers being paid a fair wage
- Reasonable working hours
- Freedom for workers to exercise their rights to form and/or join trade unions, or to refrain from doing so and bargain collectively
- The protection of workers’ health and safety
We make our suppliers and business partners aware that we expect them to share these principles in respect of their own workforce. Our Corporate Sales team works closely with the legal and compliance team to ensure that we have considered modern slavery risk, made appropriate enquiries, and received acceptable responses before commencing any sales to potential new customers, including those operating in overseas markets. Our contractual terms with suppliers make specific reference to compliance with the Act. Consideration of our Ethical Policy and Modern Slavery Policy are documented in our Supplier Take On process. This process is periodically reviewed by our Compliance team to ensure the process is being followed, with the most recent review in 2021-22. No Modern Slavery concerns have been identified.
- Whistle Blowing Policy
The business has a whistle blowing policy so that all employees can raise any concerns that they might have without fear of reprisals via a reporting method which is independent of day-to-day line management and has direct access to the Board. A whistle blowing report is made to the Board every month, whether or not any incidents have been reported, and the policy is reviewed annually to ensure it remains appropriate.
Due Diligence for Slavery and Human Trafficking
As part of Direct Wines’ due diligence processes we identify and mitigate risk as follows;
- We identify and assess potential risk areas in our business and our supply chains. These are described below. The Group Compliance Director is responsible for Modern Slavery Risk Assessment.
- Where practical, we mitigate the risk of slavery and human trafficking occurring in our supply chains. This is principally achieved through developing relationships with our suppliers so that we understand their business model and ways of working, and by including contractual terms requiring compliance with applicable legislation (including the Act).
- We monitor potential risk areas in our supply chains.
- We protect whistle blowers.
- We ensure a high level of understanding of the risks of modern slavery and human trafficking in our business by providing training to all relevant staff.
- Our Global Buying Team is known within the industry for the frequency of in-person visits to producer vineyards and wineries. This enables them to see conditions for workers at first hand and develop a strong understanding of what responsibility and sustainability look like in our industry. Board members also visit producer vineyards and wineries overseas from time to time, gaining direct insight into how our partners operate and building relationships at the highest level.
- When incidents of Modern Slavery are identified in regions from which we purchase wine, we make specific enquiries of our suppliers in those regions to gain assurance that their employment practices are legal and ethical. No suspicious incidents have been identified in the current financial year.
Direct Wines does not and will not knowingly support or deal with any business involved in slavery or human trafficking. Direct Wines completes due diligence on its suppliers, where practicable, to satisfy itself that it is trading with a reputable organisation. We expect all those in our supply chain to be opposed to slavery and human trafficking.
As a minimum, Direct Wines expects each entity in its supply chain to adopt ‘one-up’ due diligence on the next link in the chain for those organisations governed by the Act. It is not practical for Direct Wines to have a direct relationship with all links in the supply chain.
Monitoring for developments in anti-slavery legislation
In October 2024, the Modern Slavery Act 2015 Committee published a report recommending that the UK Government should legislate to strengthen the terms of the Act. However, at the time of writing this statement, no draft legislation has yet been tabled. Should the Government propose such legislation, we will act in good time to ensure that we remain compliant.
Risk Assessment: Higher risk areas in the business and supply chain
Wine Suppliers
We source wines directly from growers and producers in more than 20 countries across the world, from the most well-known and well-established wine regions such as France and Italy to regions whose wine is less familiar in the UK market such as Greece, Turkey and Canada. Many of these producers have worked with Direct Wines and its founders, the Laithwaite family, across multiple generations – the relationship between Direct Wines and its suppliers is a close one, and is based on shared values of honesty, integrity and fairness.
The suppliers are agricultural businesses who often rely on a largely temporary/short term labour force at peak activity periods such as the grape harvest. We recognise that this type of workforce may be at increased risk of exploitation. As a result, our wine buying team undertakes targeted training in Modern Slavery risk so that they are in a position to assess conditions for the workforce when they visit our network of producers. Completion of the training is monitored by the Group Compliance Director, who also acts as the first point of contact for our buyers if they wish to discuss potential concerns.
Central to our buyers’ work is their programme of visits in person to suppliers’ wineries and vineyards, which is an important opportunity to view suppliers’ working practices and production operations at first hand. Our experience in growing and producing wine in different countries means that we are well placed to understand the seasonal pressures on local labour markets and have first-hand knowledge of how a responsible producer should look after members of its work force. We remain focussed on building and maintaining strong working relationships with suppliers. Working with our partners on the basis of shared values and strong business ethics will always remain central to our business model.
Where we do buy from producers with whom we are less familiar, our supplier take-on process requires consideration of Modern Slavery compliance and our contractual terms require producers to operate in accordance with all applicable laws, including the Modern Slavery Act. Supplier take-on is overseen by the Finance department.
As part of our risk management, we monitor the trade press to identify instances of reported slavery or trafficking in wine regions from which we source products. No such instances have been noted in the current financial year. In the past we have made enquiries of our producers in regions where such concerns have been reported – in all cases our suppliers have been happy to discuss their arrangements with us and provide assurance.
Agency staff in warehouse
Our practice in this area is documented as part of our Engaging Individual Contractors Policy. Our warehouse in Gloucester in the UK is staffed by a mixture of permanent employees and agency staff. The use of agency staff provides the business with operational flexibility but it is recognised that the types of role which are typically fulfilled by agency staff may present a higher modern slavery risk. We mitigate this risk through a long-standing partnership with a single, reputable local employment agency who comply with the requirements of the Modern Slavery Act. We do not engage any staff on a “casual” basis. Senior members of the Operations team have completed Modern Slavery training.
International Wholesale Sales
In addition to our core business of retail sales in our British, American and Australian markets, our Corporate Sales Team team (based in the United Kingdom) also generates revenue through a number of wholesale clients in markets across the world. These sales are immaterial to the group. The inbound supply chain is no different from that of our core operations but these sales are to business customers across the world, including in developing markets where there may be an increased risk of Modern Slavery.
As part of the due diligence measures we describe above, the Corporate Sales Team has a process to escalate any compliance concerns or uncertainties (including but not restricted to Modern Slavery) for discussion with the Group Compliance Director and the Legal department at an early stage when negotiating with a potential new customer. The purpose of this escalation is to ensure that all aspects of the potential new business relationship (including any Modern Slavery risk) are fully considered and any relevant compliance enquiries are completed before terms are agreed. Members of the Corporate Sales Team who are responsible for these negotiations are included in our Modern Slavery training requirement.
Mitigation of risks:
Training Provision:
Training provision is the responsibility of the Group Compliance Director, who monitors legislativ developments in this area and can ensure the training remains up to date. We continue to expect that each employee for whom training is relevant should receive refresher training at least once every three years. The Group Compliance Director works with departmental heads and our Human Resources department to ensure that new starters who should receive training are identified, and that the training is appropriately tailored to take account of factors such as the individual’s role, the specific risks which may be faced in that role, and any training that individual may have previously received.
This statement has been approved by the Board of Directors on 22 January 2025 and constitutes our slavery and human trafficking statement for the financial year ending 28 June 2024. This statement is available on the Direct Wines website at laithwaites.co.uk.
Our previous Slavery and Human Trafficking Statement is available here:
- Modern Slavery Act 2018
- Modern Slavery Act 2019
- Modern Slavery Act 2020
- Modern Slavery Act 2021
- Modern Slavery Act 2022
- Modern Slavery Act 2023
David Gates
Chief Executive Officer
24 January 2024
Tax Strategy
Direct Wines Group UK Tax Strategy
Direct Wines Holdings Limited (Direct Wines) is fully committed to complying with its statutory tax obligations, including payment and reporting of taxes as required by UK tax laws and regulations.
The UK alcohol sector is subject to higher rates of taxation and more tax regulation than most other sectors. We are proud to make a significant tax contribution to the UK and encourage government to ensure UK alcohol taxation is proportionate.
Approach to UK tax risk management and governance
Direct Wines is privately owned by the Laithwaite family and has been from the founding of the company in 1969. The family take a long-term approach to business with an emphasis on relationship, trust and reputation. This sets the tone for a high standard of corporate and family governance, reflected in our directors whose number include experienced professional executives and non-executives.
The Group Chief Financial Officer is responsible for keeping our board of directors, which meets every second month, and our audit committee, which meets separately from the Board twice a year, appraised of tax matters. The senior management team are responsible for the implementation of the tax strategy and meeting our day to day tax obligations through our tax processes.
We have designed tax processes and controls to ensure we comply with all UK taxes and the Senior Accounting Officer requirements. Responsibility for each tax process is assigned to a person with end to end process overview and knowledge of sufficient detail within the process. We ensure the staff involved are suitably experienced, qualified and trained and have sufficient time and resources to fulfil their responsibilities.
Tax processes are annually reviewed and their efficacy tested, using a risk-based approach, to ensure we remain compliant in the context of any relevant changes in the business or to tax law. This review is performed by an internal governance specialist and external advisors provide an objective assessment against the required standard. The group has a dedicated tax professional to co-ordinate tax management and to provide advice to the business.
Tax Risk Appetite
The Group has historically maintained a low-risk status with HMRC and remains committed to achieving this standard. Tax Planning We take tax into consideration in making business decisions both at a strategic and operational level. Our priority is tax compliance rather than tax planning. When seeking external tax advice, we use reputable advisors from a panel, who understand our approach to tax. We do not engage in tax motivated planning but do take advantage of tax reliefs that Parliament intended (for example R&D).
Relationship with HM Revenue & Customs (HMRC)
We maintain a transparent and collaborative relationship with HMRC and make HMRC aware of significant transactions and business developments with regular meetings and communication.
The Tax Strategy is published to comply with the legislative requirement under paragraph 16(2), Schedule 19, Finance Act 2016 and was formally approved by the Board on 22 May 2024. This strategy relates to the financial year to 28 June 2024.
