Tax Strategy

Concord is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The group’s tax affairs are managed to match Concord’s overall high standards of corporate governance to:

Maintain a transparent and constructive relationship with HMRC and global tax authorities

Comply fully with all regulatory and other obligations as a responsible corporate citizen

Reduce the level of tax risk arising from its operations as far as is reasonably practicable

Disclose all relevant facts and identify any transactions or issues where there is potential for the tax treatment to be uncertain

Ensure compliance with legal requirements in a manner that ensures payment of the right amount of tax

Allocate processes to appropriate persons to review and identify key risks and mitigating controls

Seek advice from external advisers where appropriate

This strategy applies to Concord Resources Limited (“Concord”) and to the group of companies headed by Concord in accordance with paragraph 23 of Schedule 19 to the Finance Act 2016. A list of the entities to which it applies is set out below. In this strategy, references to ‘Concord’, ‘the firm’ or ‘the group’ are to all these entities. The strategy has is being published in accordance with paragraph 16(4) of the Schedule.

This strategy applies from the date of publication until it is superseded. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities.

Concord is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The group’s tax affairs are managed in a way which takes into account the group’s wider corporate reputation in line with Concord’s overall high standards of governance.

• Ultimate responsibility for Concord’s tax strategy and compliance rests with the Board;
• Executive management of the group is delegated by the Board to the CEO;
• The Board’s requirement to monitor the integrity of Concord’s financial reporting system, internal controls and risk management framework, expressly includes those elements relating to taxation;
• The Chief Financial Officer (‘CFO’) is the executive with responsibility for tax matters;
• Day-to-day management of Concord’s tax affairs is delegated to the Global Financial Controller, who reports to the CFO;
• Support with the day-to-day management of Concord’s tax affairs and preparation of tax returns is outsourced to KPMG;
• The Board ensures that Concord’s tax strategy is one of the factors considered in all investments and significant business decisions taken;
• The CFO reports to the Board on Concord’s tax affairs and risks during the year.

• Concord operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the group’s financial reporting system;
• Concord seeks to reduce the level of tax risk arising from its operations 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 its tax obligations;
• Processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and mitigating controls in place. These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required;
• Appropriate training is carried out for staff outside the finance team who manage or process matters which have tax implications;
• Advice is sought from external advisers where appropriate.

Concord manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.

When entering into commercial transactions, Concord seeks to take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation.

The level of risk which Concord accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the group’s tax affairs. At all times Concord seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible corporate citizen. In relation to any specific issue or transaction, the Board is ultimately responsible for identifying the risks, including tax risks, which need to be addressed and for determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question.

Concord seeks to have a transparent and constructive relationship with HMRC through regular meetings and communication in respect of developments in Concord’s business, current, future and retrospective tax risks, and interpretation of the law in relation to all relevant taxes.

Concord will ensure that HMRC is kept aware of significant transactions and changes in the business and will seek to discuss any tax issues arising at an early stage. When submitting tax computations and returns to HMRC, Concord discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.

Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.

Concord Resources Holdings Limited

Concord Resources Limited

Concord Resources International Commercial and Trading (Shanghai) Co.Ltd.

Concord Resources Europe B.V