Tax policy

Brief background

Adeptiv Marketing Limited (hereinafter: the “Company”) is a 100% subsidiary of PostNL. PostNL is the Dutch-based postal and logistic solutions provider. As the first listed postal company, PostNL has the largest and most modern network for letters, parcels and e-commerce in the Benelux. In addition, PostNL also operates in Germany, Italy and eight other countries across the world, amongst others in the United Kingdom. The Company is a group entity active in the market of developing and implementing effective customer-contact strategies and has its office in London.

This policies and principles publication applies to the Company and summarises the approach of the Company to dealing with their tax affairs and associated risks. This approach is based on the tax policies and principles that are set and apply within PostNL. Reference is made to PostNL’s Annual Report 2016, Section Governance, Chapter 13 (Our tax policies and principles).

As part of a multinational group, the Company is required to comply with UK legislation for large enterprises to publish their tax strategy. This publication is considered to have complied with this requirement.

Approach to risk management and governance

The Company views tax (meaning all taxes that we face in our businesses) as an important matter for the Company and for its stakeholders. As such, a coherent, responsible and compliant approach towards tax is considered an integral part of doing business. Group Tax, which is a central staff function at the head offices of PostNL, is mandated to oversee this approach towards tax. In that role, Group Tax, inter alia, defines the tax strategy and acts as the central business partner on tax towards all stakeholders, including the Company, whilst maintaining the group tax principles and ensuring the adherence thereto.

The Company strives to be compliant with UK tax laws and regulations and are guided by the relevant international standards (such as OECD guidelines), thereby aiming to comply with the letter as well as the spirit of the laws mentioned.

In cooperation with Group Tax, the Company has mechanisms in place to be able to adhere to their tax principles. It is acknowledged that a robust governance framework is required to maintain control over tax matters and related risks. The tax control framework has been built and developed accordingly. As an example, only reputable firms in the UK are consulted when the Company seeks tax advice or other tax-related services.

Attitude to tax planning

Tax planning involving the Company requires opportunities in this area to have a substantial level of robustness taking into account the principle of business rationale. This means that in addition to factors such as financial impact, complexity and reputation, solid business and/or commercial reasons have to exist. In addition, this means that no (i) contrived or abnormal structures or (ii) secrecy jurisdictions or so-called tax havens for tax avoidance are used. Considering these principles, the Company views its tax risk appetite as moderate.

A multi-disciplinairy and central stance is taken when working on tax planning, involving, from the Company’s perspective, relevant representatives of the Company as well as representatives of PostNL’s tax, treasury, legal and finance departments.

Working with HMRC

The Company strives to build relationships with HMRC based on mutual trust, understanding and transparency. In this respect, the Company views transparency as an integral part of sound tax governanance. To the extent applicable and feasible, the Company will pro-actively disclose issues in order to, in cooperation with HMRC, deal with such issues in an efficient and constructive way.

At the same time, it should be acknowledged that the activities of the Company are, to date, not that substantial that at this point in time the Company has been appointed a CRM of HMRC.

Concluding remark

This publication has been approved by the general management of the Company on 12th December 2017.

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