RECTICEL GROUP UK SUBSIDIARIES - TAX STRATEGY FOR THE YEAR ENDED 31 DECEMBER 2023

This statement is published by Recticel Limited and Recticel Insulation UK Limited (“the Companies”) on behalf of them and their subsidiaries (“the Companies”) in order to comply with their duties under paragraph 19(2) of Schedule 19 of the Finance Act 2016 each to publish, for the financial year ending 31 December 2023, a tax strategy for the UK sub-group of which it was, at 31 December 2022, the head.

This statement is valid for each of the Companies whilst remaining a member of the Recticel Group.

Overview

The Companies act as responsible corporate tax citizens, in compliance with applicable tax law and regulation.

Whilst members of the Recticel Group, the Companies are subject to the Group’s Tax Procedure, the main objectives of which are:

1) To be compliant with all tax laws & regulations and to seek protection against any related risks which may affect future cash flows and/or results. These risks include the possibility of, and consequences of, disagreements with tax authorities on the application of the law;

2) To protect shareholder value in relation to the taxation consequences of all aspects of the Group’s business activity (i) within the overall Group Strategy; (ii) in compliance with relevant laws, disclosure requirements and regulations; and (iii) while protecting Recticel’s reputation and brand.

Risk management and governance arrangements in relation to UK taxation

The approach of the Companies is to establish a governance environment which ensures compliance with all aspects of UK taxation legislation and minimises the risks of real or perceived non-compliance. They achieve this through Group and local policies, the use of robust financial systems, and the use of professional tax consultants to keep them up-to-date with developments in tax regulations and to assist them in remaining compliant.

Attitude towards tax planning

The Companies consider the tax implications of major or complex business decisions, and aim to utilise available tax reliefs and incentives only in line with their intended objectives. They do not engage in artificial tax arrangements, and ensure that tax outcomes are consistent with commercial substance.

Attitude to risk in relation to UK taxation

The appetite of the Companies for tax risk is low. Therefore, they seek to avoid real or perceived noncompliance with UK taxation legislation, so as to minimise the risks of disagreement with tax authorities, financial penalties and damage to the reputation of the Companies and the Recticel Group.

Approach to dealings with HMRC

The Companies are committed to openness and transparency in all our dealings with HMRC, encouraging open dialogue on a timely basis. They aim to submit all tax returns and payments on time, and to respond promptly and cooperatively to any enquiry from HMRC.